OBJECT

North BRLOG is promoting land at South West Cambridge for a landscape-led urban extension to Cambridge, and in representations it is requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy overall and the strategy for the edge of Cambridge, including the over reliance on the existing new settlements and new neighbourhoods to meet the housing requirements, and the decision to not release additional land from the Green Belt on the edge of Cambridge despite these being identified as sustainable locations.

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; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. 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 predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum. The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates for Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; 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. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will 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 affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. 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. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG and submitted with Issues & Options representations) highlighted the difficulty that the existing new settlements have in providing sufficient affordable housing, and also that there is sufficient residual value in strategic greenfield sites on the edge of Cambridge to support planning obligations and policy requirements including affordable housing in full. It is clear that the existing and planned new settlements and new communities on the edge of Cambridge are not and will not provide enough affordable housing, which should be a major concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from other strategic sites, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including the promoted development by North BRLOG at South West Cambridge.

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 around Cambridge, which are related to the significant need for housing and affordable housing in Greater Cambridge, and the need for additional housing to support the economic growth of Greater Cambridge. The cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high too. The Housing Needs of Specific
Groups Report (GL Hearn October 2021) provides further information on affordability and affordable housing needs. Table 42 of the GL Hearn Report identifies an affordable housing need of 199 dwellings per annum for Cambridge and 105 dwellings per annum for South Cambridgeshire, which equates to a combined total of 304 affordable dwellings per annum or a total of 6,384 dwellings during the plan period from 2020 to 2041. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely a large proportion of those journeys are undertaken by car this would add to traffic congestion and air pollution. The promoted development by North BRLOG at South West Cambridge would include affordable housing, and is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge and to other employment opportunities available in the City. The promoted development at South West Cambridge would be consistent with the exceptional circumstances to justify the release of land from the Green Belt, and would enable more employees and residents to live closer to where they work.

Paragraph 141 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 identified 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 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 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 promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities available in the City Centre. It is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge, and to other employment opportunities available in the City. Therefore, the release of the land at South West Cambridge 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.

As set out in the North BRLOG representations to Section 2.3: Edge of Cambridge and to the HELAA Site Assessments for Site Ref. 52643 (Land north of Barton Road and at Grange Farm,
Cambridge), the Vision Document for South West Cambridge seeks to address landscape, heritage and Green Belt impacts by retaining substantial parts of the promoted development for green infrastructure that would remain within the Green Belt.

There are three other paragraphs in the NPPF that suggest additional allocations should be made on the edge of Cambridge at the South West Cambridge site. 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. 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.

As set out above, the South West Cambridge site is accessible by walking, cycling and public transport, and will be well-related to planned bus and walking/cycling improvement projects being brought forward by the Greater Cambridge Partnership. The site is accessible to employment, education, retail and leisure opportunities. The promoted development would include a primary school and neighbourhood centre to meet the needs of residents and the surrounding area. There is a substantial and current identified need for affordable housing and a high housing affordability ratio in Cambridge and South Cambridgeshire, making it difficult for those that work in Greater Cambridge to access housing to buy and rent. The promoted development at South West Cambridge would provide market and affordable/social housing.

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 take into account the evidence from similar development elsewhere.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including sites in the edge of Cambridge, in order to address the under-delivery of affordable housing from elsewhere.

It is requested that the promoted development at South West Cambridge is released from the Green Belt and allocated in emerging GCLP for a landscape-led urban extension.