OBJECT

NW Bio is promoting the Mill Lane Site, Sawston for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster, and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Sawston and the decision to not release additional land from the Green Belt.

The overall development strategy proposed would be very reliant on the delivery of an extensions to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne are proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predicts high average annual housing delivery rates for the new settlements: Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum; and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon), which has the highest annual delivery rate of current new settlements, is delivering at 295 dwellings per annum. The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, and there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that more realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided, at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not, and will not, provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites, including the Mill Lane, Site, Sawston, that are capable of providing policy compliant levels of affordable housing.

The promoted development by NW Bio, the Mill Lane Site, Sawston, is located within the Green Belt. In these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation, and it is proposed that other land within the Rural Southern Cluster is released from the Green Belt for these reasons. The Mill Lane Site and Sawston generally are very well related to Addenbrooke’s Hospital, Royal Papworth Hospital, Cambridge Biomedical Campus and other employment opportunities within and on the edge of Cambridge.

Additionally, the Mill Lane Site is owned by Northwest Biotherapeutics (NW Bio), a biotechnology company developing novel immune therapies to treat cancer. NW Bio’s DCVax®-L immune therapy for Glioblastoma brain cancer is in the NIHR's Priority Portfolio, and was the first product to receive PIM designation as a Promising Innovative Medicine from the Medicines and Healthcare products Regulatory Agency (MRHA). NW Bio currently has offices in London and is developing an advanced manufacturing and technology development facility in Sawston, where they are working together with Advent BioServices to develop the Vision Centre on the former Spicers site. Advent is one of only a small number of companies in the world that specializes in technology/process development and advanced manufacturing for cell and tissue therapies for cancer and other diseases.

Since our previous submission, significant progress has been made in the physical development of the Vison Centre. Most importantly, it is expected within the next week or two that the Medicines and Healthcare products Regulatory Agency (MHRA) will be granting certification of Phase One of the production facility to ramp-up production to 45 self paying patients per month under their Specials/Compassionate Treatment Program. This milestone approval represents 7 months of testing and MHRA reviews and inspections involving all of the now 39 staff and growing. In turn, this major event for the entire area has been facilitated by the following developments at the plant itself over since our previous submission of representatives, including the following:

• Significant upgrade to two clean room suites to enable these to be Medicines and Healthcare product Regulatory Agency (MHRA) compliant
• Warehouse incorporating Goods in/quarantine and a temperature controlled store
• Two process development laboratories
• Quality control laboratory
• Freezer facility incorporating room for 60 x -80C freezers (currently 30 freezers in place)
• Construction of further office to support freezer facility
• State-of the-art Ultra cold Liquid Nitrogen facility with the capacity to store up to 3,000,000 samples at -196C for third party clients
• Installation of a nitrogen generator which removes and liquifies N2 from the atmosphere – removes the need for weekly deliveries of gas to site
• Cell therapy product goods in/out rooms
• Data management centre containing 3 towers loaded with processers and other essential IT equipment
• Installation of lift shafts and stairs to upper floor
• Fitting out of additional office space
• Creation of corridors for materials, staff and waste

The following infrastructure also has now been put in place to serve the Vision Centre:

• Installation of emergency generator, boiler, uninterrupted power supply, air handling units
• Installation of BT fibre network
• Installation of environmental monitoring equipment and software – monitors temperatures, pressures, air changes, humidity 24/7
• Installation and implementation of a quality management system and the writing of over 1000 regulatory documents
• Installation of electricity supply to futureproof the building and remove the VC from the larger site network
• Implementation of a laboratory information management system
• Development of website
• Awarded licences from the Human Tissue Authority for cell storage
• Underwent inspection from MHRA -awaiting licence to manufacture advanced therapy products for UK Specials programme and for clinical trials

The Vision Centre is located just across the A1301, a 5 or 10-minute walk from the proposed residential site on Mill Lane. The Vision Centre is an advanced manufacturing facility that will produce cell therapy products for the UK and for export to the European Union and other geographies. The development of the Vision Centre will involve the creation of up to 450 new high-value jobs across a wide range of skill levels in phases over the next few years.

Recruitment has also taken place since the submission of previous representations and the total number of employees at the Vision Centre is now 40. These include manufacturing scientists, QA and QC staff, facilities management, IT, clinical coordinator, administration, validation experts, HR and finance personnel. This also includes the recruitment of three apprentices as part of the national network ATAC scheme in cell and gene therapy, with a fourth apprentice to be taken on shortly.

Some of the staff that have been taken on to date are from the local area but other are from elsewhere in UK including London, Stevenage, Bedfordshire, Kent, Berkshire, and Suffolk. It is not possible for all staff to be recruited from the local area as a result of the need to recruit Qualified persons (for regulatory purposes).

A key factor which will affect the pace at which personnel can be hired for these jobs will be the availability of housing nearby to the Vision Centre. A proportion of Vision Centre employees will have to live close to the site because producing and managing living cell products requires unpredictable and varied hours (e.g., when tissues are received from hospitals for processing at any time of the day or evening). The jobs at the Vision Centre are and will continue to be for a range of employees, from school leavers through to PhD level. This will result in increased employment and learning opportunities within Sawston and South Cambridgeshire as a whole, which will have benefits for social inclusion.

The ability of other employees of the Vision Centre to live in close proximity to the site will also have clear benefits for their mental health and well-being, by avoiding the need for significant commuting and promoting opportunities for active forms of travel, such as walking and cycling. The residential development of the Mill Lane Site, Sawston would also provide additional housing that is much needed for nearby surrounding employment sites, including existing sites to the east and north of Sawston; Huawei’s emerging business and research campus at the former Spicers site; Granta Park; Cambridge Biomedical Campus; and the expanding Wellcome Genome Campus.

The Mill Lane Site is also in a location with extensive existing transport access by walking, cycling, bus and train and the Site has good accessibility (a 15 minute or so walk or a short cycle ride) to existing services and facilities within Sawston including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. Having all of these services and facilities within close proximity of the Site will allow future occupants to access these services using sustainable travel modes, thus reducing emissions associated with use of the private car, and will assist the development, and its occupants, in integrating into the wider Sawston community. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

There is also an identified need for affordable housing in Sawston that would not be met by the emerging GCLP.

Paragraph 141 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identified previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The Mill Lane Site, Sawston is well served by public transport (bus and rail) and is well connected with existing cycle routes, and there are future public transport improvements proposed in the surrounding area. Therefore, the release of the site from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

There are three other paragraphs in the NPPF that suggest additional allocations should be made in Sawston and the Rural Southern Cluster. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders.

Sawston contains a good range of services and facilities including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. The promoted development by NW Bio would support existing services and facilities. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

The nearest bus stops are located on Cambridge Road within an acceptable walking distance of the site via the existing footways on Mill Lane and New Road, and provide access to Bus Services Citi 7 and 7A, and are likely to be used by future residents of the site to access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance of the site, and likely to be used by future residents of the site to access existing services and facilities in Cambridge and the wider area surrounding the site.

Therefore, the promoted development by NW Bio at the Mill Lane Site, Sawston is accessible by a range of sustainable modes of transport, and it would be consistent with national policy to direct additional development to this site.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 115 affordable dwellings in Sawston for those with a local connection to the village. The emerging GCLP contains one allocation for residential development in Sawston that it is proposed will be carried forward from the South Cambridgeshire Local Plan (2018) (S/RSC/H/1 (c): land south of Babraham Road, Sawston) for 80 dwellings. Assuming that this site comes forward and delivers a policy compliant level of affordable housing (40%), it can be assumed that this site would deliver 32 affordable dwellings. Accordingly, there would be a residual need for 83 affordable dwellings within the village. The identified need for Sawston would not be met without an additional allocation. It is noted that a Sawston Neighbourhood Plan Area was designated in 2018, and it appears that there has been some evidence gathering since then but a draft plan has not yet been published. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Sawston should seek to accommodate district-wide affordable housing needs and not just those local needs arising in the village and the immediate surrounding area. The promoted development by NW Bio would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages in the Rural Southern Cluster including at Sawston, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is an identified need for affordable housing in the villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages including Sawston, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

As requested in NW Bio’s representations to Section 2.5 Rural Southern Cluster, the Mill Lane Site, Sawston should be released from the Green Belt and allocated in emerging GCLP for residential development.