The development strategy set out in the consultation document is based around a need for 11,640 additional homes to be identified over the period 2021-41. In keeping with our response to S/JH, we consider that this is inadequate to support the realistic growth objectives of the Greater Cambridge area over the next two decades.

In order to ensure choice, affordability and diversity, the Local Plan must make provision for a sufficient quantity of housing. It must also include a range of housing types and sizes, across a variety of sites and locations. In accordance with the NPPF (paragraph 68), strategic policy-making authorities should identify a sufficient supply and mix of sites over the local plan period. This should include small and medium sites (NPPF, paragraph 69), in addition to large and strategic sites, to ensure the ongoing delivery of housing throughout the plan period.

In terms of the spatial strategy, we strongly object to the approach set out in the consultation document.

We believe that there is an over-reliance on North East Cambridge (the North East Cambridge Area Action Plan – NEECAP Area), the edge of Cambridge and a limited number of new settlements. Whilst some development is proposed in the rural area south of Cambridge (‘Rural Southern Cluster’) the consultation document sets out the following approach for the ‘rest of the rural area’ (page 31, emphasis added):
“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;
• New employment sites in the countryside meeting specific business needs; and
• Windfall development - an allowance for homes on unallocated land, which would need to be consistent with policy requirements in the Plan, including Policy SS/SH: Settlement Hierarchy, which sets out scales of development in different categories of village.”

We strongly object to the proposed development strategy, and in particular the lack of site allocations for the rural areas. The Site at ‘land east of Cambridge Road, Hardwick’ (Site No. 40414) would clearly has the potential to deliver housing and employment that is well-connected to public transport and local services, and that can help the village thrive – fulfilling the objectives for rural areas set out in the first two bullet points as quoted above. The lack of allocations and general approach is considered to lack any sense of forward planning for the existing village settlements, some of which are highly sustainable and represent excellent locations for growth. Existing village settlements make up a significant proportion of the Greater Cambridge area, and form the majority of South Cambridgeshire District. By adopting a reactive-only approach (windfalls-led), there are restricted opportunities for a genuinely plan-led approach to the development of these villages.

We believe that the proposed strategy is in conflict with the policy set out in NPPF (paragraph 79), which sets out the following approach in relation to rural housing:
“To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”

In the context of the NPPF, we urge the Councils to review their development strategy in relation to the rural area.

As shown by Figure 10 of the consultation document (page 40), the proposed spatial strategy represents a decrease in the proportion of growth within rural areas: from 30% in the Structure Plan; to 23% in the currently adopted Local Plans; down to a proposed 18% (for the emerging Greater Cambridge Local Plan). Supporting text states that “the less sustainable rural area would have a lower share of development in the new plan, whilst still providing some limited development to help support our rural communities” (page 40, emphasis added). This represents a gross generalisation: there are many settlements within the rural area that are very sustainable, and there are many that could be made more sustainable if evidence suggests (via a more informative audit of facilities/services) that growth could address a local shortfall of services. We consider that the spatial strategy should include an enhanced and more informative audit of services and local needs for each settlement and support more allocations within the rural area, particularly where it could address local needs that would make a settlement more sustainable, or where there are existing sustainable settlements on public transport corridors such as Hardwick Village.

We are strongly of the opinion that the development strategy should include a range of site allocations within the rural area villages. In addition to harnessing the existing potential of sustainable locations – where there is good access to public transport, etc – the careful planning of village site allocations can deliver benefits and enhancements for the existing population of the settlement (in addition to new residents). Where well-located and well-planned, a new development or settlement extension within a village context can be a catalyst to deliver wider and more holistic improvements, in the best interests of local communities – the Local Plan evidence base should re-assess this and identify where development in or adjacent to settlements could be made to address/support local needs.

Another risk to the proposed strategy is that unplanned, piecemeal development is likely to come forward in and around the villages in the event that housing completions stall on the strategic / new settlement sites. There is a genuine risk that major infrastructure requirements, S.106 triggers and other constraints could delay the delivery of housing completions on several of the major sites. The impact on housing land supply – as experienced within South Cambs District in recent times – is that the tilted balance of NPPF will become engaged and windfall sites will be granted planning permission through an appeals-led approach. This is less likely to deliver the well-planned and sustainable development that could be provided through an allocations-led approach.

The ongoing sustainable development and rejuvenation of existing village settlements should form part of the vision and development strategy of the Greater Cambridge Local Plan. The strategy set out in D/DS includes an over-emphasis on the City and new settlements; it is imbalanced and demonstrates a lack of consideration for the significant proportion of the area which is made up of village settlements. These communities require new housing to meet local needs, and opportunities for sustainable growth and development. We believe that the strategy should be revisited with this in mind.

On a related note, alongside the lack of medium and large-scale site allocations within the rural area villages, the Settlement Hierarchy (Policy S/SH) proposes significant restrictions on the typical scale of development within the villages (depending upon their ranking in the hierarchy). By limiting the size of housing development that can come forward via windfalls, there is a reduced prospect of significant community benefits and affordable housing being delivered through these sites.