Policy S/DS – Development strategy

2.34. As set out above, it is essential, not just for the prosperity of those living in the area, but also for the wider region within the Oxford-Cambridge Arc and the UK in general, that Greater Cambridge plays its part in delivering economic growth.
2.35. The obligation is on the LPAs to properly plan for and match the provision, and manage the impacts, of housing, including affordable housing, and jobs. The failure to co-ordinate and plan sufficient land for development would result in the Local Plan being found unsound and in turn potential unplanned development arising, in the absence of a 5-year housing land supply. In turn this would have external implications for infrastructure delivery, worsening housing and employment land affordability, increased commuting and carbon impacts. Clearly this is not sustainable in terms of social, economic and environmental impacts. In other words, not delivering sufficient land for jobs and housing would be contrary to climate mitigation strategies.
2.36. The evidence base is, we accept, currently blurred by the effects of COVID-19, but Greater Cambridge is in a strong position given its sectoral mix and there is still high demand for workspace.
2.37. The consultation document makes clear the existing commitments and allocations within the emerging Plan. Northstowe and Waterbeach are progressing, of course, and the hope from the joint authorities is for accelerated pace there. However, there are no changes proposed to overall numbers in those locations, and it is difficult to know how the LPAs expect to force that pace anyway.
2.38. MGH argue that a better pace overall is likely to be delivered by opening up new locations around Cambridge, including those supported by new infrastructure such as a rail station, and other public transport provision. Policy S/DS recognises the opportunity for “Evolving and expanding Cambourne into a vibrant town alongside the development of the new East West Rail station, which will make it one of the best connected and most accessible places in the area”, and identifying the delivery of 1,950 homes in the plan period.
2.39. We understand that Cambourne is identified as a broad location for growth, but with no specific sites identified at this point. The LPA has left the zone for Policy S/CB as, what has been referred to in one of the consultation sessions as a “mysterious circle” because the sites are not yet defined, and suggesting that the delivery of the development here would be later in the plan period. However, MGH can start delivering development at North Cambourne before the rail connections are all in place, because new sustainable transport infrastructure (C2C and Park & Ride) will be delivered in advance of the rail and provide a sustainable mode of transport as an alternative to the car. The C2C scheme will connect Cambridge to Bourn Airfield New Village and Cambourne, and therefore residents of North Cambourne would also be able to utilise this new infrastructure for travel.
2.40. Moreover, whilst Paragraph 23 of the NPPF states that “Broad locations for development should be indicated on a key diagram…” MGH considers that the opportunity exists for greater precision and therefore greater certainty (both spatially and in terms of the tests of soundness) compared to the loosely positioned circle over the existing settlement. At present the uncertainty risks raising concern with local residents unnecessarily as well as making planning for new infrastructure, such as the MRT more difficult.
2.41. The consultation rightly recognises the prospects for Cambourne as one of the best-connected places in the area, due to the planned preferred EWR route and station at North Cambourne. Our vision document and illustrative masterplan shows how these new place-making components can be delivered. The vision document, along with the transport paper that supports this representation, also explore how the new community at North Cambourne can be well connected to the existing settlement by the creation of ‘green bridges’ supporting active travel and high levels of permeability. The proposed location of the North Cambourne railway station will also add significantly to the impetus for these improved connections.
2.42. We also note that, in the transport modelling of the new settlement location options tested, the Cambourne area performed best in terms of active mode share for trips generated and equal best for car trips per dwelling. Again, our transport paper identifies more detailed information to further support these measures and thus further reduce carbon emissions.
2.43. The Development Strategy Topic Paper highlights that future development at Cambourne will address a series of key issues:
• How to integrate with and maximise the opportunity provided by East West Rail;
• The role of the new development in Cambourne as a place, and how it can contribute towards the achievement of net zero carbon;
• The relationship with Cambourne and Bourn Airfield, and how to make the area more sustainable, through the mix of services, employment and transport opportunities offered by the area as whole;
• The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy;
• How the place will develop over time, and the infrastructure needed to support different stages during its development;
• Making effective connections within the new development and with Cambourne for public transport and active travel, as well as connections to surrounding villages so they can also benefit;
• Be structured around, and have local and district centres that can meet, people’s day to day needs within walking distance, including responding to changing retail and working patterns;
• How it can help deliver the Western Gateway Green Infrastructure project, and in doing so positivity engage with its landscape setting, as well as recreation and biodiversity enhancement opportunities such as woodland planting; and
• Take opportunities to reduce flood risk to surrounding areas, that take innovative solutions to the management and reuse of water.
2.44. In addition, the Council’s evidence indicates that large scale development at Cambourne could have landscape impacts and that these would be hard to address. We consider this point further in our response to the HELAA assessment, in the vision document and in a supporting landscape paper prepared by Cooper Landscape Planning.
2.45. Landscape factors will be explored further as part of preparing the draft Local Plan, but the Councils are clear that the design of North Cambourne will need to be ‘landscape led’ in order to minimise impacts in the wider landscape and to have a focus both on place making for the expanded town, and the delivery of the wider vision for green infrastructure set out in the plan. This includes supporting the objectives for ‘Strategic Green Infrastructure Initiative 8: Western gateway multifunctional GI corridors’
2.46. Notwithstanding the issue of landscape, the consultation paper also highlights that, in the context of the significant economic and carbon benefits of locating development at the proposed new rail station at Cambourne, it is considered that the benefits are likely to outweigh the level of landscape harm..
2.47. The supporting text to draft policy S/CB says that, nevertheless, it is ‘too early to identify a specific development area and amount of development’ (hence the ‘mysterious circle’). The document does though go on to provide suggested provisional amounts and timescales associated with Cambourne as follows;
• “..anticipated to start delivering in 2032/2033 after opening of the new railway station, with build out rates based on Housing Delivery Study assumptions for new settlements of gradual increase in annual completions to maximum of 300 dwellings a year;
• 1,950 dwellings anticipated in 2020-2041
• Noting as above that it is too early to identify a specific development area and amount of development for Cambourne broad location, for the purpose of transport and other evidence testing we needed to include a specific number of total dwellings assumed to be present once development is fully built out. We therefore included an assumption of 10,000 dwellings.
Use of this figure is a proxy for a strategic scale development for the purposes of testing at this point, and does not mean that the Councils have made any decisions about the level of housing that should be located in this area.”
2.48. Building on the points set out in earlier sections, MGH advocates that the joint authorities plan for a level of growth that is informed by the economic strategy, and which is noted as plausible, should be pursued. This involves matching the provision of jobs with homes in locations that are capable of higher levels of self-containment and where the options to reduce reliance on private cars are highest.
2.49. The GL Hearn Employment Land Review that forms part of the evidence base stated that the higher employment scenario places greater weight on the fast jobs growth seen in the recent past, particularly in key sectors. By implication, this higher-level outcome is considered possible in the report but not the most likely. As such, the maximum level of homes, associated with the higher employment scenario, is not considered by the report to represent the objectively assessed need for homes in Greater Cambridge.
2.50. Importantly though the Employment Land Review makes recommendations to plan positively for growth and provide for more than the medium level of jobs, in order to provide flexibility (Section 5.3 of the Development Strategy Topic Paper refers).
2.51. In planning positively for growth, MGH agrees that it is appropriate that the new Local Plan provides new land for the identified undersupply in particular types of employment and where those are most suitable to meet sustainable development targets. This is particularly the case where there is a more blended market demand between Research and Development and office uses (former Class B1 b and a).
2.52. The GL Hearn supplementary paper identifies that spreading employment outside of Cambridge would be contrary to prime office market preferences for the city centre and city fringe locations. However, the paper also acknowledges that secondary offices and lab development is likely to be successful around Cambourne with improved accessibility.
2.53. It is also highlighted that industrial and warehousing tend to have a greater reliance on strategic road access rather than public transport and would benefit from the A428 connection. If higher growth is achieved over the next two decades, then it is suggested by the GL Hearn review that the current pipeline of supply is likely to be insufficient without further supply being made in the new plan.
2.54. It is noted that there is a likely undersupply in general industrial premises (Class B2). These premises are required and any losses, particularly in the city, would require re-provision that would need to be either on alternative sites within Cambridge or more likely elsewhere in South Cambridgeshire. Further provision should therefore be made in the new plan to address this anticipated undersupply.
2.55. The GL Hearn paper also anticipates undersupply in warehousing and distribution (Class B8) space, and it is suggested that suitable locations should be identified for small and mid-sized light industrial and distribution units with the drive-in e-commerce further increasing the need for smaller scale warehousing opportunities (final mile centres). This positive approach will ensure a flexible supply, supporting a healthy local economy over the plan period and beyond. Again, the GL Hearn paper recognises the opportunity that Cambourne provides for this sector.
2.56. The GL Hearn analysis therefore allows the expansion of Cambourne to be planned in a way that anticipates the sort of employment spaces that would be likely to be successful in the area, and is well aligned to the mixed employment strategy that the plan is seeking.
2.57. The consultation document states that having identified the objectively assessed need for housing to support the medium level jobs, the next consideration is whether it is appropriate and possible to meet those needs in full within the plan area. The total homes arising from the forecast jobs is identified in section 4 of the strategy topic paper as the objectively assessed need. In translating jobs to homes, this is represented by the scenario whereby the additional homes above the standard method are calculated with a 1:1 commuting ratio (‘consume our own smoke’). The evidence also considered the implications of following existing commuting patterns, which would have the effect of some of the additional homes having to be provided outside of Greater Cambridge.
2.58. Given the Councils’ aims of limiting global carbon emissions, and the key acknowledged role that the location of development plays in carbon emissions, the principle of limiting longer distance commuting is particularly important. In this context, as a matter of principle, the Councils’ intention is to meet the objectively assessed needs for housing identified within Greater Cambridge over the plan period, unless evidence identifies an insurmountable problem with achieving that in a sustainable way.
2.59. In the spatial options for the Western Cluster, including Cambourne, the consultation paper says;
“Headline sustainability benefits noted include:
• Further develops and enhances a new settlement where the groundwork has already been laid, providing access to services and facilities within Cambourne and likely provision of new services and facilities, resulting in positive effects for accessibility, equalities, health, climate change mitigation and air quality.
• Good access to public transport and services, facilities and employment centres elsewhere, once strategic transport infrastructure is complete.

Headline sustainability challenges noted include:

• Access to jobs and services outside Cambourne are beyond reasonable walking and cycling distance, which could encourage car use, despite public transport provision and investment.
• Could result in damage to or degradation of biodiversity assets and green infrastructure.”

MGH fully endorses the first two points, and does not consider that the latter two represent substantial risks in the overall balance. The vision document, and our responses to the HELAA and the Sustainability Appraisal in the following sections of this representation explain why.