The Policy Direction:
As identified at page 29 of the First Proposals, Policy S/DS sets out the proposed strategy for the pattern, scale and design quality of places created in Greater Cambridge, “not only for the plan period but beyond to 2050”. With regards to this, we reiterate the comments made in response to Policy S/JH and the recommended requirement to extend the Plan period to 2050.

The preferred option for the proposed policy direction is a “blended strategy” (page 38 of the First Proposals) that is strongly focused on growth that directs 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”. The proposed development strategy seeks to take up “opportunities to use brownfield land” and “responds to opportunities created by proposed new infrastructure”. Firstly, the Commissioners wish to highlight that within the document, there is no clarity as to what is meant by development having “the least climate impact”, the term is not defined, leading to ambiguity for developers as to what proposals should be seeking to achieve. This is contrary to the requirements of paragraph 16(d) of the NPPF. Secondly, it is highlighted that the redevelopment of brownfield land can bring its own challenges with regards to sustainability; such sites are usually associated with higher abnormal costs which can sometimes put pressure on viability and the ability to deliver higher standard, sustainable developments.

With regards to the policy direction, the First Proposals document goes onto identify that the Councils propose to meet their housing and jobs needs by taking account of existing planning permissions, “alongside a limited number of new sites in the most sustainable locations”. Page 31 of the First Proposals identifies that in terms of the Councils’ new settlements, it is proposed that Cambourne will be evolved and expanded into “a vibrant town alongside the development of the new East West Rail station, which will make it one of the best connected and most accessible places in the area”.

Strategically Cambourne is ideally located, being approximately 15 kilometres to the west of Cambridge city centre and to the south of the A428, the highway that connects Cambridge with the A1 to the east.

In terms of proposed infrastructure works, there are two significant strategic transport schemes within proximity to Cambourne that are being developed by National Highways and East West Rail, to support future growth within the area. These relate to improvements to the A428 Black Cat to Caxton Gibbet and East West Rail between Oxford and Cambridge.

In terms of the A428 improvement works, National Highways has identified the upgrade of the A428 as a strategically important scheme to enable delivery of the Oxford-Cambridge growth corridor, the delivery of which is identified in National Highway’s ‘RISE2 5-year Delivery Plan’. The delivery of the scheme will have a significant beneficial impact on the potential for development within the locality and importantly for the Site. This is discussed further within the Transport Written Representation prepared by Pell Frischmann on behalf of the Commissioners, which accompanies this representation.

With regards to the East West Rail proposals, of relevance is the central section of the proposed East West railway line which is planned to link Bedford to Cambridge. This will form the final stage of the larger project to link Oxford and Cambridge. This scheme would include the construction of a new station at Cambourne. The route alignment and location of the station, which would either sit to the north-east or south-east of the Site, is yet to be announced. However, as detailed at page 23 within the East West Rail Company’s ‘Making Meaningful Connects Consultation Document’ (2021), it is anticipated that the scheme at Cambourne will support the potential for “new housing and communities within the area” and “bring economic growth to the community, creating more jobs and prosperity” through the new station.

Subsequently, the Commissioners strongly support the identification of growth at Cambourne.

The Source of Housing Supply:
Emerging Policy S/DS goes on to identify the total additional homes that need to be identified within the Plan; 11,640. This figure takes account of the identified housing need for the period 2020-2041 (44,400 homes), application of a 10% buffer (4,400 homes) to provide “flexibility to deal with unforeseen circumstances” and the current committed housing supply (37,200 homes).

As discussed in response to Policy S/JH, the Commissioners consider that the identified housing need of 44,400 should be reviewed and increased to reflect the higher growth scenario. We do not propose to repeat the reasoning for this in response to Policy S/DS (please refer to the Commissioners response to Policy S/JH for completeness) however, based on this scenario, the Commissioners consider that the total additional homes to be identified in the emerging Local Plan between 2020 and 2041 should be at least 21,650, as calculated below:

Plan Period (2020-2041): Housing need based on ‘higher’ growth (53,500 homes) + 10% buffer for flexibility (5,350 homes) – Current housing supply (37,200 homes) = 21,650 homes

If the Plan period were to be extended until 2050, as recommended in the Commissioners’ response to Policy S/JH, based on the high growth scenario, the total additional homes to be identified in the emerging Local Plan should be at least 46,917, as calculated below:

Recommended Plan Period (2020-2050): Housing need based on ‘higher’ growth (76,470 homes) + 10% buffer for flexibility (7,647 homes) – Current housing supply (37,200 homes) = 46,917 homes

Even if the Plan period were to remain as currently proposed (2020-2041), this results in the Council needing to identify a further 10,010 homes. This is a significant increase (approximately 46%) from the current requirement, which the Commissioners consider the Councils need to identify in order for the Plan to accord with national policy, specifically paragraph 20, which requires strategic policies to “make sufficient provision” for (inter alia) housing. Clearly, if the Plan period were to be increased to 2050, the requirement would further drastically increase, with the Council needing to identify 35,277 new homes in addition to the 11,640 identified within the First Proposals.

The sources to meet the housing requirement as set out within the First Proposals are included within the table that follows the ‘Homes to provide for’ table within the document. Upon review of the sources of supply table, the identified supply results in only 11,596 homes being identified between 2020 and 2041, 44 homes less than the requirement as it currently stands. Therefore, and notwithstanding the Commissioners comments regarding the need to significantly increase the housing requirement, the Councils should be at least identifying sufficient supply to meet the identified requirement.

The Commissioners support the identification of new development at Cambourne within the sources of supply table. Page 38 of the First Proposals relates to the Councils’ justification for Policy S/JH and it states, “the most sustainable location for strategic scale development away from Cambridge is to expand on existing development in the Cambourne area, taking advantage of the significant benefits that will be provided by the proposed East West Rail station as well as the improvements already anticipated from the Greater Cambridge Partnership’s Cambourne to Cambridge scheme. This significant improvement in public transport provides an opportunity to grow an existing town, enhancing the critical mass of population, employment and services available locally to those communities”. The evidence that has underpinned this justification is detailed at page 73 of the Councils’ Development Strategy Topic Paper. As discussed in response to Policy S/SD and explored further in the upcoming response to Policy S/CB, the Commissioners concur with this assessment.

The policy goes onto identify that 1,950 homes of the 11,640 additional homes to be identified within the Local Plan, as required by the Councils, should be directed to Cambourne. This equates to approximately 17% of the overall additional homes to be identified supply. However, what is not clear within the First Proposals document is which sites have been included within the current housing supply figure. Therefore, when reviewing the First Proposals document alone, it lacks transparency as to how the overall figure for future development at Cambourne during the Plan period accords with the Councils’ development strategy.

Based on the current 17% distribution figure as discussed above, if the housing need were to be based on the high growth figure resulting in the Councils needing to identify 21,650 additional homes in the currently proposed Plan period, then this would equate to approximately 3,600 new homes to be planned for at Cambourne. This would further increase if the Plan period were to be extended to 2050. Subsequently, the Commissioners’ consider that the Councils should be planning for a significant extension or new settlement within the area. The Commissioners’ Site, The Kingsfields, has the ability to accommodate such growth. As set out within the Vision Document that accompanies these representations, it is considered that the Site could accommodate circa. 4,500 new homes.

Whilst the First Proposals document includes an infographic showing the proposed housing trajectory for the different types of supply (page 35), it does not include a trajectory setting out the anticipated rate of development for specific sites, nor does it consider the reasons as to why this exclusion is considered appropriate. This is a requirement of national policy (as detailed at paragraph 74 of the NPPF) and as such, the Commissioners recommend that the Councils address this within the emerging Local Plan’s next iteration.