It is supported that sites should be developed that can be well-integrated with existing communities to reinforce the distinctive character of the city, towns and villages. It is supported that in the urban areas, sites should be developed at densities making effective use of land (NPPF Paragraph 11(a). However, a focus on higher development density should not restrict development in sustainable locations in smaller settlements, where high density development may not be appropriate. We do not agree with the statement on page 30 of the First Proposals document “Using less land for development reduces our carbon emissions, and allows more space for nature and wildlife”. High quality development can also achieve carbon neutrality and provide enhancements for nature and wildlife, along with a wealth of other benefits.

Over-reliance on Existing Allocations
The proposed development strategy in the First Proposal document relies predominantly on existing allocations carried forward from the Adopted 2018 Local Plans and outstanding planning permissions, alongside a limited number of new sites.
The First Proposals document identifies 13 ‘new’ sites, totalling 11,640 homes. Of these, ‘new’ sites, three sites (Eddington - North West Cambridge, Waterbeach New Town and Northstowe), are all existing allocations. An additional 1,000 homes are proposed to be provided at Eddington and Waterbeach New Town and Northstowe are assumed to achieve faster delivery rates of an additional 750 homes each over the plan period. A site for 2,850 homes at Cambridge Airport comprising safeguarded land from the previous plan, which was also identified as a growth area as part of the Cambridge Local Plan (2003). As set out in greater detail below, noting the significant amount of time that this allocation has been identified within previous Local Plans, we raise significant concerns over the delivery of this site within the timescales anticipated, particularly noting larger sites by their very nature can take longer to be delivered. To encourage a more reliable delivery rate across the plan area we propose that additional sites are allocated to ensure the consistent delivery of dwellings to significantly boost the supply of homes as required by Paragraph 60 of the NPPF (2021).
It should be noted, therefore, only 9 of these 13 sites are strictly ‘new’. In total the 9 sites will provide 6,246 dwellings (equating to approximately 12.8% of the total 48,840 homes to provide for).
It is clear that the First Proposals document makes provision for a very limited number of new sites. There is a heavy reliance on existing and previously identified sites rolled forward from the adopted Local Plans and many of these sites are on a large scale which also means they typically take longer to be brought forward.
Whilst we recognise that the inclusion of the 10% buffer seeks to provide the flexibility to deal with unforeseen circumstances should any sites not be brought forward as planned, the heavy reliance on existing allocations and commitments is overly optimistic and along with the very limited number of new proposed site allocations, the 10% buffer is not considered sufficient. The buffer should be increased to a minimum of 20% and further sites allocated to ensure a robust strategy to account for both the current heavy reliance on existing allocations and planning permissions, as well as to accommodate any additional jobs growth as stated above. Such an approach has been adopted in other local authority areas, including most recently across Babergh and Mid Suffolk Local Authorities.
We have concerns with the deliverability of Cambridge Airport. The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan and safeguarded in the 2018 Local Plans for development should the site become available. As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030. The Topic Paper states at Page 116:
“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”.
There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, when it is only expected to become available from 2030 at the earliest.
Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF.
It is also unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.
Relative to this and the delivery of North-East Cambridge is the requirement for relocating the existing Waste Water Treatment works at North-East Cambridge, the relocation and delivery of which could implicate the larger allocations’ housing rates/timing. Whilst it is understood that a site for the replacement facility has been identified and recent public consultation undertaken (with an intention for a DCO application to be made in 2022/23), it is acknowledged that the larger allocations will be dependent on the delivery and relocation of this new facility.

Over-reliance on Windfall Sites
In addition, there are concerns regarding the heavy reliance on windfall within the development strategy, which comprises 5,300 dwellings and equates to almost 11% of the total number of homes to be provided. The NPPF definition of ‘Windfall sites’ is “Sites not specifically identified for development” whilst the First Proposal document defines ‘Windfall development’ as “Sites which have not been specifically identified as available for development in the Local Plan. They normally comprise previously developed sites that have unexpectedly become available”.
The Housing Delivery Study for Greater Cambridge (AECOM, October 2021) reports that Greater Cambridge has historically achieved a high rate of windfall development and we have not sought to interrogate this evidence at this stage to confirm whether this conforms with NPPF Paragraph 71. Nonetheless, this windfall reliance is considered high, particularly in light of the Councils’ apparent anticipation that these will mostly comprise previously developed sites. It is also noted that the settlement boundaries have been tightly drawn to the existing urban edges, which is unlikely to provide sufficient flexibility for (greenfield) windfall sites to come forward.
A more appropriate strategy is for the windfall requirement to be reduced and a greater range of sites explicitly allocated, including for the lower order settlements where the current development strategy is for very limited development.
Through the positive allocation of sustainable sites at the lower order settlements, including Minor Rural Centres, this will ensure that the Greater Cambridge growth strategy is genuinely plan-led, as required by Paragraph 15 of the NPPF (2021) and ensure that such growth is supported by the appropriate infrastructure. In addition, by re-allocating a proportion of the anticipated windfall growth to specific sustainable sites, this will provide a greater level of certainty of the anticipated location of growth to the Councils, developers and the local community compared with the current proposed strategy that will inevitably see a range of speculative development within the rural areas.
Land to the East Side of Cambridge Road, Melbourn offers a logical and sustainable location for residential growth. The Site’s position on the edge of Melbourn provides a sustainable location for new development with local public transport connections and pedestrian and cycle links, as well as proximity to nearby local amenities including jobs, services and facilities within the village centre. The Site also lies in close proximity to Melbourn Science Park, which has recently achieved approval for a further extension, providing employment for a number of companies engaged in pharmaceuticals, biochemistry and mechanical engineering.

Lack of Development within the Villages
At page 75 of The Development Strategy Topic Paper (2021), it is stated:
“Our evidence, Sustainability Appraisal and consultation responses show that a strategy focussed on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure. As such we consider that villages should not be the primary focus for growth within the development strategy.”
Whilst it is not disputed that villages should not be the primary focus for growth, the current strategy is too restrictive and cannot be supported. Appropriate village development can be sustainable in terms of transport and carbon emissions and provide the necessary infrastructure requirements, as would be the case for land to the east side of Cambridge Road, Melbourn.
In fact, the current development strategy with the high reliance on windfall sites is much more likely to lead to unsustainable village development than a strategy where the Council has control over ensuring village development is located where there is good access to a high quality public transport network and provides the required infrastructure.
Overall we have concerns regarding the robustness of the development strategy and its ability to bring sufficient land forward for development at a sufficient rate to address the OAN over the plan period as required by NPPF (2021) Paragraph 23.
It is considered that there should be a greater focus on a wide range of sites being brought forward for development, by including a greater number of site allocations in sustainable rural areas with good access to public transport and facilities, such as land to the east side of Cambridge Road, Melbourn.
Smaller sites can often be brought forward quicker and provide greater certainty of delivery, particularly in the early part of the plan period. As acknowledged by Paragraph 79 of the NPPF (2021), housing in rural areas can maintain the vitality of rural communities and provide opportunities for villages to grow and thrive, especially where this will support local services.
As discussed later in this Section, it is clear that Melbourn is a sustainable location and able to support additional housing growth, which is evidenced through the two allocations proposed for the settlement. Melbourn should, however, be allocated a greater proportion of growth that is comparable to its identification as the largest village in the south west of the district (Development Strategic Topic Paper 2021; 262).