The Council’s over-reliance on a few major sites (and critically the complex nature of some), we believe, is flawed and likely to result in delivery challenges.
As such, we think it would be prudent for the Councils to allocate more sites in a variety of locations for a wider range of housing. Additional allocations in the villages will help in this regard, as would less complex/constrained sites closer to Cambridge.
Policy S/DS states that the proposed development strategy for Greater Cambridge is to direct development to where it will have the least climate impact and where active and public transport is the natural choice.
In general, we support the principle of focusing development on sites where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way. In relation to minimising car travel, this needs to be considered holistically along with a number of other competing objectives, and provision for car travel is not the only criteria to consider when selecting the most appropriate sites to allocate. It is also very important that due regard is given to the national policy and the three objectives of sustainable development set out in the NPPF 2021 (economic, social and environmental). This means allocating land for development to ensure choice and competition for market land, along with ensuring growth to ensure vitality of villages. Growth within villages can also assist with meeting localised housing need (particularly for affordable housing), which will not be met by a small number of strategic allocations around the largest settlements. In accordance with national policy it is also important that where possible growth is directed to sites that are situated outside of the Cambridge Green Belt.
In this regard, it is also important that a suitable level for growth is directed to the villages within South Cambridgeshire. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. This, however, has not been reflected within the First Proposals within the Local Plan, with minimal allocations within the villages of South Cambridgeshire.
It is suggested that the provision for increasing the range of sites to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and secure affordable housing more immediately and more reliably. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report.
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).
Accounting for the clear recommendations from the Planning Inspector on the 2018 Local Plan, it is not clear why this strategy has not been followed as part of the First Proposals.
Orwell, benefits from being a sustainable settlement in its own right. Orwell is a Group Village (as defined within the adopted Local Plan) that is not situated within the Green Belt. It benefits from primary education facilities, and a range of services, including shops, a pub, and community facilities.
Orwell has a very tightly drawn Development Framework which has remained unaltered since 2003. This does not allow for any windfall development. Orwell did not receive any allocations within the 2018 Local Plan and therefore provision for additional growth as part of the Local Plan 2041 would be appropriate and assist with maintaining viability and vibrancy of the village and meeting identified affordable housing need within Orwell.
For the above reasons, it is considered that the distribution of growth needs to be revisited and that the First Proposals are unsound in their current form. Whilst, clearly allocations that seek to minimise car travel has significant benefits, this should not be the only factor that dictates the most appropriate locations for new housing and employment development. In this regard, policy S/DS is not in accordance with national policy and it is not considered to be justified or effective in its current form.