At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land off Shelford Road, Fulbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and dedicated cycle routes into the City Centre and Cambridge Biomedical Campus, including Addenbrooke’s Hospital, the Councils have not proposed any new site allocations around Fulbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.