5.0 POLICY S/DS: DEVELOPMENT STRATEGY

5.1 In line with the above, policy S/DS seeks the plan to provide 44,400 dwellings with a 10% buffer added for flexibility, totalling a need for 48,840 dwellings within the plan period. Page 32 of the First Proposals document shows that 37,200 are commitments, windfall etc, leaving a further 11,640 to be planned for. Curiously, when totalled together, the proposed allocations only total 11,596 leaving a shortfall of 44 dwellings.

5.2 In order to make up this shortfall, the Coton site could come forward. Whilst it has a capacity for 77 dwellings, the additional 33 dwellings would assist the Council should any other site provide delayed delivery. However, concern is raised below about delivery potential within the Strategy, which would significantly increase shortfall within the Plan period. These representations show why the Coton site is considered appropriate, although this can be summarised as: • The Green Belt assessment for a wider plot shows a ‘moderate’ harm, whereby an assessment by EDP shows the Site itself provides a ‘Low’ contribution to Green Belt objectives; • Coton is within 2 miles of West Cambridge and the village has seen limited growth in recent years, not allowing the village to evolve; • The Comberton Greenway is improving access to West Cambridge for cyclists and pedestrians, with Grange Road, Cambridge a 17 minute cycle ride form the village; • Coton is situated on the proposed Cambourne to Cambridge Busway (as shown on Figure 11 of the First Proposals document) and a station at Coton will provide further transport alternatives to the car; • Delivery of 40% affordable housing; • Development would benefit services and facilities within the village including the public house, post office and garden centre.

5.3 When assessing the Development Strategy, it is important to look at past delivery rates. Unfortunately, there are no formal figures available beyond 2019/20. However, this does provide useful context when looking at ‘current’ delivery rates. The table below summarises housing delivery in the past four years. The ‘total’ figure shows a fluctuating delivery rate that falls well below emerging Local Plan target of 2,114 dwellings per annum. It highlights that a robust strategy is necessary to increase delivery rates beyond this level. Area 2016/17 2017/18 2018/19 2019/20 Cambridge 1,183 1,112 868 460 South Cambridgeshire 551 737 1,152 1,107 Total 1,734 1,849 2,020 1,567

5.4 It is well known that larger sites have significant constraints to delivery compared to smaller sites. They have larger lead-in times, and therefore any delay will significantly impact delivery figures. A good example of this is Bourn Airfield. It is an allocated site in the current plan, yet it still does not benefit from a formal outline planning permission. The application (ref S/3440/18/OL) has now been with the Council for over 3 years without formal determination.

5.5 Given the need to then submit reserved matters applications, prepare necessary infrastructure and clarify the route of the Cambourne to Cambridge Busway, the ability for the site to commence delivery in 2023/24 seems very optimistic. Given the delays to the development already, the proposed delivery rates at Bourn Airfield does not appear reliable or robust.

5.6 The Development Strategy appears to have two key directions, those being development on the edge of Cambridge and increased delivery rates at the new settlements.

5.7 A key site at Cambridge is the North East Cambridge site. The proposed policy shows that the site will provide 3,900 dwellings between 2020 and 2041. The area has not been subject to a planning application as yet given the reliance upon the production of an Area Action Plan.

5.8 The Area Action Plan has been subject to a recent public consultation, and a report to the Joint Local Planning Advisory Group on 30 November 2021 sets out proposed changes to the Area Action Plan as a result of an assessment of the public responses. Of note, the proposed changes include a reduction in densities of development, a reduction in building heights and an increase in proposed open space provision by 17 hectares. However, despite these significant changes, the total housing numbers within the Local Plan remains the same. However, the nature of the changes to the Area Action Plan must impact upon delivery by its very nature. Proposed delivery rates at North East Cambridge must therefore be revised in line with the recommendations to the Joint Local Planning Advisory Group.

5.9 In addition to this, North East Cambridge is reliant upon the relocation of the existing sewage treatment works on the site. This is highly contentious locally and will no doubt be subject to legal challenge ahead of any relocation. The process has the potential to delay development and delivery at North East Cambridge. The ability of the area to provide 3,900 dwellings by 2041 therefore appears overly-ambitious, with any delay to the treatment works seriously impacting upon the Council’s delivery ambitions.

5.10 With regards the increase in delivery rates at new settlements, the emerging policy specifies this will relate to the new settlements of Northstowe and Waterbeach. This raises an immediate concern regarding how this is to be achieved. The ‘Housing Delivery Study for Greater Cambridge’ October 2021 document provides a justification for Northstowe given the quicker delivery methods of Urban Splash within phase 2A. As per Waterbeach, the development is expected to deliver an additional 50 dwellings per annum from 2026/27 onwards, resulting in 750 additional dwellings by the end of the proposed plan period.

5.11 However, unlike Northstowe, there is no justification as to how Waterbeach will achieve this increase in housing delivery. It is assumed the figures factor in another ‘peak outlet’ to deliver the additional 50 dwellings per annum. However, if the scheme was capable of having 7 developers on site at the same time, why was that part of the original build out rates from the current iteration of the Local Plan? The proposals seem overly generous and lack any clear justification that the increased delivery rates are achievable.

5.12 Historically, South Cambridgeshire District Council has relied upon new settlements and urban extensions to deliver the majority of its housing need. Martin Grant Homes has previously argued that this is to the detriment of villages, which as a result become dormant and suffer from a lack of inward investment.

5.13 The above information confirms there is significant doubt regarding the spatial strategy and the associated housing trajectory. There are serious concerns regarding delivery rates at Bourn Airfield, Waterbeach and North East Cambridge, which will impact upon Greater Cambridge’s ability to provide a five year housing land supply.

5.14 The solution therefore would be to add further small and medium sized sites within the trajectory. This would cover off any delays in delivery. Smaller sites benefit from limited infrastructure improvements, and take significantly less time in the planning system. These advantages are set out in paragraph 69 of the National Planning Policy Framework 2021.

5.15 The emerging Local Plan is reliant upon some Green Belt release to meet the housing delivery targets. This includes release of land around the edge of Cambridge, as well as two sites within Green Belt villages.

5.16 Martin Grant Homes support the release of Green Belt land in order to meet some of this housing need. By their location, Green Belt villages such as Coton are situated in close proximity to Cambridge and as such can play an important role in supporting the City. These representations justify why Green Belt release in Coton would promote sustainable development opportunities. The Local Plan however does not fully capitalise on appropriate Green Belt release, instead shifting development to more unsustainable locations (such as Melbourn and Duxford) where there will be more reliance upon the car.

5.17 Martin Grant Homes reserve the right to further assess delivery rates through the further phases of Local Plan preparation.