“The proposed development strategy takes up opportunities to use brownfield land and responds to opportunities created by proposed major new infrastructure.”

• The proposed development strategy does not respond sufficiently and most effectively to the opportunity created by the A428/E-W Rail/OxCam Arc corridor.
• The strategy only makes one allocation within the A428/E-W Rail/OxCam Arc corridor (at Cambourne).
• This does not capitalise fully on the opportunity because:
> Further growth could be delivered along the corridor in a sustainable manner; and
> To be reliable, any growth delivered within the corridor should be delivered in more than just one location in order to provide:
- Greater choice in terms of the location, size, type and tenure of housing that the emerging local plan can offer.
- Greater flexibility and resilience in this arm of the emerging local plan’s housing/development strategy.

“For our new settlements, we propose:
• Evolving and expanding Cambourne into a vibrant town alongside the development of the new station, which will make it one of the best connected and most accessible places in the area; and …”

• Like Cambourne, Papworth Everard will be one of the best connected and most accessible places in the area.
• It too should be allowed to evolve and expand in a proportionate and sustainable manner.
• Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096) could accommodate such, as demonstrated in the updated vision document for the site (December 2021 – submitted through the ‘Submit additional site information’ part of the ‘First Proposals’ consultation).

“We propose some development in the rural area south of Cambridge, the Rural Southern Cluster, where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links, including:
• Employment and tied housing at the Wellcome Genome Campus expansion – confirming the existing planning permission;
• Additional employment at Babraham Research Campus, through releasing the Campus and a modest area of additional land from the Green Belt;
• New smaller sites for housing and employment in villages that have very good public transport access and are close to jobs, some of which are through release of land from the Green Belt; and …”

• It is not clear why the cluster approach has been adopted only in the southern rural area of Greater Cambridge and not other rural parts of plan area.
• The rural southern area is not the only area which lends itself to such an approach. Another obvious location for the adopting the cluster approach to allocating new development is the A428/E-W Rail/OxCam Arc corridor. Significant employment exists in both Cambourne and Papworth Everard already and there is clear logic in allocating new employment and housing to support it.
• Both Cambourne and Papworth Everard have very good public transport links (one of the key criteria applied in the Rural Southern Cluster allocation approach).
• Accordingly, growth should be allocated to Papworth Everard in the same manner as it is proposed to be allocated to villages in the Rural Southern Cluster in order to:
> support and grow the existing employment provision in the area;
> help meet the plan’s housing requirement (which should be based on the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes);
> provide greater choice in terms of the location, size, type and tenure of housing that the plan can offer; and
> provide greater flexibility and resilience in the Councils’ housing/development strategy.

“In the rest of the rural area, we propose a very limited amount of development:
• Small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive; …”

• The proposed development strategy involves growth in only a very limited selection of the settlements in Greater Cambridge.
• Papworth Everard will have excellent public transport access following the delivery of several committed transport infrastructure projects. It is therefore a settlement where housing and employment growth should be being allocated in order to:
> Help the village thrive;
> Support the local economy;
> Help meet the plan’s housing requirement;
> Provide greater choice in terms of the location, size, type and tenure of housing that the plan can offer; and
> Provide greater flexibility and resilience in the Councils’ housing/development strategy.

“In order to provide greater confidence that the identified housing needs in Policy S/JH New Jobs and Homes can be met, and that a continuing supply of housing can be demonstrated, we are proposing to allocate enough sites to provide approximately a 10% buffer so we have the flexibility to deal with unforeseen circumstances. We also propose to provide flexibility in the amount and type of employment land supply to help enable the Greater Cambridge economy to continue to flourish.”

• The ‘additional sources of supply’ which the Housing Delivery Study says will be necessary for gap-filling are not included in the ‘First Proposals’.
• The Councils have included an ‘over-allocation buffer’ of 10% but, as the Study implies, this simply underpins the gap-filling (by building in flexibility and resilience to the supply), but does not constitute gap-filling itself.
• What is needed for effective gap-filling is the short-medium term sources of supply that paragraph 11.19 of the Housing Delivery Study refers to (smaller sites in urban areas and villages), like Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096).
• As paragraph 11.19 points out, spatial options that combine such sites with longer-term sources are better able to deliver across the plan period, and with a smoother trajectory.
• It is also the case that these short-medium term sources will provide greater variety in terms of location, size, type and tenure of housing and will, as stated in paragraph 11.19, “[better-match] the housing supply with demand”. These are essential matters in themselves but are of even greater import when coupled with their ability to gap-fill the housing supply ‘troughs’.
• Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096) and other small-medium sites that are well located in relation to public transport corridors and nodes should therefore be allocated in order to:
> Provide a reliable, smooth supply of housing land over the whole plan period; and
> Provide as much choice as possible in terms of the location, size, type and tenure of housing that the plan can offer.

“The total additional homes to be identified is set out below, taking into account the identified housing need for the period 2020-41, application of the approximate 10% buffer, and current committed housing supply.”


"Homes to provide for Homes 2020 2041
Housing need (rounded) 44,400
Approximate 10% buffer for flexibility 4,440
Total number of homes to provide for 48,840
Current housing supply: comprising adopted allocations, windfall allowance, and dwelling equivalent from communal accommodation allocated or with planning permission 37,200
Total additional homes to be identified 11,640
The sources of housing supply to meet the requirement set out above include the following sites (note some sites will continue to build out beyond 2041 – see individual site sections):"


• Despite being significant, the level of growth proposed is insufficient.
• Through their ongoing extensive and detailed research, Cambridge Ahead (likely the foremost authority on the mater of Cambridge’s economy and growth), have concluded/demonstrated as follows with respect to the ‘First Proposals’:
> If planned for well, higher growth rates than those proposed can be accommodated in a way that improves quality of life for existing and new residents in balance with the needs of the environment and the economy (i.e. in a sustainable way).
> The most recent growth data does not support the projections expressed in the ‘First Proposals’. This raises concerns that the Councils will again serially underestimate the opportunities that high growth creates.
> Cambridge Ahead’s view is that the long run rates in the ‘First Proposals’ are adopting an under-estimate and do not provide the best possible objective assessment of the area’s growth. As a result, the ‘First Proposals’ risk repeating the previous errors in the EEFM forecasts and ignoring the warnings flagged by the Cambridge Ahead’s CPIER.
> The three complementary arguments underlying the recommended annualised growth scenarios for the emerging Plan – KS3/1.1%, with the possibility of the slightly higher KS2/1.5% - have clear flaws, as set out in GL Hearn’s analysis. The historical reversion to the regional mean was notably higher than the recommended figure. The reasons put forward for discounting the recent performance of the higher exogenous sectors have not provided supporting evidence and therefore lack a credible evidential basis. In addition, the suggestion that the high growth between 2011-17 was peaking and is likely to regress to a future regional or national mean has not only been unconvincingly argued, but has now been convincingly rebutted by the continued high growth of the region.
> Accordingly, Cambridge Ahead do not feel that the recommended Plan annualised growth rates stand up to the test of providing an objective assessment for the region’s proposed future growth.
• Having regard to Cambridge Ahead’s findings therefore, higher rates of growth not just can be provided for (because they can be delivered sustainably) but should be provided for (in order that the levels of growth that current trends show are most likely to occur over the plan period are catered for).
• The growth in jobs and homes proposed in the ‘First Proposals’ and subsequent drafts of the emerging local plan should therefore be increased to the higher jobs and homes scenario (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes).


"Location Policy reference / Site name Homes 2020 2041
New settlements S/CB Cambourne 1,950"

• New housing along the A428/E-W Rail/OxCam Arc corridor should not be allocated to Cambourne alone.
• Papworth Everard provides an excellent location for new housing and relates equally well to the A428/E-W Rail/OxCam Arc corridor.
• Allocating land at Papworth Everard for housing would provide:
> Greater choice in terms of the location, size, type and tenure of housing that the plan can offer.
> Greater flexibility and resilience in this aspect of the Councils’ housing/development strategy.


What alternatives did we consider?


“… Our evidence showed that these performed well against our core evidence and better than most other alternative options when considered against key aims of:
• Reducing climate impacts through compact development located to connect homes and jobs, and where active and sustainable travel can be maximised;
• Making best use of suitable safeguarded and brownfield land;
• Making best use of existing and committed key sustainable transport infrastructure; and
• Supporting rural communities to thrive and sustain services.”

“Consideration was given to the provision of a range of sizes and types of sites to give flexibility and help with delivery over the plan period, reflecting our evidence, and a modest element of housing was in principle considered to be an appropriate element of the strategy. Drawing on our evidence, a wide range of sites were considered but many were not preferred due to their impacts, with only a limited number of sites being preferred in Cambridge, close to centres of employment in the southern cluster, and in villages well served by public transport in the rest of the rural area. Allocating large numbers of sites in villages was not a preferred approach, as evidence demonstrated how poorly dispersed strategy performed with regard to a number of issues, but particularly in relation to transport and carbon impacts.”


• Despite what is claimed, the development strategy which has been selected does not perform well against the key aims of:
> Making best use of existing and committed key sustainable transport infrastructure; and
> Supporting rural communities to thrive and sustain services.
This is because:
> it does not capitalise fully and most effectively on the committed key sustainable transport infrastructure along the A428/E-W Rail/OxCam Arc corridor.
> It involves and therefore supports very few rural communities and, therefore, far from thriving, most rural communities will stand still or stagnate during the plan period, rather than growing in a sustainable manner.

• Further, the development strategy is insufficiently diversified because:
> It does not include enough small-medium size allocations to:
- Provide a reliable, smooth supply of housing land over the whole plan period; and
- Provide a suitable level of choice in terms of the location, size, type and tenure of housing that the emerging local plan will deliver.

• As a result the development strategy risks:
> further concentrating growth and wealth in a limited number of areas within Greater Cambridge.
> Not sufficiently capitalising on the significant opportunity offered by the A428/E-W Rail/OxCam Arc corridor.
> Failing to support the successful delivery of the A428/E-W Rail/OxCam Arc corridor as a result of not allocating development which will help fund, support and connect with it.