OBJECT

Ely Diocesan Board of Finance (EDBF) has promoted a number of sites through the emerging GCLP process.

EDBF’s representations to the GCLP Preferred Options consultation refer to two of those sites, as follows:

• Land at Hinton Way in Stapleford (HELAA Site Ref. 40369) for residential development, and adjacent to the preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford); and
• Land off Butt Lane in Milton (Site Ref. 40365) for employment development on remainder of land adjacent to approved Cambridgeshire Constabulary Police Station.

The sites are currently located in the Green Belt. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster (for the Stapleford site) and the rest of the rural area (for the Milton site), and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Great Shelford, and the decision to not consider the relocation needs of existing businesses within the North East Cambridge area. It is requested that both sites are released from the Green Belt.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predicts high average annual housing delivery rates for Northstowe and Waterbeach.

The redevelopments at North East Cambridge and Cambridge East are complex and involve the relocation of the existing uses and are likely to take much longer to deliver than currently predicted; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East.

Most of the new settlements deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases.

For these reasons, it is requested that additional small and medium allocations including land off Hinton Way in Stapleford should be identified in emerging GCLP, which can be delivered easily and provide policy compliant levels of affordable housing.

The Proposed Submission version of the North East Cambridge AAP is currently being reported through various committees of Cambridge City Council and South Cambridgeshire District Council, in advance of public consultation in early 2022.

It is noted that a number of amendments have been made to the AAP, including a 25% reduction in the amount of new commercial (office) floorspace to be provided across the North East Cambridge area and an associated reduction in the number of jobs to be provided from 20,000 to 15,000 jobs. It is intended that there would be no net loss in the quantum of existing industrial (Class B2 and B8) floorspace as a result of the regeneration of the North East Cambridge area. Although it is acknowledged in the AAP that some existing businesses within North East Cambridge would need to relocate as part of the redevelopment.

The Councils intend to support those existing businesses that will be displaced from North East Cambridge, including help to find alternative sites. However, finding alternative sites is likely to be difficult, partly because of the number of businesses that are likely to be displaced either permanently or for a temporary period, and partly because some business will want to remain close to the edge of Cambridge to be close to customers and employees. It is suggested that the remaining land off Butt Lane in Milton, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, could be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area, as well as for general employment purposes.

The promoted land by EDBF is currently located within the Green Belt, and in these representations it is requested that the Stapleford site is released to accommodate housing and affordable housing, and that the Milton site is released to accommodate employment uses including those business displaced from the North East Cambridge area.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt at Stapleford and Milton, which are related to the significant identified need for housing and affordable housing in Greater Cambridge and the need to support economic growth (for Stapleford), and the specific need to provide land for existing businesses that will displaced by the redevelopment at North East Cambridge (for Milton).

Paragraph 141 of the NPPF requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identify previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

Paragraph 142 of the NPPF requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in the emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The EDBF land off Hinton Way in Stapleford is well served by public transport (bus and rail) and is well connected with existing cycle routes, and there are future public transport improvements proposed in the surrounding area. The EDBF land off Butt Lane in Milton is adjacent to Milton Park & Ride and is well connected to existing cycle routes, and there are proposed public transport and walking/cycling improvements proposed in the area including connections to Waterbeach, Milton and North East Cambridge. Therefore, the release of the land off Hinton Way and off Butt Lane from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

There are a further three paragraphs within the NPPF that suggest additional allocations should be made in Stapleford and the Rural Southern Cluster:
• Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas.
• Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.
• Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Great Shelford and Stapleford contain a good range of services and facilities, reflecting their status as a Rural Centre in the settlement hierarchy. For example, they contain a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants.

The promoted development by EDBF at land off Hinton Way in Stapleford would support the existing services and facilities. Shelford Station is located close to the site. There are bus routes on Hinton Way, Mingle Lane, Station Road and Cambridge Road, all of which are close to the site. There are cycle routes through Stapleford and Great Shelford into Cambridge. The route for the proposed Cambridge South East Transport project by the Greater Cambridge Partnership is located to the north west of the site, and there are proposed stops at Hinton Way and Haverhill Road that would be within close proximity of the site. Therefore, the promoted development by EDBF at land off Hinton Way in Stapleford is accessible by a range of sustainable modes of transport, and it would be consistent with national policy to direct additional development to this site.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a current need for 28 affordable dwellings in Stapleford for those with a local connection to the village, and an identified need in Great Shelford for 47 affordable dwellings – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. It should be noted that additional affordable housing needs will arise in Stapleford and Great Shelford in the future and during the plan period to 2041. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Great Shelford and Stapleford should only seek to meet locally derived affordable housing needs but also those district-wide needs of Greater Cambridge. The preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford) for 100 dwellings would meet the current identified needs for affordable housing of Stapleford, but not district-wide or future needs. The Stapleford and Great Shelford Neighbourhood Plan is at an early stage and a draft plan has not yet been published, so it is not clear whether this document will seek to address future and district-wide affordable housing needs through additional allocations; although it is noted that the emerging GCLP does not anticipate any future amendments to the Green Belt boundary to accommodate those affordable housing needs.

It is for these reasons that EDBF is requesting an additional allocation at land off Hinton Way in Stapleford.

It is requested that additional housing allocations should be made in the more sustainable villages in the Rural Southern Cluster and on the edge of Cambridge including at Stapleford, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is a need for affordable housing in the villages which would only be partially met.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements and the new communities on the edge of Cambridge are reviewed so that they are more realistic.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that additional housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including at land off Hinton Way in Stapleford, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is a current need for affordable housing both in the village and district-wide and there will be a need in the future too.

It is requested that the emerging GCLP should identify additional employment land allocations to meet the needs of businesses that will be displaced as a result of the redevelopment at North east Cambridge. The remaining land off Butt Lane in Milton, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, could be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area, as well as for general employment needs.