New Settlements:
Between the First Conversation and the First Proposals stages, the October 2021 SA states that a sustainable settlement sizes review was undertaken and concluded that only new settlements of 4500+ homes should be considered ‘sustainable’ within the Options. This is different to the more detailed assumptions within the HELAA which has been applied to individual site option assessments yet this broader high-level is still considered by the authority as being appropriate for SA purposes. This has the effect of excluding the consideration of any HELAA site which is capable of meeting the key objectives and vision if it is below 4500 homes in size, even if it would comprise a strategic expansion at/adjacent to an existing village.

Furthermore, because of this minimum threshold criteria being applied, any New Settlement option has been negatively skewed on the basis that at this scale, sites were unlikely to provide sufficient housing until later in the plan period due to lead in times and delivery of new infrastructure. Hence no new or extended village options have progressed through to First Proposals.

Paragraph 105 of NPPF2021 guides significant development to locations that are or ‘can be’ made sustainable through offering a genuine choice of transport modes. No consideration has been given to strategic scale growth to improve the relative sustainability of any existing village where they meet other key objectives of the plan. This categorisation also goes against previous new settlement allocations. Bourn Airfield is considered to be a sustainable new settlement in the 2019 Local Plan at 3,500 homes. Cambourne has also evolved through previous development plans as four linked villages of circa 1200 units each.

As a result of this change in focus, no scheme under 4500 homes at any location in the rural areas has been assessed as a reasonable alternative – even as significant growth at existing villages along transport corridors. Any development in the rural areas has been dismissed outright based on the negative sustainability impacts of a perceived ‘dispersed’ strategy.

By limiting new settlements options to a minimum 4500+ new homes and other development in the rural areas to small/non-strategic sites without any regard to distribution or scale, the SA does not properly assess a combined urban area/transport corridor strategy. There is no explanation why new or extended villages cannot be considered a reasonable alternative where they meet other spatial objectives. The SA need to test strategic scale sites in/adjacent to rural centres or villages of between 700 units up to 4,500 units as an integral part of the spatial options.

The SA has not taken forward any meaningful appraisal of growth outside the City or the existing new settlements as reasonable alternatives to the preferred spatial strategy. Sites under 4500 homes have not been properly considered.

In summary, we consider the impacts of a New Settlement option or village expansion proposal as part of any spatial strategy has been unfairly discounted in the formation of the First Proposals strategy or testing of reasonable alternatives.

Western corridor:
A key theme of the GCLP is to reduce the over reliance on car use and high levels of car ownership and to minimise and mitigate the transport impacts of development, including the impacts on the environment and the health and wellbeing of local communities.

Paragraph 104 NPPF2021 states that transport issues should be considered from the earliest stages of plan-making/ and that opportunities from existing or proposed transport infrastructure should be optimised.
The delivery of ‘transformational’ infrastructure benefiting existing as well as new communities and the local environment should inform the selection of strategic sites and the policies to shape them. This primarily includes the EWR project and its future station at Cambourne and linked improvements along the C2C corridor. However, we do not consider this extends far enough.

The local opportunity arising from the nationally significant A428 Improvement scheme has not been fully explored within the SA when developing and refining options and assessing effects. The evidence base acknowledges this could include assessing where alternative allocations or mitigation measures would improve the sustainability, viability and deliverability of proposed land allocations (including individual sites) provided these are compliant with national policy as a whole (Infrastructure Topic Paper -ITP). The opportunity to extend the C2C corridor in a westerly direction along the section of the existing A428 from Caxton Gibbet to Croxton (and beyond to East of St Neots) once it has been down-graded to a local road should be explored further.

The ITP concludes that all of the spatial options with the exception of Option 5 Villages have the potential to increase use of active travel modes and reduce reliance on the car, as long as the exact location of the development sites is carefully considered. Unfairly, this rules out consideration of any village expansion opportunities along key corridors, as set out in the SA under the more recent spatial options. The transport evidence that the SA is based upon is overly restrictive.

There are some reasonable alternatives that should have been clearly considered including for example, a potential Croxton Garden Village Option as part of Options 4, 5,6 and 8. In relation to Croxton (HELAA Site 40288), the SA dismisses it on the basis that a new settlement option was not favoured, instead focusing on additional development onto brownfield sites on the edge of Cambridge, and to take advantage of a new EWR station at Cambourne.

If properly assessed against the backdrop that the A428 DCO scheme already has funding and a decision on its planning status is due before the next iteration of the draft plan in Summer 2022, the site should have scored differently. Both in terms of its relative sustainability and landscape impacts. The site was put forward as a location for a garden village of circa 1750 for the GCLP area with the potential to extend to 4000. However, as New Settlement options were ruled out before reasonable alternatives were considered, it was automatically discounted.

Given the aforementioned changes to the A428 and the opportunity this scheme brings to creating cycleways and/or extended bus strategy along the de-trunked route in the near future; the presence of an existing mainline rail station at St Neots and the new station options at Cambourne and St Neots South, this site should form part of any sustainable strategy across Greater Cambridgeshire.

For the site-specific assessments, Croxton was given a red flag overall and considered unsuitable, despite being available and achievable. The only red flag relates to landscape and townscape constraints. This whole assessment has been undertaken with no regard to the changing landscape from the A428. The site assessment should be reviewed and updated to properly reflect the changing circumstances, for consistency. There are examples where policy-on criteria has been used to assess a sites suitability, including at Cambourne and the potential future EWR station.

Vistry Group acknowledge the March 2021 announcement by the GCP indicating a change in focus away from the CAM project which has heavily influenced the First Proposals options. The LTP is yet to be updated and until such a time, we welcome the acknowledgement that the current proposals could be subject to change in the draft plan should the assumptions on the abandonment of the CAM change (Development Strategy Topic Paper Sept 2021).

Overall, the First Proposals do not currently include sufficient flexibility to adapt to rapid change and runs the risk of falling short on delivering the housing requirement. The sites selected do not create a balanced distribution of need and affordability focusing the majority of growth in Cambridge or at the existing three new settlements from the previous local plans. The narrow-focused distribution of development to 2041 does not provide sufficient confidence that delivery rates can be sustained over the short-medium and long-term.

Until all of the reasonable alternatives have been appraised, it is not possible to conclude that the First proposals would represent the most sustainable strategy. As stated in the 2021 evidence base, further work is required to establish which infrastructure projects can be relied upon.