General Comment:
In order to help achieve the aspirations as detailed at page 97 of the First Proposals in relation to the Greater Cambridge’s new towns, Policy S/CB is proposed. Page 99 of the First Proposals states that the policy will “identify Cambourne as a broad location for longer term strategic scale growth as an expansion to Cambourne and will provide continued guidance for the development of the existing allocation at Cambourne West”. It goes onto explain that the policy will set out the intention to identify Cambourne as a broad location for growth in the 2030’s to respond to the opportunity that will be provided by the proposed East West Rail which includes a station at Cambourne.

It is identified at page 100 and 101 of the First Proposals that “given the East West Rail route and station location at Cambourne have yet to be confirmed, it is too early to identify a specific development area and amount of development” at Cambourne. The Church Commissioners for England consider that further clarity is required regarding this point given that Policy S/DS specifically identifies the allocation of 1,950 new homes between 2020 and 2041 at Cambourne. It is not considered that the First Proposals sufficiently explains the link between the two emerging policies, and as such is currently inconsistent with paragraph 16(d) of the NPPF which states that plans should “contain policies that are clearly written and unambiguous”.

Furthermore, the only reference to when additional growth at Cambourne can be expected to come forward, is made at page 99, where “growth in the 2030’s” is briefly mentioned. It is assumed that the Councils would seek to plan for this and allocate land for such development as part of subsequent Local Plan reviews or updates however, this is not explained within the First Proposals. Again, the Commissioners consider greater clarity regarding the intention of the policy and the mechanisms for planning for future growth at Cambourne, are explained and justified.

Large Scale Development:
Whilst it is acknowledged that the identification of broad locations for growth for years 6 and onwards of the Plan is acceptable in policy terms (as set out at paragraph 68(b) of the NPPF), the Commissioners consider that the Site (referred to as ‘The Kingsfields’) presents a specific, developable opportunity that could help the Councils meet their aspirations for new towns. The strengths of the Site are detailed below however, before turning to look at the Site specifics, the Commissions wish to highlight the benefits of large scale development sites, such as The Kingsfields. Please see Deloitte’s accompanying comprehensive written representation for further context regarding the context of The Kingsfields.

The Commissioners’ advocate that the identification of a large scale development site at Cambourne would facilitate for the holistic planning of the area, ensuring that the infrastructure, services and facilities that would be required to serve the community are properly masterplanned. Paragraph 73 of the NPPF supports this and identifies that the “supply of large numbers of new homes can often be best achieved through planning for large scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities”. Therefore, it is recommended that as the Councils consider future sites to accommodate growth at Cambourne, they do so having consideration for the benefits that can be achieved through large scale development.

The Kingsfields:
The below sets out the Commissioners’ reasoning as to why the Site represents a suitable option for the future growth of Cambourne. The reasoning is structured to respond directly to the proposed criteria contained within S/CB; ‘Future development at Cambourne will need to consider’ (as set out page 99 and 100 of the First Proposals). Where appropriate, commentary is also provided in response to the assessment of the Site within the HEELA.

Proposed Future Development Criteria:

• “To integrate and maximise the opportunity provided by East West Rail”
The East West Rail alignment has not yet been confirmed, with the route still being defined within a broad corridor. There are also options for the new Cambourne Station to be located north or south of the A428. Whilst locating the station to the south of the A428 would be closer to the Site, quality pedestrian and cycle connections would ensure that a northern station would also be accessible from the development, and therefore locating the station north or south of the A428 presents no concern in terms of accessibility.

• “The role of the new development in Cambourne as a place, and how it can contribute towards the achievement of net zero carbon”
Whilst the Councils do not think that further new settlements should be allocated within Greater Cambridge (page 39 of the First Proposals), as has been identified within the Commissioners’ representation in response to emerging Policy S/JH, it is considered that the Councils’ housing requirement should be significantly increased to accommodate the potential higher levels of growth identified within the evidence base. Subsequently, a new settlement within the locality of Cambourne (which as identified within the First Proposals at page 39 as “the most sustainable location for development away from Cambridge”) should be explored as a potential opportunity to accommodate some of this uplift. The Site represents a potential suitable option in that it can be developed to provide an extension to Cambourne whilst still providing sufficient land for it to evolve and organically grow into a new settlement.

On behalf of the Commissioners’, JTP has prepared a vision document for the Site, titled, ‘A Vision for the Kingsfields’ (“the Vision Document”). The vision is based on the notion “little steps become great strides”, meaning that whilst the development of a new settlement within this locality is very much possible, this is a longer term aspiration. The Commissioners acknowledge that the journey towards this begins with a series of steps that can lead to the realisation of a new place in a way which is both sustainable and where people want to be. The creation of a community that helps forge the future identity of the place is crucial. Evolving from this and taken in the right direction, will allow the Site to then make great strides towards a genuinely zero carbon, super-connected place, and one where the community actively provides for itself (please refer to the Vision Document for further commentary as to how this could be achieved). This is why the Commissioners consider that the Site is suitable for accommodating both the current level of growth directed towards Cambourne within the First Proposals and future requirements.

As this criterion relates specifically to achieving net zero carbon, the Commissioners wish to highlight the strong focus on sustainability that has helped shaped the vision for the Site. The Vision Document is supported by work undertaken by Sustainability Consultant, Hoare Lea. Hoare Lea has formulated a ‘Sustainability Charter’ for the Site which helps to define a pathway and enable the realisation of the sustainability aspirations for the Site. The Sustainability Charter is based on five defined factors or ‘capitals’ – natural, human, social, economic and physical so, whilst responding to the challenge of climate change, it also encompasses health and wellbeing and biodiversity. The Sustainability Charter therefore goes much further than solely identifying how the Site could achieve net zero carbon.

Details of the sustainability measures that could be supported at the Site are detailed within the Vision Document and Sustainability Charter but in summary they potentially include (inter alia): an aspiration to be net zero carbon through (inter alia) a reduction in embodied carbon through carbon budgets and completion of a whole life carbon assessment for the Site and on-site energy generation within the identified energy park; the co-location of services in community hubs and focus on shared spaces and neighbourhood co-creation; the inclusion of mobility hubs; and facilitating continued co-creation of the environment by the community through the integration of ‘agrihoods’, where the production of food is embedded into the local character of the areas and people can actively participate in ongoing nature recovery, grow their own food, share knowledge and socialise.

• “The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy”
As identified within the Commissioners’ response to the Councils’ vision for the Plan, agriculture is a key economic and environmental resource for Greater Cambridge. It has also strongly shaped the landscape and character of the Cambourne area, where agricultural practices are still very prevalent. Subsequently, the Commissioners have sought to support the practice and existing economic role of the place, whilst also providing the additional homes the community requires, through the inclusion of agrihoods within the masterplan contained in the Vision Document. It is anticipated that such agrihoods could potentially support the regenerative farming practices that already take place on the land to the immediate east of the Commissioners’ land, to the south of the A428.

Furthermore, the masterplan shows how employment use development could be integrated into the Site. The identified employment land is predominantly located within and around existing areas of employment within the Site. It is also noted that a parcel of land located to the immediate north east of the Site’s southern parcel, is included within the Councils’ HEELA (site reference: ‘40076 – Land south west of Caxton Gibbet’), having been submitted in response to the Call for Sites exercise for a variety of uses including employment. This parcel offers an opportunity for a flexible range of uses at a key gateway into the Site and provides a strong interface between the proposals and Cambourne West. Because of its locality, this area also has the potential to support micromobility opportunities, such a mobility hub, to encourage active travel through the Site and to existing neighbouring communities.

• “How the place will develop over time, and the infrastructure needed to support different stages during its development”
As discussed above, the Commissioners’ vision for the Site is centred around the evolution of a place, under the notion; “little steps become great strides”. The Commissioners consider that the Site is both suitable to accommodate the proposed 1,950 homes the Councils are looking to direct towards Cambourne, as well as any future increase up to a capacity of approximately 4,900 homes. The Vison Document includes an indicative parcel within the Site to accommodate an initial 2,000 new homes along with the infrastructure and services necessary to support this. This will be developed as the Commissioners’ plans for the Site evolve.

Whilst focusing on the infrastructure required to support the Site, it is of note that whilst the HEELA scored the Site ‘amber’ in terms of ‘Site Access’ and ‘Transport and Roads’, the Transport Written Representation prepared by Pell Frischmann does not identify concern in terms of being able to access the Site.

• “Making effective connections within the new development and with Cambourne for public transport and active travel, as well as connections to surrounding villages so they can also benefit”
Sustainable travel modes are at the heart of the proposed transport strategy for the Site, with accessibility both to and from the Site being achievable by walking and cycling. The Site is within 2km of the edge of Lower Cambourne and Cambourne Village College and Great Cambourne and Upper Cambourne are within 5km, which is approximately 25 minutes by cycle. Therefore, there is significant opportunity for residents of the Site to travel to these areas by more sustainable modes of transport. The masterplan within the Vision Document identifies such potential routes which include upgrading existing public rights of way and providing new pedestrian and cycle links (including a new segregated pedestrian/cycleway running alongside any new vehicle connection which runs east to west providing a new connection to Ermine Street. This would provide a quality connection to the planned ‘Cambourne to Cambridge (C2C) Better Public Transport Project’ travel hub in Cambourne. This would provide another public transport option for the residents of the Site and would improve accessibility to Cambridge and destinations in-between.

• “The relationship with Cambourne and Bourn Airfield, and how to make the area more sustainable, through the mix of services, employment and transport opportunities offered by the area as a whole”
The connectivity of the Site to the wider area including Cambourne and the villages beyond (which includes Bourn Airfield), has been covered in response to the criteria above.

• “Be structured around and have local and district centres that can meet people’s day to day needs within walking distance, including responding to changing retail and working patterns”
The masterplan contained within the Vision Document illustrates how the Site could be developed to accommodate a range of services and facilities to ensure that all residents are within walking distances of local centres that can meet their day to day needs. The Site is capable of being developed to provide the services and facilities to support the community as it grows, without being reliant on Cambourne, whilst still providing suitable access to Cambourne and the larger range of goods and services that can be found there.

The Vision Document also explores ‘Flexible Ways of Working’, highlighting that it is widely acknowledged that we will not fully revert to previous patterns of working and therefore it is essential that places are designed, from the outset to support flexible and productive ways of working. The vision for the Site is where this support is not only intrinsic but where its benefits (through reduced car use, greater community integration, and increased viability of local facilities and services), translate into better, mixed-use, people focused placemaking.

Subsequently, whilst the Site scored ‘amber’ within the HEELA in terms of its accessibility to services and facilities, it is evident from the above that the Site is capable of being developed to provide a betterment to the existing situation as assessed within the HEELA.

• “How it can help deliver the Western Gateway Green Infrastructure project, and in doing so positively engage with its landscape setting, as well as recreation and biodiversity enhancement opportunities such as woodland planting”
With regards to landscape, the HEELA scores the Site as ‘red’, identifying that development across the parcels assessed would have “a significant adverse impact upon the landscape character, views and visual amenity. It would be an encroachment into the countryside, urbanisation of the rural landscape and amalgamate both the villages of Caxton and Papworth Everard.” However, as identified at page 73 of the Councils’ Development Strategy Topic Paper, it states “our evidence shows that the most sustainable location for further new settlement scale development is through an expansion of Cambourne…It is important to recognise that our evidence says that large scale development at Cambourne would have landscape impacts and that these would be hard to address. However, when considered in the context of the significant economic and carbon benefits of locating development at the proposed new rail station at Cambourne, it is considered that the benefits are likely to outweigh the level of landscape harm”.

Notwithstanding the above, in order to support the masterplan for the Site, a landscape strategy has been prepared by The Richards Partnership. This strategy is contained within the Vision Document. The strategy has had significant regard for the Councils’ landscape evidence base, including the Greater Cambridge Green Infrastructure Opportunity Mapping Study (September 2021) which identifies ‘Strategic Initiative #8 – Western Gateway (multifunctional GI Corridors) and includes a broad swathe of land in the western side of the district.

A key element of the strategy is the inclusion of a major new tree planting initiative that creates a wildlife corridor and buffer along the new A428. Extensive green corridors running through the Site and substantial buffers between the Site and Caxton, Eltisley and Papworth Everard help address the Councils’ previous concerns regarding the amalgamation of nearby villages.

Within the locality of Cambourne, it is considered that other potential locations to accommodate the growth of Cambourne will have greater impact on the area’s landscape character. For example, the broad plateau landscape to the north of Cambourne and east of the A1198 has a much more open and expansive character, with little or no visual interrelationship with Cambourne. The absence of any urban form and influences in this area suggests it would be more difficult to assimilate significant urban form into this landscape. Similarly, the proximity of Caxton and Caxton End to the more modern Cambourne villages suggests it would be difficult to introduce further development here without bringing about physical, visual and perceived coalescence between the recent Twentieth Century developments and the older villages to the south and south east.

• “Take opportunities to reduce floor risk to surrounding areas, that take innovative solutions to the management and reuse of water”
It is noted that within Appendix 4 of the HEELA, that the Site is assessed as ‘amber’ in respect of flood risk. This is because parts of the Site are at risk of surface water flooding. A Flood Risk Assessment prepared by Pell Frischmann on behalf of the Commissioners has been submitted and used to help inform the concept masterplan within the Vision Document. As identified within the Flood Risk Assessment, the majority of this risk is contained to topographical depressions, watercourses and drains on Site. Mitigation measure can be incorporated through appropriate site design and consideration of the flow routes, which can be built into landscaping and external areas. The Commissioners therefore consider that surface water drainage should not be viewed as a constraint to development, but an opportunity to explore innovative solutions to water management.

In summary, the above demonstrates the extensive work that has gone into the formulation of a well evidence and robust Vision Document for the Site. The concept masterplan contained within the Vision Document shows that the Commissioners are having consideration for the key themes that are emerging within the proposed development considerations criteria contained within policy S/CB. The Commissioners strongly recommend that the Councils’ review and re-assess the Site in light of the information that has been prepared to support this representation.