General Comments
Our client is generally supportive of the Plan’s vision and overall aims as set out at Section 2 of the
consultation document, and in particular with the aim to plan for enough housing to meet needs,
including significant quantities of housing that is affordable to rent and buy, and different kinds of homes
to suit diverse communities.
The First Proposals document supports the delivery of 44,400 new homes over the Plan period 2020 to 2041. This reflects an objectively assessed need for 1,771 homes per year to be built in the Greater Cambridge area and evidence showing a need to plan for about 550 additional homes per year to meet need for housing. The Plan explains that this is the number associated with the most likely future level of jobs and assumes that all the additional homes generated by forecast jobs above those supported by the Standard Method will be provided in full within Greater Cambridge.
The Plan’s strategy is to direct development to 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. The strategy proposes 19 additional sites for development, and states that these sites together with those already within the Cambridge City and South Cambridgeshire 2018 Local Plans, will be adequate to meet this housing need.

Addressing Housing Delivery.
As set out above, the Plan’s strategy proposes 19 additional sites for development, and states that these sites, together with those already within the Cambridge City and South Cambridgeshire 2018 Local Plans, will be adequate to meet this housing need. Figure 4 of the consultation document shows the proposed new housing allocations together with locations of additional new homes on existing allocated sites, locations for faster delivery of homes already planned, and currently planned
development to be delivered by adopted allocations, existing permissions and windfall allowance.
The majority of the locations for proposed new housing shown on the Figure 4 illustrative map are large sites of 500 or more homes which will deliver a slower rate in the early years being less likely to make a contribution to housing completions within the first five years in comparison with smaller or medium sized sites. NPPF paragraph 69 states that small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly.
We contend therefore that Policies S/JH and D/DS would not be sound on the basis because they would not be justified or effective. Our view is that for a housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of housing in the right place, including further small and medium sized additional housing sites.

Rural Housing Needs.
The First Proposals consultation document confirms that Greater Cambridge wants its rural villages to continue to thrive and sustain their local services but doesn’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. The strategy is for some development in and around larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, the two authorities will continue to support infill development
and affordable housing on suitable sites, but that village growth is not proposed. The Plan explains that the evidence shows that villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of our villages. Alongside rolling forward a number of existing housing sites, the consultation explains that a limited number of new sites for housing have been identified at more sustainable villages and a design-led approach has been taken to identifying housing capacity at these sites.
The development strategy proposes some development in the rural area south of Cambridge, the Rural Southern Cluster, where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links. In the rest of the rural area, the Plan proposes a very limited amount of development including small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive.
The Plan acknowledges that providing a limited amount of development in the rest of the rural area can help meet the specific needs of specific employment sectors, support delivery of a range of types and sizes of housing across the Greater Cambridge area, and can support the social sustainability of villages and help support community aspirations but that this must be balanced with the implications for climate change of distributing development.
It is clear from Figure 4 (illustrative map showing the locations of proposed new housing development) that no new housing is proposed across the rural southwestern part of South Cambridgeshire except for housing allocations proposed at Melbourn: Moor Lane (up to 20 homes – site ML) and land to the west of Cambridge Road (up to 140 homes – site CR).
A considerable body of evidence demonstrates that there is a lack of affordable housing in rural areas across the UK and this is particularly acute in the Cambridgeshire. In South Cambridgeshire the affordability ratio of the 25% lowest house prices and 25% lowest incomes is 10.8 (September 2020, Housing Market Bulletin) is more than 3 times the level considered to be affordable. Failure to deliver an appropriate supply of new homes within this part of the Greater Cambridge rural area will mean that
affordability will worsen.
We consider that for the housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of rural housing, the right type of rural housing and in the right place to meet local needs for this part of Greater Cambridge, including much-needed affordable homes. The absence of additional housing allocations within the rural southwestern part of South Cambridgeshire other than the two sites at Melbourn, means that Plan is unlikely to meet the specific housing needs of this part of Greater Cambridge.

Additional growth arising from Oxford-Cambridge Arc.
The consultation document acknowledges that Greater Cambridge sits at the heart of several economic corridors including the Oxford-Cambridge Arc and that an Oxford-Cambridge Spatial Framework is in the process of being prepared by Government. Reference is made to the consultation undertaken in September and October 2021 which sought views on a vision for the Arc. The First Proposals Consultation acknowledges that the outcome of the Oxford-Cambridge framework is unknown at this point but that it is hoped that by developing a clear and positive vision for the future of the Greater Cambridge area, the joint authorities will be able to shape the proposals.
Notwithstanding that the level of growth to be delivered in the Arc has yet to be quantified - a July 2021 statement by the Housing Minister clarified that the National Infrastructure Commission 2017 report target of up to one million new homes within the Arc is not Government policy - our view is that the development strategy proposed by Greater Cambridge is unlikely to be sound in terms of providing an effective housing strategy given the limited number of additional housing sites would be likely to be incapable of providing a sufficient level of flexibility to deliver additional growth which will come through the Oxford-Cambridge Arc.

Summary
We act on behalf of our client, Mill Stream Developments, and have been instructed to submit this representation to the Greater Cambridge Local Plan First Proposals Consultation. We look forward to continuing to work with the Shared Planning Service as it prepares a new Local Plan for the Greater Cambridge area and would welcome the opportunity to comment on further iterations of the Plan.
We contend therefore that Policies S/JH and D/DS would not be sound on the basis because they would not be justified or effective. Our view is that for a housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of housing in the right place, including further small and medium sized additional housing sites.
We consider that for the housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of rural housing, the right type of rural housing and in the right place to meet local needs for this part of Greater Cambridge, including much-needed affordable homes. The absence of additional housing allocations within the rural southwestern part of South Cambridgeshire other than the two sites at Melbourn, means that Plan is unlikely to meet the specific housing needs of this part of Greater Cambridge.
Our view is that the development strategy proposed by Greater Cambridge is unlikely to be sound in terms of providing an effective housing strategy given the limited number of additional housing sites would be likely to be incapable of providing a sufficient level of flexibility to deliver additional growth which will come through the Oxford-Cambridge Arc.
Finally, we continue to be of the view that our client’s site represents a sustainable opportunity to deliver residential development with significant benefits and only very limited adverse impacts. Against this background, we would request that our client’s site is included for
consideration at the next plan-making stage.