Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58200

Received: 13/12/2021

Respondent: Enterprise Residential Developments Ltd and Davison Group

Agent: Carter Jonas

Representation Summary:

It is considered that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

Full text:

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Enterprise Residential Development Ltd and the Davison Group that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

Enterprise Residential Development Ltd and the Davison Group request amendments to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Enterprise Residential Development Ltd and the Davison Group’s representations to Policy S/DS, there are no housing allocations made in most villages, including Elsworth, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages. That information is not reflected in the assessment contained in Table 5.4. The identified need for 12 affordable dwellings in Elsworth will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. It is requested that land at Meadow Drift, Elsworth is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Enterprise Residential Development Ltd and the Davison Group’s representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified need for affordable housing. Elsworth is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 12 affordable dwellings in Elsworth. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Elsworth, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). A ‘mixed significant negative and minor positive effect’ score is also identified for efficient use of land objective (SA8). As set out above there is an identified need for 12 affordable dwellings in Elsworth, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Elsworth, will not be met by the development strategy or the strategy for rural areas. Elsworth contains some services and facilities, including a primary school, public houses, church and sport and social club. The accessibility to services and facilities is good for Elsworth, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land at Meadow Drift, Elsworth is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.