How much development and where?

Although somewhat supportive of satisfying the housing demand locally to prevent a further increase in commuting, such a large increase in house building within the city requires a significant investment in community facilities and infrastructure to be a benefit to current local communities, not a further strain on resources.

Investment in public transport should come before extra housing, rather than retrospective when reliance on private transport has already been established.

The proposed housing needs are greater than the standard Government calculation, which may in itself be questioned. In addition, the long-term effect of the pandemic on working and travel patterns now needs to be incorporated in the projections.

1.0 Introduction

1.1. Savills is instructed to act on behalf of Martin Grant Homes Ltd (MGH). MGH controls a substantial area of land to the north of (and adjoining) Cambourne (referred to as North Cambourne).
1.2. Our representations are structured to respond to relevant sections of the Greater Cambridge Local Plan (GCLP) ‘First Proposals’ consultation. This follows on from our representations to the ‘First Conversation’ in the previous stage of the Local Plan during 2020, and our earlier response to the Call for Sites in 2019.
1.3. This representation is accompanied by a vision document and illustrative masterplan (under separate cover), setting out the key strategies and proposals for North Cambourne, and by other technical reports on transport and landscape. The vision document and illustrative masterplan explain how new employment could be delivered together with new infrastructure, facilities and housing, creating a new sustainable community, that is well connected to Cambourne and to Cambridge as well as providing improved access to services and facilities for existing Cambourne residents.
1.4. Development at North Cambourne is a highly sustainable option for accommodating both new housing and new jobs in the Greater Cambridge area. There is significant opportunity for development here of a scale that can promote self-containment and consolidate the functions of the existing settlement. This will support internalised movements using active travel and sustainable modes, minimising carbon impacts as compared to other development options and thereby addressing the Climate Emergency that the Greater Cambridge local authorities have declared.
1.5. The Government has identified the Oxford-Cambridge Arc as a key corridor for growth in the country. This reflects the fact that the fundamentals of the economy in Cambridge are very strong, with certain key sectors clustered in the area including Life Sciences and Bio-Medical. The Arc therefore represents one of, if not the best, opportunity for delivering growth where the economy can sustain it, where productivity is high, and where there are huge opportunities to improve equality and sustainability .
1.6. The narrative as a whole indicates MGH’s general views, as well as indicating areas of support or objection in relation to the First Proposals emerging policies and general direction of travel for the Local Plan. The headings and sub-headings in the following sections relate to the main sections and policies in the First Proposals consultation.
1.7. MGH has already consulted widely among local communities on its proposals for North Cambourne and will continue to participate in the discussion about where growth should take place in Greater Cambridge in order to appreciate, advance and fully embed all of the benefits that development can deliver here, as well as understand and respond to local concerns.
 
2. Vision and Development Strategy

Vision and aims
2.1. Helping Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water efficiency, and is resilient to current and future climate risks, requires bold action - and promptly. MGH shares the Councils’ commitment to delivering homes, jobs and infrastructure in the most sustainable places that will secure this transition in a timely way.
2.2. We support the emerging Local Plan aims to;
• increase and improve networks of habitats for wildlife and green spaces for people;
• create new distinctive and inclusive places that will help people to lead healthier and happier lives, where there is less reliance on travel by unsustainable modes;
• encourage a flourishing mixed economy, providing a range of jobs whilst protecting the global reputation of Greater Cambridge for innovation;
• plan enough homes to meet the needs of the area, including affordable housing and a wide range of housing to suit the needs of the community;
• plan for transport, water, energy and digital networks; and health, education and cultural facilities; in the right places and built at the right times to serve the growing communities;
• help to tackle the climate emergency through proactive interventions to mitigate carbon emissions through sustainable design measures, eliminating the need to use fossil fuels within buildings and achieving net zero emissions through on-site measures.
2.3. In the current consultation the Greater Cambridge authorities have indicated that location is the single biggest factor in impacting on carbon, albeit recognising that it is not suitable to focus on any one broad location. In order to balance this, we understand that the combined authority is proposing;
1) a blended strategy – taking the most sustainable elements of the Western Cluster / Public Transport corridors (incorporating Cambourne) and including them, to meet a variety of needs; and
2) a focus on development at a range of the best performing locations in terms of minimising trips by car.
2.4. In addition, the Greater Cambridge authorities have indicated that mitigating carbon emissions from new buildings will be a key issue in delivering the authorities’ longer-term net zero carbon objectives. With South Cambridgeshire having declared a climate emergency in 2019, it now aiming to halve emissions by 2030 and reduce them to zero by 2050. In terms of the effect of these goals on emissions from new development, we understand that the combined authority is proposing;
1) a net zero carbon policy for new development; and
2) a focus on calculating whole life carbon emission from new development.
2.5. In the public feedback sessions held so far as part of this First Proposals consultation, a focus on public transport corridors and the densification of the Cambridge urban area were the top options preferred by respondents.
2.6. Importance was also given in the feedback sessions to the opportunity to deliver sufficient jobs as well as homes, and the particular recognition of the benefits that East West Rail (EWR) brings to Cambourne. The preference being to expand here, rather than create further new settlements.
How much development and where? - general comments
2.7. The NPPF, at paragraph 61, sets a requirement to determine minimum housing numbers using the standard method. At paragraph 81 the NPPF also states that significant weight should be placed on the need to support economic growth and productivity, and that policies should address the specific locational requirements of different sectors. The NPPF states that this is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential. This includes making provision for clusters or networks of knowledge and data-driven, creative or high-tech industries, but also recognising all of the supporting roles that employment and services need to provide to support communities. Paragraph 105 of the NPPF also sets out the requirement that the planning system should actively manage patterns of growth in support of sustainable transport objectives. Significant development, it states, should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes, which can help to reduce congestion and emissions, and improve air quality and public health.
2.8. The location of Greater Cambridge within the national economic priority area of the Oxford to Cambridge Arc lends even further weight to the need to support this growth. The Arc already supports two million jobs and brings £110 billion to the UK economy per annum, which is over 7% of England’s economic output (Gross Value Added) . The emerging Spatial Strategy and Vision for the Arc suggests that by 2050 the economic output could increase by between £80 billion and £160 billion per annum, and up to a further one million jobs generated.
2.9. MGH supports the strategic ambitions to deliver substantial growth in the GCLP plan period to 2041, and in the wider Arc Strategy to 2050, and we have set out our position in more detail in the following sections.
2.10. The timeframes associated with plan making also need to be realistic. Paragraph 22 of the NPPF states that “strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
2.11. The updated Planning Practice Guidance (PPG) states that where the new policy applies, “the authority will need to ensure that their vision reflects the long-term nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan.”
2.12. A recent Ministerial Letter to the Chief Executive of the Planning Inspectorate confirms that the changes to the NPPF are intended to ensure that local authority plan preparation can continue “at pace while also ensuring that the government’s objectives are delivered”
2.13. For the strategic sites contained in the Plan, MGH suggests that it sets out and indicative plan for ‘future Growth Areas’ for the period to 2050, which aligns with the timescale for the Oxford to Cambridge Arc Strategy.

I support the proposals which exclude any developments in the area of Little Linton and focus on existing sustainable developments.The settlements of Linton and Little Linton have separate historic identities. New development here would disrupt the open landscape and destroy the separation. Land is an important environmental resource in this area and should be protected.
I supportive retention of land between Little Linton and Linton within the designated countryside.
The direction of future development should be focussed on other more sustainable locations as outlined in this current Local Plan.

I strongly object to the level of growth proposed in the Draft Local Plan on the following grounds: inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base.

Cambridge was born as a University Town and has a beautiful Medieval city centre. It's already grown something like 20% over the last 20 years, and you are proposing to double the growth rate over the next 20. This would completely change the nature of the city, from a small city with a historic heart and a scientific and technological focus to a large city. I would hate living in a large city, and many people alonside me have moved here for its peaceful and countryside nature. Please revise your growth outlook. People who work here don't need to live here. Please focus on building small, independent houses in land that is already destined to house building. Please don't build on the Green belt. If the Biomedical campus has to grow, let's focus on connecting it well to other places through public transport and cycling connections.

see attached

Horningsea Parish Council believes that the local plan as developed in 2018 requires a rework owing to the impact of the global pandemic.

This talks of 'creating space', but admits that water supply cannot just be created quickly. We have so many problems that already need to be addressed (air quality, transport, water, high housing costs, strained services) how can be have the hubris of assuming we can cope with more?

The plan is based on job “needs” in the area, translated into housing “needs”. However, these are based mostly on projections of previous growth rates, with insufficient challenge as to whether similar continued growth is either “needed” by the citizens of Cambridge, or indeed feasible without very significant worsening of the following factors that are already acknowledged to be key problems for Cambridge:
* transport infrastructure
* housing affordability
* water scarcity
* social and economic inequality
* access to shared civic spaces
* access to green spaces
* ecosystem pollution and the generation of waste products
Endless growth is of course not theoretically possible in a physical world of limited resources. There are always factors which increasingly make further growth more unattractive, costly, and dangerous to the entities living in the growth system. What models does the Planning Service have to determine likely limits to growth of the Cambridge economy?

The development at North East Cambridge is not supported. As previously noted by GCSP prior to this First Proposal, no allocation was made at North East Cambridge due to uncertainty of the Waste Water Treatment relocation, which recognises that housing and jobs for the plan period and beyond are not dependent upon S/NEC, which can be provided via other policies. Policy S/NEC is being promoted as sustainable but requires the construction of a replacement for a fully functioning and future proofed Waste Water Treatment Works to an area of Green Belt, which doesn’t appear with the same level of prominence in the Proposed Plan for consideration.
The proposed relocation will be at a great cost to the Public Purse at a time Post Covid 19, when the country can least afford it and there is limited surety around future working patterns and business requirements.
The area of Green Belt currently proposed for relocation of the Waste Water Treatment Works has been tightly defended throughout earlier Plan issues and its importance reinforced in previous Green Belt studies, the most recent in 2021 which confirms that development at the proposed location would result in ‘Very High Harm’. This doesn’t appear to support the substantial weight that should be given to any potential harm to the Green Belt.

The additional 11,640 dwellings required to cover a 10% buffer have already been provided for elsewhere, so the high level of need that should be demonstrated before considering any additional Green Belt land release has not been met.

Hallam Land Management (HLM) have made comments in respect of the amount of development and its location in response to Policy S/JH and Policy S/DS respectively.

There is a need to allocate additional employment land to sustain the continuing growth of the rural southern cluster. SmithsonHill draws attention to the merits of its Hinxton site in this respect.

There is a mismatch between the economic potential of the innovative and fast growing agglomeration of major science and technology based employment sites in the rural southern cluster and the scale of employment land and new homes currently being planned for in the local area to support it.

SmithsonHill is beginning to explore the option to adapt and amend its AgriTech park proposal at Hinxton (site previously subject to planning inquiry and put forward to the local plan call for sites process as an employment-led site) to support a wider mix of employment uses.

The Wellcome Trust is also innovating in the form of employment and housing investment it is making at the Genome Campus at Hinxton to provide more of a homes and jobs balance; an approach could be extended further across the rural southern cluster to support the important economic role of the area whilst helping to manage the length of travel to work journeys and related carbon emissions.

It is noted that the November 2020 sustainability appraisal identifies an assessment option involving supporting a high-tech corridor by integrating homes and jobs (southern cluster). At paragraph 4.11 of the appraisal it is concluded that this option “performs very well”, however the option doesn’t appear to have been developed further for the purposes of the current consultation – either in terms of a search for a new settlement or through the investigation of other spatial development forms that may have the scale and potential to achieve similar sustainability benefits.

On page 39 of the first proposals consultation document it is stated that:

“We also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion. We are supporting both jobs and homes growth in this area, through rolling forward a number of existing housing allocations, and by identifying new allocations, including for jobs at Babraham Research Campus, jobs and tied homes confirming the existing planning permission at Wellcome Genome Campus, and a number of housing sites at well-connected villages in the area.”

It is considered that the scale of new homes and employment land proposed for the rural southern cluster is not commensurate with the economic growth potential of this area, including SmithsonHill’s proposed employment site.

The status of the SmithsonHill site is that it remains available, deliverable and viable. The site would be an opportunity to bring nationally significant benefits to the economy and create a significant amount of jobs in the Greater Cambridge area.

The landowners and CBC Limited support GCSP’s recognition of the need for growth in Cambridge to address the undersupply of housing in the greater Cambridge area and the need for housing to meet the needs of the life sciences sector in Cambridge in order to fulfil the potential for knowledge based employment growth.

We support the First Proposals approach to concentrate growth in sustainable locations, recognising that the Cambridge Biomedical Campus and its immediate environs has or is planned to benefit from some of the best sustainable transport infrastructure in the plan area.

The Cambridge Biomedical Campus sits at the heart of an important eco-system. The Campus has grown rapidly over the last twenty years to establish itself as an internationally important cluster of leading Life Sciences businesses and research institutions. In order for the Campus to continue to contribute to Cambridge and the UK’s success, CBC has developed the 2050 Vision, which recognises the importance of integrating Campus related housing, environmental improvements and social infrastructure within an expanding cluster of science. The Campus is one of the best locations within Greater Cambridge to sustainably address future needs.

We will continue to support the long term development of the Campus in line with the Vision 2050 and we recognise that recent revisions to the NPPF urge a longer term approach for strategic development. However, the landowners and CBC Limited recognise that the First Proposals present an opportunity to plan the next phase of the Campus expansion and they wish to work closely with GCSP to deliver on that opportunity.

How much:
Pigeon agrees with the assertion that over recent years, jobs have been created faster than new homes have been built, with the resulting increase in house prices and economic in commuting. We support a strategy that seeks to address this through planning for sufficient homes that meets the identified need, including affordable need. However, the amount of new housing proposed, although above the Standard Methodology, is not of sufficient scale to reverse commuting patterns, or provide for sufficient affordable housing provision.

Commuting Patterns

As already noted, if the Local Plan is to achieve the Vision of a big reduction in carbon emissions, then sufficient homes should be provided which allow for those currently working in Greater Cambridge to live within the area (in addition to meeting the needs arising from future job creation). Such an approach of better aligning job and housing growth would promote more sustainable commuting patterns and deliver significant environmental, social and economic benefits.

Affordable Housing

There is both an acute general need for affordable homes across Greater Cambridge, and a specific need in rural communities which is unlikely to be met through rural exception sites given high land values. The amount of new housing proposed, particularly when taking into account the level of new jobs forecast, will result in a significant need for additional affordable housing. A greater total number of new homes is therefore necessary to meet the identified affordable need, and contribute to achieving sustainable communities.

We also note the resulting delivery strategy set out in the Council’s Housing Delivery Study for Greater Cambridge October 2021 is expected to result in the Council having only a 5.15 years supply of housing land in the years 2025 to 2030. This could give rise to delivery concerns if there is a change in circumstances, further putting pressure on the delivery of affordable housing. We suggest that increasing the current 10% buffer to 20% would give greater robustness to the overall supply position.

Where:
The general focus on strategic sites and continued growth or densification of existing allocated areas is noted as a strategy for delivering large numbers of sustainable homes in the medium/long term. This strategy risks under-delivery where market and other factors may hold back major investment in strategic sites, whether due to confidence about necessary infrastructure, market absorption rates or other unexpected factors. Furthermore, densification will not necessarily result in increased delivery rates, but rather extended delivery times for these new settlements (i.e. build out rates will remain unchanged). Pigeon suggests a more balanced strategy is adopted with a larger number of new sites included, where these would offer genuine active and/or public transport choices. Such an approach would conform with the Vision and Aims of the plan, whilst offering greater resilience to any changes in circumstances through a more balanced portfolio. Moreover, such an approach could help to facilitate some of the other ambitions of local communities relating to local infrastructure provision (such as the provision of public open space), and also assist Small and Medium sized builders to enter the market thus increasing delivery rates.

Pigeon suggest the strategy is amended, with additional sites identified in sustainable villages which benefit from good active/public transport links.

One such example is Hardwick where no growth is proposed despite the village’s location along the Cambourne-Cambridge public transport corridor. Hardwick is within cycling distance of both Cambridge and Cambourne/Bourne Airfield (where the new East-West railway station is proposed), and walking/cycling distance of the Park and Ride facility proposed at Scotland Farm.

We support the provision of additional housing on existing allocated land at Eddington.

As a member of the North Barton Road Landowners Group (NBRLOG), we support the proposals to develop a sustainable urban extension at South West Cambridge. This would support our shared aims relating to climate change, biodiversity and green space, wellbeing and social inclusion, while providing homes in close proximity to jobs at West Cambridge. The Councils’ Preferred Options for Local Plan policies and proposals should be amended to include NBRLOG’s proposals for South West Cambridge.

Question the need for so many homes, what is this number based on? Changes in lifestyle and lower population growth could see less need for new homes - e.g urban commercial buildings changing to housing, downsizing. Brownfield sites to be prioritised.

Marshall supports the GCSP’s recognition of the need for growth in Cambridge and supports its aims to plan for enough housing to meet the needs of Greater Cambridge and plan for a flourishing and mixed economy that provides for a wide range of jobs. Marshall recognises that the GCSP’s ambition and proposed approach to deliver more homes than are required by the standard method reflects the Government’s objective to boost the supply of housing.

The Greater Cambridge Local Plan provides an opportunity to significantly boost the supply of housing and employment floorspace to support the area’s economic prosperity and growth ambitions. There is further potential to do this and truly maximise Greater Cambridge’s economic potential than currently identified in the ‘First Proposals’ consultation document and Cambridge East represents the largest and most sustainable opportunity to realise this potential. Marshall are keen to work positively and proactively with the GCSP and wider stakeholders to develop policies for Cambridge East that best reflect the GCSP’s Local Plan ambitions and objectives. Marshall also proposes to undertaken public consultation on the scheme during the second quarter of 2022, to identify the important constraints and opportunities in consultation with local communities and other interested parties.

We note the following statement in the consultation document (page 22):
“Greater Cambridge has a strong and nationally important economy. Over recent years, jobs have been created faster than new homes have been built, and this has contributed to higher house prices and increased commuting into the area.”

This summarises our key concerns, namely:
• Cambridge City and the surrounding area are unique, and of national and international significance.
• The Planning vision for Greater Cambridge must embrace the growth potential that the area possesses, and plan for that growth to the greater benefit of the local economy and UK PLC, whilst ensuring that economic growth is harnessed in a sustainable way for the good of all.
• The life science, biomedical and tech-based sectors are particularly fast-paced and market trends and demands over the next two decades will evolve and cannot be entirely foreseen. As a result, adequate flexibility is needed within the Local Plan; this needs to be factored into both the growth projections (jobs and housing numbers) and the spatial strategy.
• As referenced in the above quotation, a past failure to deliver a sufficient supply of new housing alongside economic/jobs growth has resulted in problems including lack of affordability and increased commuting distances, with associated issues such as traffic congestion, environmental concerns and social/community fragmentation. The new Local Plan must not allow these past mistakes to be repeated, as the impact will be negative in terms of economic, social and environmental effects.

We have three broad comments:
• The Plan should embrace the maximum economic benefits that can sustainably be accommodated within the Greater Cambridge area. Life sciences, biomedical and technology sectors are key areas to the UK economy, asserted heightened importance as a result of the Pandemic. These sectors rely on knowledge clusters and Cambridge is alongside Oxford as one of two UK locations able to offer such a cluster that is sufficiently attractive to compete with major global economies such as Silicon Valley in California. Its importance to UK growth is essential and the Plan needs to accommodate the needs of these sectors – and ensure that the supporting infrastructure (including a wide choice of new homes) is available for existing and new employees.
• The Plan is proposing too few homes to support the ambitious and aspirational economic growth of Greater Cambridge.
• The spatial strategy is placing an over-reliance on a limited number of strategic sites within the City and depends upon the intensification of existing strategic sites to deliver additional homes. A broader development strategy is required to ensure a more flexible and responsive approach. There is a danger that if development on the strategic sites stalls or delivery timescales slip, then housing completions will be negatively impacted, potentially leading to unplanned speculative development.

Grosvenor Great Britain (GBI) supports the vision and aims. It also supports the amount of development, but not the distribution and proposed allocations. Refer to main report of representations.

In order for rural villages to continue to thrive and sustain their local services and facilities it is imperative that sites are allocated on the edge of villages otherwise the services and facilities within them will decline and this will not address the local housing need. Given the framework boundaries will continue there are limited infill opportunities
and therefore some housing on the edge of villages would be more appropriate.

In the second paragraph the wording should be revised to state "Alongside this we will plan for the business space, supporting community facilities, green spaces, infrastructure and access to excellent education provision to meet the needs of our growing communities " rather than "Alongside this we will plan for the business space, supporting community facilities, green spaces and infrastructure to meet the needs of our growing communities" to recognise the importance of access to excellent education provision as well.

In the fourth paragraph the wording should be revised to state "This means providing opportunities to regenerate or enhance areas that aren’t yet reaching their potential,..." rather than "This means providing opportunities to regenerate areas that aren’t yet reaching their potential,..." to recognise that areas can/should be improved through regeneration or enhancement.

2.1: How much Development and Where? (P22)

We support suggestion that the Greater Cambridge Plan wants “our rural villages to continue to thrive and sustain their local services…” We object however to subsequent suggestion that the plan actively seeks not to “encourage lots of new houses in places where car travel is the easiest or only way to get around.”

The provision of the appropriate number of new houses within rural Cambridge will be fundamental to ensuring villages thrive and survive. If the vast majority of growth is to be focused in a few strategic locations then it is clear that both the sphere of influence of such areas will grow and present threat to village facilities and the lack of growth will hinder further villages ability to support their communities.

The strategy pre-supposes that sustainability policy should be driven by transport considerations alone. How people work and live are evolving rapidly. Travel is only one issue that must be considered in the overall sustainability of future housing provision.

Recommendation: We strongly encourage that housing provision is facilitated in village locations that allows such settlements to grow comparatively alongside the strategic locations identified for growth.

Our clients support the identified requirement for 44,400 new homes in the period to 2041 as a minimum. This is above the minimum figure recommended by Government using the standard methodology which is appropriate for an economically thriving and ambitious region. Furthermore, it is pleasing to see the application of a pragmatic 10% flexibility allowance to allow for the non-take up of allocations or account for where delivery is stalled. The requirement for additional land for a minimum 11,640 homes to be identified in the Plan period to 2041 is appropriate.

Detailed comments provided under S/DS: Development Strategy.

“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 larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, we’ll continue to support infill development and affordable housing on suitable sites, but we do not propose lots of village growth.”


"Housing Delivery Study – FINAL VERSION Prepared for: Greater Cambridge Shared Planning AECOM

…

11.19 It is still the case that generally the spatial options that mix short-medium term sources of supply (smaller sites in urban areas and villages) with longer-term sources (new settlements, urban extensions and Green Belt release) are better-able to deliver across the plan period as a whole with a smoother trajectory. These sites also have different characteristics and are likely to result in variety in terms of location, size, type and tenure of housing, and also be more geographically spread to reduce competition, thus better-matching the housing supply with demand.”

“11.20 The housing delivery assumptions in this report still show that in order to optimise housing delivery, demonstrate a five-year housing land supply and maintain delivery across the plan period, it will be necessary to gap-fill the ‘troughs’ in the housing trajectory with additional sources of supply. This should be underpinned by cautious but realistic lead-in times and build-out rates, and an ‘over-allocation’ of land against the eventual housing requirement (we recommend at least a 10% buffer) in order to ensure that any unforeseen delays to delivering individual site allocations during the plan period, or changes to market conditions, do not result in under-delivery that would threaten the five year housing land supply or performance against the Housing Delivery Test.”

• The ’additional sources of supply’ which the Housing Delivery Study says will be necessary for gap-filling are not included in the ‘First Proposals’.
• The Councils have included an ‘over-allocation buffer’ of 10% but, as the Study implies, this simply underpins the gap-filling (by building in flexibility and resilience to the supply), but does not constitute gap-filling itself.
• What is needed for effective gap-filling is the short-medium term sources of supply that paragraph 11.19 refers to (smaller sites in urban areas and villages), like Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096).
• As paragraph 11.19 points out, spatial options that combine such sites with longer-term sources are better able to deliver across the plan period as a whole with a smoother trajectory.
• It is also the case that these short-medium term sources will provide greater variety in terms of location, size, type and tenure of housing and will, as stated in paragraph 11.19, “[better-match] the housing supply with demand”. These are essential matters in themselves but are of even greater import when coupled with their ability to gap-fill the housing supply ‘troughs’.
• Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096) and other small-medium sites that are well located in relation to public transport corridors and nodes should therefore be allocated in order to:
1. Provide a reliable, smooth supply of housing land over the whole plan period; and
2. Provide as much choice as possible in terms of the location, size, type and tenure of housing that the plan can offer.

In order for rural villages to continue to thrive and sustain their local services and facilities it is imperative that sites are allocated on the edge of villages otherwise the services and facilities within them will decline and this will not address the local housing need. Given the framework boundaries will continue there is limited infill opportunities and therefore some housing on the edge of villages would be more appropriate.

The same points mentioned within the vision and aims comments are relevant again – the need to have jobs, services and facilities near to where people live is, as the plan progresses, likely to be less important given the increased propensity to work from home (which the draft plan advocates under policy J/RW) coupled with the replacement of diesel and petrol cars. In light of this it appears reasonable to allow further development in the rural areas where families are more likely to want to live and where access to leisure and the countryside is readily available. Locations such as Girton, Over and Bassingbourn which benefit from access to nearby locations including (respectively) Cambridge, St Ives and Royston should be capable of accommodating new development in locations adjacent to the existing settlement boundary.

See additional supporting planning commentary.

The intention 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 is supported. We also consider the principle of this strategy to align with the NPPF and principles of sustainable development.

The First Proposals document states:
“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 larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, we’ll continue to support infill development and affordable housing on suitable sites, but we do not propose lots of village growth”.

Across the rural areas, owing to their location, communities are not usually served by public transport links that are as well connected or indeed frequent as urban areas. However the reduced services should not be seen as a barrier or restriction to growth as rural areas provide a variety of other services and facilities and work as a network to meet local needs.

Land East of Cambridge Road, Melbourn offers a sustainable location for accommodating residential development. The Site’s position on the edge of Melbourn provides local public transport connections and pedestrian and cycle links, as well as proximity to nearby local amenities including jobs, services and facilities within the village centre.