Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60310

Received: 13/12/2021

Respondent: Gladman Developments

Representation Summary:

The Councils should seek to allocate a range of sites, by size, type and market locations to ensure that the Local Plan delivers identified housing need for the region. Growth should be dispersed across the settlement hierarchy and the region to ensure future sustainability and vitality.
Recognise that some Green Belt land may need to be released to meet needs, but not in excess of meeting the needs. The methodology used to assess Green Belt land needs to be suitably robust and clearly demonstrate that exceptional circumstances exist. There may be no alternative to Green Belt release to meet some of the needs of Cambridge, however its unlikely to justify Green Belt release in the villages and towns.
Many settlements are sustainable and capable of accommodating growth, and residential development performs a key role in maintaining and enhancing their sustainability and vitality. Growth should be directed to those settlements which have not experienced development in the current plan period.
It is vital that the Councils are not overly optimistic in the projected delivery rates of new strategic sites or overly reliant on these sites to deliver need as often subject to significant infrastructure costs and provision.

Full text:

The proposed direction of this policy focuses development in and around the City of Cambridge and through new settlements. Some development is proposed in the Rural Southern Cluster area of South Cambridge, including Green Belt land, and minimal development is proposed in the rest of the rural area.
The Councils should seek to allocate a range of sites, by size, type and market locations to ensure that the Local Plan delivers identified housing need for the region. Growth should be dispersed across the settlement hierarchy and the region to ensure future sustainability and vitality. Growth should also be focused along sustainable transport corridors, such as the Melbourn to Cambridge corridor in the southwest of the area. This corridor is a sustainable location for growth, offering sustainable transport options in to Cambridge whilst allowing housing needs to be met without releasing Green Belt land in the rural southern cluster.
While Gladman recognise that some Green Belt land may need to be released to meet the needs of Cambridge City, the release of Green Belt land in excess to meeting the City’s needs is unnecessary. As outlined at paragraph 140 of the NPPF (2021);
‘Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.’
The Councils must ensure that the methodology used to assess Green Belt land is suitably robust and can clearly demonstrate that exceptional circumstances exist to justify the release of Green Belt land.
Furthermore, the release of Green Belt should not be the primary source of developable land when other suitable and sustainable sites are available outside of the Green Belt. This is clearly outlined at paragraph 141 of the NPPF (2021) which states;
‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.’
It is recognised that there may be no alternative to Green Belt release to meet some of the needs of Cambridge on the edge of Cambridge, however that is unlikely to justify Green Belt release on in the villages and towns. It is imperative that the Councils have considered, assessed, and rejected all other reasonable options to get to that point.
The site submissions at Section 10 and the accompanying appendices demonstrate several available sites that would not require the loss of Green Belt and supports the NPPF’s (2021) assertion later within paragraph 141 that sites in ‘other locations well served by public transport’ should be optimised. Currently, the proposed spatial strategy disproportionately directs growth towards Cambridge City and fails to account for and direct growth towards the sustainable villages on key transport corridors in South Cambridge.
Many settlements, including rural service centres, are sustainable and capable of accommodating growth which ensures their continued vitality. The accompanying Linton StoryMap and Meldreth StoryMap explore this in greater detail. While Gladman support growth in Cambridge, there should be sufficient growth directed towards the rural areas, particularly in South Cambridge in line with the housing needs of the area. The Council must recognise that residential development performs a key role in maintaining and enhancing the sustainability and vitality of settlements. Growth should be directed to those settlements which have not experienced development in the current plan period to ensure the future prosperity of the area and ensure the vitality and continued use of services and facilities within the villages remain over the plan period.
In addition, while strategic sites in close proximity to economic hubs and Cambridge City will form an important aspect of the Plan’s strategy, it is vital that the Councils are not overly optimistic in the projected delivery rates of such sites. Additionally, the Councils should not be overly reliant on strategic developments to deliver identified need as such sites are often subject to significant infrastructure costs and provision. The Councils should also be mindful that new settlements may not be delivered within the plan period up to 2041 and are often subject to lengthy delays. To ensure that this does not impact overall housing delivery, the Councils should seek to allocate small to medium sized sites in sustainable locations that can be delivered by smaller housebuilders and are less likely to incur significant delays.
Fundamentally, the distribution of development should not be a politically driven decision, but one based on robust evidence and consideration of a number of factors such as local housing needs and settlement sustainability. Green Belt land should not be released unless exceptional circumstance can be demonstrated and all other reasonable, suitable alternative sites have been considered.
Overall, the Local Plan will need a balanced strategy, including a variety of different elements to ensure delivery over the course of the plan period and to meet the needs across the plan area. It is important that the Councils do not place an over reliance on just one type of approach, in this case, large scale urban extensions and new settlements, as this could hinder delivery of much needed housing.