With regard to the sources of supply, a blended strategy is proposed which draws on multiple approaches including; densification of Cambridge urban area, edge of Cambridge (outside the Green Belt), new settlement expansion, focus on public transport corridors and some dispersal to the villages. We feel the potential for further new settlements should form part of the strategy considerations.

The potential for further new settlements has been dismissed in the assessment of options and the Strategy places unsubstantiated reliance on intensification of existing allocations (North West Cambridge) and accelerated delivery at the new settlements of Northstowe and Waterbeach. In total, this accelerated delivery and intensification is expected to deliver 2,500 new homes over the Plan period. It is unclear how this approach can significantly boost the supply of homes (as sought in Government policy) in comparison with an approach which identifies additional strategic sites for new housing.

The Plan identifies that there is the opportunity for additional homes within the built area of the existing site in North West Cambridge at Eddington (1000 additional homes). Simply making an existing allocation larger does not necessarily mean it will deliver housing at an increased rate. We note that in the draft housing trajectory (Development Strategic Topic Paper) completions at Eddington are shown to increase from 109 to 291 dwellings per annum in the monitoring year 2024/2025. Beyond this, the delivery rate is set at around 250 homes per annum. This is an unrealistic expectation and whilst it would not be disputed that larger sites can contribute more units over the longer term (i.e. beyond the plan period), it is not necessarily the case that larger sites deliver more units per year. Output is dictated by market demand in a particular area, the number of sales outlets (per developer) on site and the capacity of homebuilding for each company on site. Given that a housebuilder would typically build 35-50 homes per sales outlet, the expectation for Eddington would require 5-7 housebuilders on this single site. This is extremely unlikely and does not reflect the historic disposal strategy of the landowner for this site. There appears to be no certainty contained in the evidence base that this additional housing at Eddington can come forward in the period to 2041.

The accelerated delivery at Waterbeach equates to an additional 50 units per annum over the period 2026/27 to 2041/41. A total of 750 additional homes are identified above the planned growth. No evidence is presented in the current consultation as to how this accelerated delivery is to be achieved. Housing delivery at Waterbeach has not yet started (anticipated to commence in 2022). In a similar approach to Northstowe, the draft housing trajectory assumes 250 units from each site per annum. At this stage there is no evidence to support the view that delivery rates can be sustained in these locations at this level.

As advised at para 73 (d) NPPF 2021, strategic policy-making authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites. Without further justification for the densification and acceleration of key schemes within the development strategy the housing delivery element of the Plan would be unsound.

The conclusion must be that further strategic sites need to be allocated for housing to ensure the required annualised supply of housing of 2,326 homes can be achieved. Vistry Group and RH Topham & Sons Ltd do not feel that sufficient evidence has been put forward to show that this can be achieved by a strategy that relies upon increasing the density of existing allocations and accelerating delivery. The identification of a further new settlement or strategic expansion of a sustainably located settlement would provide greater certainty around housing supply over the Plan period and beyond. We feel there is more potential for integrating new development (in the form of new allocations) with planned new infrastructure to the west of Cambridge such as the A428 Improvement Scheme.

The Landowner, RH Topham & Sons Ltd submitted a proposal for a new settlement option at Croxton during the 2019 Call for Sites stage (HELAA reference 40288). This site offers the opportunity to co-ordinate the delivery of new homes and jobs with key elements of committed transport infrastructure. NPPF 2021, para 73 directs strategic-policy makers to consider the opportunities presented by existing or planned investment in infrastructure when considering suitable locations for new development. This must therefore consider potential site opportunities which arise as a result of changes to key infrastructure. In terms of suitability, the Site falls outside of the Cambridge Green Belt, lies wholly in Flood Zone 1 (lowest probability of flooding), outside of any protected landscape/open space designation and is not part of a County Wildlife Site. In addition, there are no abnormal physical constraints to the development of the land.

The Concept Plan included with the earlier submission and provided with these representations shows how a Croxton Garden Village concept within the Greater Cambridge Local Plan administrative boundary could be achieved. The land contained between the new A428 carriageway and the existing road can accommodate circa 1,750 homes and associated supporting infrastructure within the South Cambridgeshire administrative boundary.

The land is in single ownership and can be phased over future Plan periods to continue delivering to 2050. A proposed Garden Village at Croxton would be a unique, practical and exciting opportunity to deliver housing and growth needs using Garden Settlement principles. The proposed location, being bounded by the existing and new A428 road could provide a solution towards meeting the identified social and economic needs and addressing the housing and development delivery during the Plan period and beyond.

The land is controlled by Vistry Group which was formed in January 2020 following the successful acquisition of Linden Homes and the Galliford Try Partnerships & Regeneration businesses by Bovis Homes Group PLC. With developments from Northumberland to Cornwall and Cheshire to Norfolk, Vistry is one of the top five housebuilders in the UK by volume. As one of the country’s leading housebuilders, Vistry has an established reputation for quality that runs through their homes’ design, build, specification and customer service.

Vistry Group has an established track record of taking large strategic sites through Local Plans to planning permission and importantly then delivering the new communities (infrastructure and homes) on the ground in a timely manner.

Introducing further land supply through alternative locations where they are not affected by large-scale upfront infrastructure requirements with long lead-in periods can enable new communities to be established quickly. For example, utilising planned infrastructure projects to direct growth to areas that have the necessary infrastructure capacity and options to influence delivery rates is key. Taking advantage of this immediate opportunity that new transport connections will offer during the Plan period will help create new markets to offer choice and avoid market saturation. The committed A428 dualling scheme should be a key focus for locating new housing in a location with improved connectivity and accessibility.

A Croxton growth option should be considered in the context of extending the C2C corridor scheme to link through to the St Neots rail infrastructure.

When the A428 Black Cat to Caxton Gibbet improvements scheme opens in 2025/2026, the new dual carriageway will become an extension of the existing A421. The certainty created through the committed funding stream and the current Development Consent Order application can be relied upon during the early part of the Plan period which allows major decisions to be made on locating development along this road corridor.

The First Proposals acknowledge that Cambourne could be a broad location for growth where the exact quantity, locations and design will be defined through future plan reviews. It correctly acknowledges that it is too early to identify a specific development area and amount of development.

There is potentially a case for a longer plan period to 2050 to be advanced to allow time to plan the necessary infrastructure but this would not change the need for sufficient land to be identified for the phase to 2041 on deliverable sites.

There is already significant committed growth around Cambourne and at Bourne Airfield which can continue through the Plan period regardless.

Whilst the future EWR route and new station locations are uncertain, all of the published work to date demonstrates that the land at Croxton will not be affected by any of the route options. The site is the only contained land parcel between the Black Cat Roundabout and west Cambridge that does not require any land to be safeguarded to deliver EWR. Should the current or preferred Route Options 1, 2 or 9 be realised, the recent Value Management Scenario testing has shown that all works would occur beyond the site boundaries. This is in stark contrast to any Cambourne-related works.

In summary, the draft development strategy does not currently reflect a robust spatial strategy that is capable of delivering the stated growth levels during the plan period. Some additional sites will be required.

Our Clients acknowledge this is a ‘First Proposals’ stage but it is imperative that progress on the plan preparation is not unnecessarily delayed pending decisions on the EWR route. There is the opportunity to include safeguarded land/corridors within the 2041 plan with a view to locating additional growth in a future plan review to 2050 once the route is fixed/delivered.

For the current Plan, additional land will be required to be identified now that will be compatible with, and complement future growth at Cambourne.