Spatial Strategy

1 Paragraph 20 of the National Planning Policy Framework (NPPF) requires strategic policies to set out an overall strategy for the pattern, scale and design quality of places to deliver housing (including affordable housing).

2 Page 29 of the First Proposals document that development strategy for the GCLP “is to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.”

3 In the context of the above statement, it is important to note that Greater Cambridge possesses a network of established sustainable settlements, such as Histon & Impington, which are well served by a wide range of shops and services, significant employment and education opportunities and highly sustainable transport links to the city and beyond. Histon & Impington is unquestionably a sustainable settlement capable of accommodating proportionate growth whilst reducing the impact on climate change. Histon and Impington is to continue its position in the settlement hierarchy as “Rural Centre” a Tier 2 (out of 5) settlement.

4 As set out at page 43 of the First Proposals document Greater Cambridge possess an excellent range of existing public transport connections, with new investment and projects coming on stream now and throughout the Plan period. The existing Guided Busway, bus network, rail network and numerous Park & Ride facilities allow the Councils the opportunity to identify new housing allocations at established rural settlements which benefit from convenient access to these sustainable travel measures. Indeed, the Councils confidence in making sustainable allocations in rural areas should be further enhanced through the investment in other proposed public transport initiatives such as East West Rail, Travel Hubs, further Park & Ride facilities and the new multi modal link to Cambourne. Page 44 of the First Proposals document contends that the proposed development strategy is “heavily informed by the location of existing and committed public transport schemes”.

5 The development strategy pursued by the GCLP is described as a “blended strategy” taken from the development strategy in the adopted Local Plans and four new strategy choices. The blended strategy covers the following: Cambridge urban area, edge of Cambridge, new settlements, villages, public transport corridors, providing homes close to jobs in research parks to the south of Cambridge, integrating development with infrastructure improvements to the west of Cambridge and a further hybrid option which involves Green Belt release.

6 The GCLP contends that this blended strategy will make “best use of existing and committed key sustainable transport infrastructure” and support “rural communities to thrive and sustain services”. In respect of specifically planning for the rural area of Greater Cambridge the development strategy proposes a “a very limited amount of development” at small sites at villages which have “very good public transport access”. The First Proposals document does not define “very good public transport access”. In terms of making specific new allocations in the rural area the GCLP makes a “limited number of new sites for housing at our more sustainable villages”. In this regard, we wish to highlight that Histon & Impington is only separated from the urban area of Cambridge by the A14 and thus has excellent physical and public transport links to the city.

7 To meet the housing need target proposed by GCLP (44,400 dwellings + 10% buffer) the First Proposals document states that there are 37,200 dwellings in the current supply comprising planning permissions, existing allocations and windfall allowance. This leaves a need to identify sites to deliver 11,640 new dwellings. A total of 224 dwellings are proposed for allocation in the rest of rural area, across sites in Melbourn (x2), Caldecote and Oakington. Melbourn is a “Minor Rural Centre”, with Caldecote and Oakington being “Group Villages”, tiers 3 and 4 of the Settlement Hierarchy. Of the new dwelling allocations proposed by the GCLP only 1.9% are directed towards the rest of rural area. This figure rises to 3.2% if the housing delivery associated with supporting jobs at research parks to the south of Cambridge is included.

8 Figure 10 of the First Proposals documents states that 18% of the total housing growth (including existing allocations, planning permissions and windfall allowance) will be directed to the rural area through the GCLP. The 18% is a 5% reduction on growth afforded to rural areas through the current adopted Plans and a 12% drop on the old Structure Plan.

9 It is contended that the blended development strategy and approach to making new allocations will not facilitate the delivery of thriving rural communities or sustain key services over the plan period, supposed aims of the strategy and the GCLP. The blended strategy results in a rather confused and contrived approach to making new housing allocations heavily reliant on strategic sites and New Settlements. The approach taken to allocating new sites for housing in rural settlements appears to be led by the availability of the Councils preferred available sites, rather than one which focuses allocations on the most sustainable settlements and capitalising on the sustainability and climate change benefits provided by existing and proposed public transport infrastructure. Rural Centres such as Histon and Impington are not afforded any new housing growth, with the GCLP instead identifying allocations at lower ranking settlements in the hierarchy. There is no clear rationale provided as to why the development strategy focuses on these lower ranking settlements and seemingly dismissing the prospect of making new allocations at more sustainable settlements. In addition, there is no clear rationale provided as to why growth has been directed to the selected Minor Rural Centre and Group Villages, and not other settlements in the same classification.

10 As stated above, the GCLP will deliver only 3.2% of housing at new allocations in the rural area. Evidently this is not a balanced and flexible strategy which supports established sustainable rural communities. The proposed strategy also stifles the role of Neighbourhood Planning in Greater Cambridge by not allocating specific levels of growth to guide the review of or preparation of Plans in designated Neighbourhood Plan Areas which possess an established sustainable settlement. The approach to guide Neighbourhood Plans by identifying indicative levels of growth from Windfall numbers is not a sound or robust way to proceed.

11 The First Proposals document and accompanying evidence base aims to support rural communities and sustain their existing service provision, but its current approach to making new housing allocations and Neighbourhood Planning will clearly not deliver on this aim. The approach taken to allocating the limited growth in rural areas is site led, disregards the settlement hierarchy, sustainable transport connections and the aim of GCLP which is to locate development in the most sustainable locations to reduce the impact of climate change. Over the plan period the blended development strategy will see the stagnation of sustainable settlements in the rural area through the failure to deliver housing choice (market and affordable) which in turns supports rural businesses and services and the vitality of key rural infrastructure such as bus routes, GPs and schools. The proposed development strategy is not robust and thus unsound in its approach to delivering proportionate and sustainable growth in rural areas.


Housing Supply

12 The NPPF requires local planning authorities to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to their objectively assessed housing need. Paragraphs 60 and 68 of the NPPF make specific reference to the need for a mix and variety of land to be identified for housing.

13 The First Proposals document sets out that 96.5% of new dwelling allocations are proposed at sites which have a capacity of 750 dwellings or more. New Settlements are proposed to provide 38% of the total housing growth over the plan period (existing and new allocations), this is a 15% rise on the current adopted Plans and a 20% rise on the old Structure Plan.

14 The Development Strategy Topic Paper provides the current Housing Trajectory as of April 2021. The existing Northstowe new settlement allocation delivers new housing at a range of 204-365 dwellings per annum between 2020/21 and 2025/26, before dropping to 250 dwellings per annum for the rest of the plan period. The existing Waterbeach new settlement allocation is scheduled to commence housing delivery in 2022/23 at 80 dwellings per annum before rising to 250 dwelling per annum for the rest of the plan period. The GCLP carries forward these existing new settlement allocations and seeks to increase housing delivery at both sites by an additional 50 dwellings per annum from 2026/27 all the way through to 2040/41. Accordingly, both new settlements will be required to deliver dwellings at 300 dwelling per annum for a 15-year period. This increased delivery accounts for 13% of new housing growth proposed to be allocated by the GCLP (1,500/11,596),

15 The four proposed new allocations in Cambridge urban area and the edge of Cambridge account for 67% (7,762/11,596 dwellings) of the new allocated growth through the GCLP.

16 It is acknowledged that the allocation of new settlements and large-scale strategic sites can form a key part of a balanced spatial strategy to bring forward sustainable growth in a district. However, the approach put forward by the Councils does not represent a flexible and balanced approach capable of responding to changing circumstances (NPPF paragraph 33) or providing a mix and variety of sites. Furthermore, the per annum housing delivery targets for the new settlements are very high, particularly at Waterbeach which is yet to deliver dwellings. Bringing forward new settlements and large strategic sites is a complex process which often requires the delivery of significant up-front infrastructure which can sometimes be subject to different funding mechanism and complex land ownership constraints. These issues often impact and delay the delivery of strategic sites, accordingly, the GCLP needs to allocate a variety of different types of sites. The delays in delivery of new settlements in the Greater Cambridge area, along with the necessary strategic infrastructure are well documented and there continues to be a significant lag in the delivery of new homes required at these locations. There is nothing within the proposed plan that provides comfort that these issues will be satisfactorily resolved.

17 Over the current plan period and historically in Greater Cambridge there has been significant pressure placed upon the five-year housing land supply. This in part is due to the current over reliance on strategic sites and failure to allocate proportionate growth at established rural settlements which have fewer delivery constraints. Accordingly, promoting a more balanced development strategy will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP and Neighbourhood Plans should take the lead by positively planning for new housing at established sustainable rural settlements rather than being subject to future speculative development proposals at sites not allocated in a Local Plan when there is a deficit in supply across the plan area.

Windfall Sites

18 To deliver the Councils current proposed objectively assessed needs figure the First Proposals document states that 5,345 of this need will be met by Windfall Sites. This is an increase on 1,125 dwellings on the current adopted Plans. Accordingly, 11% of the total housing need (44,400 – plus a 10% buffer) over the plan period will be met by Windfall Sites and 9.7% (1,125/11,596) of the new housing growth proposed by the GCLP is accounted for by Windfall Site.

19 The Development Strategy Topic Paper explains that the increase in Windfall rates is because the Windfall figures associated with adopted Plans has proven to be an underestimate. It is contended that the new Windfall figure is very high and that an increase is not necessary. Windfall levels in Greater Cambridge are artificially high because of the extended period in the previous decade where a large number of speculative development proposals were approved in a period when the Councils were unable to demonstrate a five-year housing land supply. The significant number of permissions granted in this period are now being delivered and has led to the inflation in Windfall numbers. Many of these permissions, some delivered at appeal, recognised the important role other sustainable settlements can play in delivering housing need and supporting vital local services. This is not recognised in the emerging plan and settlements close to Cambridge and with excellent connectivity are well placed to support the plans wider growth aspirations.

20 The GCLP can plan positively and sustainably by re-allocating windfall numbers to make allocations at established rural settlements or by assigning an overarching housing target to designated Neighbourhood Plan Areas (which contain a sustainable settlement). This approach will assist in guarding against future drops in five-year supply and allow the Council and Neighbourhood Plan Groups to take the lead in planning positively for new housing whilst being mindful of the challenges of climate change.

21 The 10% buffer to be applied to the proposed objectively assessed housing need amounts to 4,400 dwellings. This buffer is largely accounted for by the total Windfall allowance of 5,345 dwellings. Accordingly, it is contended that the 10% is not a true buffer as it is largely accounted for by dwelling numbers which aren’t allocated at specific sites or settlements.

Water Supply Infrastructure

22 The First Proposals document and associated evidence base outline that there is a need for new strategic water supply infrastructure to support growth proposals and to protect the integrity of the chalk aquifer south of Cambridge. It is understood that Water Resource East will publish its Water Management Plan for the region (covering the period to 2050) in 2022. This Plan will likely include significant new infrastructure in the form of a new Fenland reservoir which will be available to supply water from the mid 2030’s.

23 It is noted that the ‘GCLP Integrated Water Management Study) (November 2020) (IWMS) states that higher growth option is not compatible with the planned delivery of new water supply infrastructure. The central growth scenario is considered achievable from a water supply perspective subject to regional scale water supply solution being operational by the 2030s. In this regard the DSTP states that “evidence in November 2020 had indicated that there may be potential for interim measures to support the medium growth level and potentially more, but that the maximum growth level was not possible”. These conclusions further heighten the need for the Councils to undertake further employment forecasting work to identify an appropriate point with the central and higher growth ranges set out by the HERR.

24 The IWMS and DSTP refers to interim measures being available to support growth in the short to medium term of the plan period, however, it is unclear from the published evidence as to what extent these interim measures are being examined and scrutinised as options to assist in the delivery of growth over the short to medium term of the plan period.

25 Whilst continuing to pursue this key matter with Government and the relevant authorities significant work needs to be undertaken to further identify and programme practical interim solutions to overcome this potential constraint to growth in the area. The need to programme interim measures to a specific timescale will become vital in the eventuality that a stepped approach to housing delivery is required to overcome this constraint.