S/JH: New jobs and homes

POLICY S/JH: NEW JOBS AND HOMES
4.1 The emerging plan shows a requirement to provide 44,400 dwellings over the plan period of 2020-2041, which represents development at 2,114 dwellings per annum.

4.2 It is noted that the proposed housing number exceeds what would usually be required as a minimum figure through the standard methodology calculation. Using the December 2020 formula, this would result in 1,743 dwellings per annum. This stance taken by the Greater Cambridge Planning Service will assist in addressing concerns regarding affordability and will also cater for increased demand for dwellings for skilled workers given employment growth in the area.

4.3 However, it is not considered that the housing numbers go far enough to cater for growth in the area. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) Report September 2018 confirms that growth in the employment sector has not been matched by proportionate house building. The result has been large increases in house prices.

4.4 Whilst it is acknowledged the CPIER report was published pre-Covid, the concepts and ideas remain pertinent as the economy recovers. Greater Cambridge is located within the key economic corridors of the Oxford – Cambridge arc, the London – Stansted - Cambridge corridor and the Cambridge – Norwich tech corridor. The Oxford – Cambridge arc seeks to create a strategic vision corridor between the University cities. It seeks to provide the infrastructure projects of East-West Rail and the Cambridge to Milton Keynes Expressway. At the eastern end of the arc, the driver is the City of Cambridge and its need for residential development to complement its skilled workforce.

4.5 The CPIER report provides a number of Key Recommendations to assist with growth in the area. Key Recommendation #5 of the CPIER Final Report September 2018 states: “There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast by the EEFM. This review should take into account the continuing dialogue between ONS and the Centre for Business Research on employment numbers as well as the impact of the Cambridge-Milton KeynesOxford Arc. This should be used to set new targets which Policy S/JH: New Jobs and Homes are likely to be higher than those already set – at the very least adding on accumulated backlog.”

4.6 The CPIER concludes that a target of 66,700 dwellings should be planned for in order to make the best of the opportunities available. It is therefore considered that the emerging Local Plan should increase its housing targets accordingly. Not only will this assist in combating affordability, it will also provide much needed affordable housing.

4.7 Martin Grant Homes reserves the right to further assess provision of housing need through the next stages of the Local Plan production.

Overall, we do not believe that the Councils are planning for enough growth. We also have concerns at the lack of new planned commercial space, as highlighted in the appended evidence report by Savills.
Policy S/JH is the first strategic policy within the Local Plan and sets out the total number of jobs and homes proposed over the plan period.
We agree with the supporting text for this policy, that it is very important that housing delivery keeps up for demand for increased jobs within the area.
As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan. As set out in paragraphs 5.2-5.4 below, over reliance on large scale, strategic, and importantly complex sites, is contrary to policy in the NPPF 2021, and an approach which spreads growth more evenly, with less associated risk, is urged.
The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.
Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. The Local plan sets out a projection for 1.1% growth, whereas CPIER recommends 2.4% growth and ONS recommends 4.2% growth. Accordingly, it is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.
The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox- Cam Arc as a centre for housing and employment growth.
Further information on this, is set out within a further report that has been completed by Barton Willmore on behalf of Endurance Estates, in relation to a number of sites that are being promoted by Endurance as part of the emerging Local Plan.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up with demand for increased jobs within the Greater Cambridge area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. However, a significant proportion of this growth is made up of existing allocations within the current Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 The Development Strategy Topic Paper, that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth; it generally exceeds it. This is in particular due to a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted. Therefore, a more ambitious growth strategy should be prepared.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox-Cam Arc as a centre for housing and employment growth.

2.7 Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.

2.8 The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?
We agree that it is very important that housing delivery keeps up for demand for increased jobs within the area.
As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.
The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.
Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East-West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.
The provision for lower growth scenarios does also not appear to be consistent with the Government’s objectives for the Ox-Cam Arc as a focus for housing and employment growth with associated infrastructure.
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?
We agree that it is very important that housing delivery keeps up with demand for increased jobs within the Greater Cambridge area.
As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. However, a significant proportion of this growth is made up of existing allocations within the current Local Plans.
The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth; it generally exceeds it. This is in particular due to a world renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted. Therefore, a more ambitious growth strategy should be prepared.
Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.
The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox-Cam Arc as a centre for housing and employment growth.
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

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.

New jobs and homes:
Our view is that the number of planned new homes should be significantly lower. The 31,500 homes already provided for in the adopted Local Plans are more than sufficient for a 5-year housing supply according to objectively assessed needs (see notes below). Given the exceptional circumstances we are living through, it makes sense to keep housing demand under review rather than committing to build according to high forecast growth.

We note the statement made by the Planning Authority during the webinars that “If we don’t have enough certainty about water supply, we will have to look at a stepped trajectory or reducing the amount of housing we plan for”. Officers also noted that “Quick and decisive action [is] required by central government and the water industry – this is out of our hands as a Local Planning Authority”. We agree and would support the Planning Authority in any attempt to reduce or at least delay house building from the central government allocation. Based on conversations we have had with Cambridge Water, we believe that while there might be ideas on supplying more water in the future we can see no achievable commitment. We note Natural England’s Position Statement for Applications [1] within the Sussex North Water Supply issued in September, which states that, "Developments within Sussex North must therefore must not add to this impact and one way of achieving this is to demonstrate water neutrality … As it cannot be concluded that the existing abstraction within Sussex North Water Supply Zone is not having an impact on the Arun Valley site, we advise that developments within this zone must not add to this impact.”

Notes: For an objective assessment we quote household projections by the Office for National Statistics. We note that the more recent the assessment the lower the number projected (Table 1). In the most recent projections (2018 based) the projected increase between 2020 to 2041 is 7,900. Since this projection was calculated there have been two hugely significant events: Brexit and COVID-19. The National Planning Policy Framework allows that “any other method [other than use of 2014 based projections] will be used only in exceptional circumstances”. We hold the view that leaving the EU, COVID, together with climate change are exceptional circumstances and would welcome a plan based on these.

It is worth noting that the 2014-based household projection for 2020 for Greater Cambridge was 119,400 households. In the 2018 based projections the estimate for 2020 is 108,500, so in four years the 2014-based projections have over-projected by around 10,000 households.
Table 1: Projected household change, Cambridge and South Cambridgeshire, 2020-2041
Projection Number of households 2020-2041
CLG 2014 based c. 23,600
ONS 2016 based 12,200
ONS 2018 based 7,900
Source: CLG and ONS household projections. 2014 based ends at 2039, so the 2041 figure is from a simple assumption of continuing change.

The number of houses built over the last five years (2015/16 to 2019/20) averages 1,750 a year. While need is not as simple as applying that to the future, 31,500 homes would last for more than 15 years at that rate.

[1] https://www.horsham.gov.uk/__data/assets/pdf_file/0019/106552/Natural-Englands-Position-Statement-for-Applications-within-the-Sussex-North-Water-Supply-Zone-September-2021.pdf

0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).

0.2 This response concerns a site of 1.86 hectares, identified as Land South of Cambridge Road, Milton, whose red-line boundary is provided in Appendix A (“the Site”). The Site lies to the north of the A14 and adjoins the village of Milton. The Site has recently been used by Balfour Beatty as an offices and storage compound for the A14 Improvement Works since 2018, and photos of the Site (from Google Streetview), are provided in Appendix B. Balfour Beatty has now completed the relevant works on the A14 and has vacated the Site.

0.3 In terms of the broader context, U+I have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document).

0.4 In order to deliver the comprehensive redevelopment envisaged in the NEC AAP, a number of existing industrial /non-conforming uses (to residential) will need to either be re-accommodated within a mixed use, higher density, development superblock within NEC AAP or, more likely, be relocated from areas such as Cowley Road Industrial Estate to another location close to the north-eastern edge of Cambridge.

0.5 A Commercial Advice and Relocation Strategy has been commissioned by GCSP to consider this matter in greater detail, and its findings are expected imminently. It is unfortunate that this has not been made available to comment upon during this consultation process.

0.6 Notwithstanding this, it is considered that the Site has significant potential to accommodate the existing, important, businesses in the NEC AAP that will be displaced as a consequence of the major residential-led mixed use development that will be brought forward, following the decommissioning and relocation of the Waste Water Treatment Works.

0.7 Pre-Application Advice was sought from GCSP in respect of a series of development scenarios for the Site, as provided in Appendix C. The purpose of this was to explain the flexibility of the Site, and the attitude towards development of U+I to support those businesses that play a vital role in the wider economy and have a demonstrable need to be on the North-Eastern edge of Cambridge on a site that has excellent connectivity to the strategic highways network and pedestrian/cycle connectivity into Cambridge via the Jane Costen bridge.

0.8 A series of preliminary technical documents were also provided to support the pre-application request and can also be found in Appendix C.

0.9 The Site is currently located within the Green Belt, and this representation requests that it is released and allocated to accommodate commercial/employment uses for those business displaced from the NEC AAP

1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing OBJECT

1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.

1.3 It is essential that any increase to housing is supported by a commensurate increase in the level of jobs (and vice versa), in order to maintain to maintain an appropriate balance of locating homes close to opportunities to work, within or on the edge of Cambridge, where it is accessible to public transport and/or good pedestrian / cycle / micro-mobility connections. 1.4 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.

1.5 It is essential that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

Policy S/DS: Development Strategy OBJECT

1.6 Whilst we broadly, partially, support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land (noting that it has already been identified for homes and jobs growth) we object on the basis that it does not identify the Site as a suitable ‘receptor’ site for displaced commercial uses from NEC AAP.

1.7 Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release the Site, which is related to the specific need to provide land for existing businesses that will displaced by the NEC AAP.

1.8 Paragraph 141 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identified previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

1.9 Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport.

1.10 The Site is ideally located to NEC AAP, being on the fringe of it, well connected to the strategic highway network and will be extremely well connected to NEC AAP via existing pedestrian and cycle routes across the Jane Costen bridge, that will lead directly into St John’s Innovation Park and the wider NEC area beyond it. Therefore, the release of the Site from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that will support active travel.

Section 2.6: Rest of Rural Area / Policy S/RRA: Allocations in Rest of the Rural Area OBJECT

1.11 The successful delivery of the redevelopment of NEC is a key part of the development strategy for emerging GCLP. However, the redevelopment of NEC is reliant in part on the timely relocation of existing business from land to be redeveloped by other uses. It is considered that the relocation process would be made easier if additional land was identified in emerging GCLP for relocated businesses from NEC, whether temporary or permanent.

1.12 It is requested that the Site should be allocated in emerging GCLP as a suitable relocation site for some businesses that will be displaced from the NEC AAP. This outcome would represent the exceptional circumstances to justify the release of land from the Green Belt.

1.13 It is considered that, taking into account the current Green Belt status of the Site, land could be suitable for a range of potential industrial uses (or other uses that would be deemed ‘non-conforming’ to the residential uses within the NEC AAP). The Site is ideal for this type of end-use – there are no existing residential receptors within close proximity (the nearest residential property in Milton is 125m away, but this would separated by the intervening existing Industrial Park and Tesco), and the nearest new residential receptor in NEC AAP will be over 100m away and separated by the A14 (and therefore any residential edge of NEC AAP will be protected by new acoustic barriers on the southern edge of the A14).

Policy S/NEC: North-East Cambridge SUPPORT

1.14 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process. 1.15 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC. 1.16 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP. Policy BG/BG: Biodiversity and Geodiversity OBJECT 1.17 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).

1.18 The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so: • Post-development biodiversity value of the onsite habitat; • the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development; • the biodiversity value of any biodiversity credits purchased for the development;

1.19 Whilst U+I recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).

1.20 GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.

1.21 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments
SUPPORT


1.22 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy J/NE: New Employment Development Proposals
SUPPORT

1.23 We broadly support the intent of the policy but consider that GCSP should be taking a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area.

1.24 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries
SUPPORT

HELAA Site Assessment – Land South of Milton, North of the A14 (Site Ref. 47943)

1.25 U&I’s comments and suggested amendments to the site assessment are as follows: – Proposed Development – refers to Residential, Market and affordable housing, Specialist/other forms of housing, Office, Research and Development. We would request this be amended to B2/B8/sui generis uses applicable to other uses currently in NEC AAP i.e. those that might be considered non-conforming to residential; – Flood Risk – it is considered that this should be categorised as ‘green’.
The Site lies within Flood Zone 1, and any planning application would need to be accompanied by a site-specific Flood Risk Assessment, demonstrating how any localised flood risk arising from the proposed development could be adequately mitigated. Furthermore, the proposed use would be considered less vulnerable in flood risk terms.

– Landscape and Townscape: the Site lies between the existing urban edge of Milton (with Tesco to the north, the industrial park to the east, and separated from NEC AAP by the A14. The northern edge of NEC AAP (opposite the Site) has been considered acceptable (in Landscape / Townscape assessment) for new development of 3-6 storeys. It therefore seems perverse that the Site can be assessed as ‘Red’ in Landscape and Townscape terms and would request this be
changed to Green. The intended uses for the Site would be industrial / storage / sui generis uses, that are likely to be typically 1-2 storeys in height. The Site also benefits from landscaping on its boundaries, to help soften the impact of any new development.

– Site Access – we would request that this is changed to ‘Green’, given that the assessment notes that the proposed site is acceptable in principle subject to detailed design. There are potential access constraints, but these could be overcome through development.

- Noise, Vibration, Odour and Light Pollution – we would request that this is changed to ‘Green’, given that the assessment notes that ‘the proposed site will be affected by road traffic noise from nearby main roads but is acceptable in principle subject to appropriate detailed design considerations and mitigation. The proposed site will be affected by noise from nearby industrial/commercial activities but is acceptable in principle subject to appropriate detailed design considerations and mitigation. The site is capable of being developed to provide healthy internal and external environments in regard to noise / vibration/ odour/ Light Pollution after careful site layout, design and mitigation. Furthermore, the proposed use for industrial / storage / sui generis would be less sensitive (than for a residential use, for instance).

– Strategic Highways Impact: The good accessibility of the Site by sustainable modes of transport and future improvements to public transport, walking and cycling, would provide employees with an alternative to the car for journeys to work and reduce traffic impacts from the promoted development. If the Site is to be used as a ‘receptor’ site for existing industrial uses in NEC AAP, such uses will already be making a contribution to the strategic network (in terms of existing trips) and therefore the proposed use of this Site will have a negligible impact.

– Green Belt: The Site is currently located within the Green Belt. The Site has been assessed as having ‘moderate high’ Green Belt value. In comparative terms, this performs well in the context of other Green Belt sites in the north of Cambridge. Notwithstanding this, in terms of the five spatial ‘Purposes’ of Green Belt, namely: (a) to check the unrestricted sprawl of large built-up areas; (b) to prevent neighbouring towns merging into one another; (c) to assist in safeguarding the countryside from encroachment; (d) to preserve the setting and special character of historic towns; and (e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

1.26 It is considered that only (b) and (e) would potentially be relevant here. In terms of (b) the Site lies in between the urban edge of Milton, and the northern edge of Cambridge. Theoretical coalescence between Milton and Cambridge has already, in effect, taken place by the presence of the industrial park, and its relationship to the north of Cambridge. However, this is physically separated by the permanent presence of the A14. The same would be true if the Site is developed. In terms of (e), it is considered applicable, albeit in the opposite manner of how (e) is intended. The release of land from the Green Belt here will assist in urban regeneration, by providing a receptor site that aids relocation of existing sites and facilitates NEC’s delivery.

1.27 It is considered that the Site provides lower value in Green Belt terms than has been assessed and its release would provide significant benefits insofar as providing a receptor site for important commercial/employment uses that would be displaced by the wider regeneration taking place at NEC.