S/DS: Development strategy

We agree with expanding Cambourne further into a vibrant town given the new East West Rail station which will make it a well-connected area. The significant improvement in public transport will enhance the services available in the village of Caxton. There is support for continuing development at the new settlements of Northstowe, Waterbeach and Bourn Airfield allocated in previous plans although it is not considered realistic that faster housing delivery rates take place at the new towns of Northstowe and Waterbeach. We object to very limited amount of development in the rural area with further development needed in order to support the vitality of villages.

We agree with expanding Cambourne further into a vibrant town given the new East West Rail station which will make it a well-connected area. The significant improvement in public transport will enhance the services available in the village of Caxton. There is support for continuing development at the new settlements of Northstowe, Waterbeach and Bourn Airfield allocated in previous plans although it is not considered realistic that faster housing delivery rates take place at the new towns of Northstowe and Waterbeach. We object to very limited amount of development in the rural area with further development needed in order to support the vitality of villages.

We agree with expanding Cambourne further into a vibrant town given the new East West Rail station which will make it a well-connected area. The significant improvement in public transport will enhance the services available in the village of Caxton. There is support for continuing development at the new settlements of Northstowe, Waterbeach and Bourn Airfield allocated in previous plans although it is not considered realistic that faster housing delivery rates take place at the new towns of Northstowe and Waterbeach. We object to very limited amount of development in the rural area with further development needed in order to support the vitality of villages.

We agree with expanding Cambourne further into a vibrant town given the new East West Rail station which will make it a well-connected area. The improvement in public transport will enhance the services in the village of Caxton. There is support for continuing development at the new settlements of Northstowe, Waterbeach and Bourn Airfield allocated in previous plans although it is not considered realistic that faster housing delivery rates take place at the new towns. We object to very limited amount of development in the rural area with further development needed in order to support the vitality of villages.

This statement appears to be false : ‘we do think that it may be possible to demonstrate that exceptional circumstances exist to justify a limited release of Green Belt at Cambridge Biomedical Campus’. You fail to declare release of a huge piece of Green Belt elsewhere at Honey Hill.
The council has declared a climate emergency, we should not be concreting over our green spaces and trucking in water at huge carbon cost. Rebuilding an operational WWTP just a mile away, at enormous carbon impact and trashing a peaceful open landscape to build under 4000 houses is appalling

The strategy places too much emphasis in providing homes on large urban extensions to Cambridge City and new settlements in South Cambridgeshire. The limits placed upon small new housing sites in, and around smaller settlements are excessive. It fails to have sufficient regard to supporting sustainable rural development. The policy will not assist in maintaining and enhancing the vitality of rural settlements and fails to address the increasing demand for housing away from larger settlements because of the Covid 19 pandemic.

Paragraph 35 of the National Planning Policy Framework (NPPF) confirms that plans are sound if they are, among other things, consistent with national policy.

Paragraph 60 of the NPPF stipulates that to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.

Whilst Paragraph 73 of the NPPF indicates that the supply of large numbers of new homes can often be best achieved through larger scale development, that is not a requirement. Moreover, to ensure that there are sufficient small and medium sites included within development plans, Paragraph 69 of the framework requires the development plan to accommodate at least 10% of their housing on sites no larger than 1 hectare, unless it can be shown that there are strong reasons for not doing so. The strategy set out in Policy S/DS conflicts with NPPF Paragraph 69. It is contended therefore, that the over-reliance of Policy S/DS upon large sites does not comply with the aims of the Framework.

Support the policy as it promotes active travel and public transport as the natural choice to try to address the climate crisis, to reduce carbon usage. Green Infrastructure must be delivered before, or alongside new development. Jobs should be where people live (reduce long distance commuting)

1 These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2 The GCLP states that the proposed development strategy to guide the growth of Greater Cambridge over the plan period supports “rural communities to thrive and sustain services”. In rural areas of Greater Cambridge the development strategy proposes a “a very limited amount of development” at small sites at villages which have “very good public transport access”.

3 After accounting for existing committed housing supply, the First Proposals document states that new sites to deliver 11,640 additional dwellings are needed to meet the housing need target. To help meet this new need the proposed development strategy seeks the allocation of four new sites in the rural area of Greater Cambridge, two of which are located in the “Group Villages” Caldecote and Oakington. These four sites can deliver 224 dwellings. This equates to the rural area delivering only 1.9% of the new housing supply need. This figure rises to 3.2% if the housing delivery associated with supporting jobs at research parks to the south of Cambridge is included.

4 The development strategy is heavily reliant on the delivery of new settlements and strategic sites with 62% of the total supply over the plan period coming from these sources. Strategic sites and new settlements are often complex developments to bring forward and implement with significant investment in infrastructure often required before dwellings can be delivered. It is acknowledged that these types of sites have a role to play in meeting housing needs, however, it is clear that the proposed development strategy is heavily reliant on such sites coming forward, to a point where it risks the deliverability of the GCLP.

5 The development strategy and approach to making new allocations will not facilitate the delivery of thriving rural communities and risks the vitality of key services over the plan period. The rationale for proposing allocations in Caldecote and Oakington as opposed to other available and suitable sites at other Group Villages is not evidenced robustly. It would appear that the Councils development strategy for rural areas has been one which in the main restricts development, and where allocations are proposed, the process of making allocations has been site-led rather than being led by an objective process which compares the sustainability credentials of sustainable rural settlements.

6 The First Proposals document and accompanying evidence base aims to support rural communities and sustain their existing service provision, but its current approach to making new housing allocations and supporting Neighbourhood Planning will not deliver on this aim.

7 Planning policies are required to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to their objectively assessed housing need. The NPPF makes it clear that planning policies need to bring forward a mix and variety of housing land. The approach proposed through the GCLP does not represent a flexible and balanced approach capable of responding to changing circumstances or providing a mix and variety of sites. In addition, paragraph 69a) of the NPPF requires development plans to accommodate at least 10% of their housing requirement on sites no larger than one hectare. The development strategy proposes no new housing allocations on sites of less than 1ha. Instead, the GCLP relies on previous commitments to be delivered in the plan period and the potential for these smaller sites to come forward via windfall sites. Page 40 of the First Proposals document confirms that the new allocations of this type are not proposed as they would likely need to be directed to less sustainable locations, thus having a negative impact on climate change and requiring Green Belt releases. Our client strongly disagrees with the Councils justification in this regard as the content of the Housing Economic Land Availability Assessment (HELAA) demonstrates that there are a number of available sites for residential development, located outside of the Green Belt, at sustainable settlements such as Group Villages.

8 The GCLP’s focus on directing growth to New Settlements and strategic sites will significantly limit the supply of new housing sites being delivered by smaller and mid-sized (SME) housebuilders. Paragraph 69 of the NPPF makes it clear that small and medium sized sites can make an important contribution to meeting the housing requirement of an area. The Government is keen to see these types of sites come forward to boost supply, increase design quality, increase delivery rates and assist SME housebuilders generally. The lack of small and medium sized sites being delivered by the GCLP is contrary to paragraph 69 of the NPPF and will likely lead to a constrained housing land supply over the plan period and see less bespoke housing schemes being delivered at a time when there is national drive to boost design quality.

9 Over the current plan period and historically in Greater Cambridge there has been significant pressure placed upon the five-year housing land supply. This in part is due to the current over reliance on strategic sites and failure to allocate proportionate growth at established rural settlements which have fewer delivery constraints. Accordingly, promoting a development strategy which provides variety in making new allocations will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP and Neighbourhood Plans should take the lead by positively planning for new housing at established sustainable rural settlements, such as Group Villages, rather than being subject to future speculative development proposals at sites not allocated in a Local Plan when there is a deficit in supply across the plan area.

10 Alongside the total housing need requirement, the proposed development strategy should be reconsidered and amended to ensure that established settlements in the rural area benefit from sustainable levels of housing growth.

The aims are laudable, but it is difficult to see how a development of 44,400 houses is compatible with the decrease in climate impact and better quality of life. To achieve this, new development should be required to have solar hot water and high levels of insulation.

Shudy Camps Parish Council and residents are grateful for the decision not to take either of the proposed sites in the Parish forward to the ‘short-list’. We are grateful that the policy of protecting our villages and the rural nature of the surroundings has been adhered to. The proposed sites would have caused a strain on the local infrastructure, vastly increase the levels of traffic and would have worsened the flooding that our parish is already susceptible to as a result of poor drainage.”

The plans should incorporate even less focus on the Green Belt and villages than they currently do. Greater focus on new settlements / communities and expanded development of existing sites is the most appropriate way to deliver increased housing stock.

The potential of existing projects within the Cambridge city limits should be maximised. However, growth in new settlements such as Cambourne, Waterbeach and Northstowe, which can be designed with excellent transport links (including East-West Rail) are by far the best approach to increased housing delivery. They offer a blank canvas with which to design climate friendly and enjoyable living spaces within suitable locations. They do not place a development burden on existing villages, damaging these locations irreparably for those already living there. They can also be sited (as has been done with Cambourne, Waterbeach and Northstowe) outside of the Green Belt.
A carefully considered design incorporating suitable levels of facilities and open spaces is clearly important. Locating new jobs in these areas, for example through adjoining new business parks would appear a good way to help achieve climate friendly objectives and increase the attractiveness of these new communities to would-be residents.

SCDC’s recognition the First Proposals that the plan should include very limited (or ideally no) development in existing villages is fully supported. Even where villages have good public transport connections, this objective should still apply: good public transport connections is not unique to any of these villages. In fact, public transport links within Cambridge and from new settelements are in general at least as strong.
I am not in favour of any development, and certainly not on any kind of significant scale in any local villages. Above all though, villages within the Green Belt should be spared from any further development and villages to the north of Cambridge are less attractive for any form of development given the existing imbalance of new jobs vs. new housing, which clearly points to more development south of Cambridge being the overwhelming priority.

Draft Policy S/DS (Development strategy) in respect of site 40425 (Objection) - for full text please see document attached.

We agree with the approach used to develop the spatial strategy and develop around larger areas where infrastructure already exists.

I oppose the inclusion of site S/RRA/MF in Oakington, because the green belt here is more important than ever due to the minimal separation of Northstowe from the village (which was not as originally promised.) Building up on both sides of Oakington is not safeguarding its heritage and landscape (ref. “Vision”). The field adjacent to the site regularly floods. These 20 houses are a tiny part of the overall plan but the development will have a big negative impact in a village already hugely affected by Northstowe. The removal of green belt status is not justifiable.

The proposed development strategy for Greater Cambridge directs the vast majority of growth to the Cambridge Urban Area, the edge of Cambridge and new settlements. Only a very small level of growth is directed to the Rest of the Rural Area. RWS Ltd are of the view that the Council should look to deliver a greater number of smaller allocations to ensure that there is a supply of housing that can be built out sooner within the plan period, in accordance with the NPPF.

Introduction

Walsingham Planning is submitting this representation on behalf of R. Cambridge Propco Limited, the owners of the Cambridge Bar Hill Hotel and Golf Course, Bar Hill, CB23, 8EU.

From the outset, we note that our client fully supports the Local Plan’s vision of planning for enough homes to meet Greater Cambridge’s needs, with a strong mix of housing types and tenures. We also note that the Local Plan First Proposals aims to deliver 1,771 new homes per year, which is 550 more homes per year than under the current policy context, and this is an ambitious strategy, which is to be supported. However, in order to secure this uplift in housing delivery, it is clear that the new Local Plan must be underpinned by a range of housing allocations which are deliverable in both the short and longer-term.

Development Strategy

Draft Policy S/DS sets out the proposed Development Strategy to deliver the vision, which includes provision for 44,400 new homes. The Strategy explains that the proposal is to utilise existing planning permissions alongside “a limited number of new sites in the most sustainable locations”. Indeed, it is clear from the schedule in the draft policy that the vast majority of the Council’s housing growth it to be accommodated on just 13 sites. Whilst concentrating housing development in a limited number of locations may have the benefit of creating sustainable new hubs of development, it also bears risks in terms of the deliverability of the strategy. For example, if there are any unforeseen delays on any of the major projects, it will have a significant detrimental impact on the ability to meet Greater Cambridge’s housing needs.

This is a real risk and one that is recognised in the National Planning Policy Framework (NPPF). We note that paragraph 60 of the NPPF states that:

“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed”.

Furthermore, paragraph 68 explains that:

“Planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability, and likely economic viability”.

More specifically, paragraph 68 notes that planning policies should identify specific deliverable sites for years 1 – 5 of the plan period; and specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan. At present the emerging Local Plan is only at the ‘First Proposals’ stage, but no information is currently provided to explain which of the proposed site allocations will be deliverable within the first five years of the plan period, and which will represent medium and longer-term opportunities.

Finally, we note the contents of paragraph 69 of the NPPF, which is clear 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”.

This is a key point, and it is our view that the proposals put forward in the emerging Local Plan document are currently over-reliant on the delivery of a limited number of strategic sites. For example, of the 11,596 additional homes required, 11,200 (i.e. 97% of the total additional requirement) are planned to be provided on just 6 sites.

We note that one proposed new allocation at North East Cambridge (ref. S/NEC), which is to deliver a substantial 3,900 new dwellings, is on the site of an existing waste water treatment works. The draft policy for this allocation explains that delivery of a new mixed-use development on this site is reliant on the relocation of the existing works, a process which is being led by Anglian Water. The proposed development is also reliant on the successful implementation of the North East Cambridge Trip Budget, which has been calculated to ensure that there are no additional vehicle trips on Milton Road at peak times and subsequently no result in queuing on the A14 at Milton Interchange. It is clear, therefore, that there are significant hurdles that will need to be overcome before any scheme can progress on this site, and the timescales for development are currently very much unknown.

Similarly, 2,750 new homes are proposed on the Cambridge Airport site (Policy S/CE). However, it is clear from the policy wording that this is another long-term opportunity, as it is reliant on the closure and relocation of the airport, which is currently not anticipated to take place before 2030.

The Development Strategy also relies upon the faster delivery of housing at planned new settlements in Northstowe and Waterbeach, which will bring forward 1,500 additional new homes before 2041. However, whilst some acceleration of development may be possible at these new settlements, the additional new homes – that were previously expected after 2041 – are not likely to be available until towards the end of the plan period.

It is clear, therefore, that the emerging Local Plan relies upon its existing allocations – which have not yet been built-out - combined with a limited selection of new strategic sites, but each with its own constraints.

It is our firm view that the Local Plan should make provision for a wider range of sites, and include more small and medium-scale opportunities, to ensure a more fluid supply of housing land and ensure that there are also sites dedicated to deliver housing growth in the shorter term.

Alternative site at Bar Hill

With this in mind, it is relevant that we recently submitted our client’s site (the Bar Hill golf course) to the ‘call for sites’ exercise (ref. 56476). The site has not yet been assessed and so was not taken into account in the formulation of the First Proposals document, but we consider that it offers strong potential as a future allocation to provide an additional option to support housing growth in the Greater Cambridge area in a sustainable location.

Full details about the site can be found in our call for sites submission, and so we do not seek to reiterate all of the site specific information here. However, in summary we believe that this site has strong potential to provide a sustainable urban extension at Bar Hill (delivering around 300 homes, with complementary facilities). It should be noted that this site is available for the use proposed, and the site owner is already progressing a pre-application enquiry with the Council in relation to the prospects for the site.

The site comprises the existing golf course, with its associated fairways, roughs and bunker, alongside two ornamental lakes. There are also three storage barns located in the north of the site, which would be removed as part of any development. The site lies directly adjacent to the established settlement of Bar Hill (a minor rural centre) and has good potential to form a natural sustainable urban extension to the settlement. Indeed, the urban area of Bar Hill already extends in the direction of the golf course. The site is also bounded by the A14, which has recently been upgraded through junction improvements, and this also forms an urbanised edge to the site, on its northern boundary.

It is relevant that Bar Hill is well-served by a range of shops, services and community facilities, including a Tesco Extra store, public house, Post Office, primary school and village hall. The local centre, anchored by Tesco, is located off Saxon Way, within easy walking distance of the hotel and golf course. A new residential development on the land would thus be sustainably and accessibly located with regards to the main facilities of the settlement. It is also notable that there are two bus stops on Crafts Way (known as ‘Hollytrees’ and ‘Acorn Avenue’), which are both adjacent to - and within easy walking distance of - the golf course land, and which provide access to bus services to Cambridge, Swavesey and the centre of Bar Hill. The site would therefore be well-served by public transport.

The site is subject to few physical, heritage or environmental constraints. The site is not located within a Conservation Area and there are no listed buildings within the vicinity of the site. A stream does bisect the site along its northern extent (close to the lakes), and the land along its banks does fall within Flood Zone 2 / 3. The land within the higher flood risk areas would remain clear of residential development. The majority of the golf course, however, lies within Flood Zone 1 and is thus within the lowest area of risk of flooding from coastal and fluvial sources.

It is recognised that the entire extent of the golf course lies within the designated Green Belt. However, we note from the recent Greater Cambridge Green Belt Assessment (2021) that the land does not contribute strongly to the purposes of the Green Belt designation in this location. The Assessment identifies three purposes of the Cambridge Green Belt, and the site scores as follows:

- Purpose 1 – Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre: Limited / No contribution;
- Purpose 2 – Maintain and enhance the quality of its setting: Moderate contribution; and
- Purpose 3 – Prevent communities in the environs of Cambridge from merging into one another and with the city: Moderate contribution.

The Assessment concludes that the release of this land from the Green Belt would have a ‘moderate / high’ level of harm on the Cambridge Green Belt. The Assessment explains that this would mean that:

“Release of land results in a loss of strong contribution to one of the Green Belt purposes, but would constitute a negligible impact on adjacent Green Belt land"; or

"Release of land results in a loss of relatively limited contribution to one of the Green Belt purposes, and would constitute a moderate impact on adjacent Green Belt land”.

The assessment does not therefore rule out the release of this land from the Green Belt. In particular, it is highly relevant that the site performs much better in the assessment that most plots, with the harm rating for the vast majority of the Green belt land assessed as being ‘high’ or ‘very high’. The site is one of a very small number of plots that attained a ‘low’ to ‘moderate high’ harm rating in the recent assessment.

Moreover, it is relevant that as part of a development on this land, the vision is to retain the majority of the golf course site as ‘open land’. It is envisaged that the north-west section of the golf course (to the north of Crafts Way and The Fairway) could be developed to provide a new neighbourhood within Bar Hill, which would function as a sustainable urban extension to the settlement. Meanwhile, the retained area of land would have the potential to act as a strategic reserve for future housing allocations or might be converted to form a new country park / area of public open space / allotments / recreation or sporting use, with possible focus on planting and habitat creation which would deliver substantial biodiversity net gain over the existing use of the land as a manicured golf course. Certainly, any development on this land, has the potential benefit of opening up the southern / eastern areas of the land for public access, delivering significant new areas of public open space for the Bar Hill / north Cambridge communities on either a temporary or permanent basis.

The proposed residential element of the scheme would include a mix of housing styles, sizes and types, and could include apartments as well as detached and semi-detached dwellings, to cater for the full range of local housing needs. There would also be scope to provide some self / custom-build plots, and the scheme would of course include affordable housing provision. There is scope to provide some form of community building / local shop, to service the local community’s needs, and – subject to further market testing – additional complementary uses could be added. There is scope to provide these uses along the main spine through the development, or around a new village square.

Conclusion

In summary, whilst our client supports the vision of the Local Plan First Proposals document, it is our view that the Development Strategy requires further amendments in order to deliver the housing growth planned.

The Local Plan, as currently drafted, places an over-reliance on a limited number of strategic sites, and it is our view that it would be preferential to include a broader range of small and medium-sized sites, which are less constrained; that are available now; and that can ensure a supply of deliverable housing land in the short-term. Moreover, this strategy would also ensure that there is more choice and flexibility in the plan, so that if a problem arises with one of the larger strategic sites, housing delivery can continue on alternative sites.

To this end, we would encourage the Greater Cambridge Shared Planning Unit to seriously consider our client’s site at Bar Hill golf course, which can provide a sustainable urban extension to an existing settlement in a sustainable location, and which can deliver around 300 homes, in addition to community facilities and new publicly-accessible green infrastructure. We consider that this site would complement the draft Development Strategy, and provide a medium-scale site which is deliverable within the Local Plan period.

(Education) The plan proposes that sites are developed at densities with recognition that ‘using less land for development reduces carbon emissions and allows more space for nature and wildlife’. Whilst the Council accepts these principles, sufficient land would need to be made available for educational purposes.
Cambridgeshire County Council’s Children and Young People Committee have previously approved the site sizes which would be required to deliver a new school. These ensure that there is sufficient flexibility for sites to be developed in line with space per pupil/area guidelines provided by the Department for Education (DfE) (DfE Building Bulletins 103 and 104 for mainstream and special provision respectively), and allows for on-site early years and childcare provision, in line with Council policy. Whilst the Council will endeavour to explore different options for delivery or education provision, and in keeping with the surrounding area, there would need to be clear reasoning for any request to deviate from its policy and published national DfE’s Building Bulletins’ guidance for full consideration by members of the relevant committees.
The proposed strategy is heavily informed by the location of existing and committed public transport schemes. The Council is fully supportive of this but would also insist that footpaths and cycle routes are taken into consideration, to ensure that schools are centrally located and easily accessible to families living within the catchment area and to fulfil the objective that ‘developing sites can be well-integrated with existing communities’. This ensures that children and their families can attend them by either walking or cycling rather than through local authority provided transport or car and fulfil health and well-being expectations for children, e.g., around ‘healthy schools’

(Transport) From the evidence of the options tested at the time S01 performed best in transport terms. It should be noted that not all transport mitigation had been tested. Transport however is not the only consideration when developing a Local Plan and there are numerous other factors that require consideration. Therefore we are happy to support S09 Preferred Option growth level Preferred Option spatial strategy for the Emerging Local Plan. S09 emerged from including sites that performed well in transport terms in earlier testing. Section 15 of the Greater Cambridge Local Plan: Transport Evidence Report October 2021 provides a good summary of the transport impacts.
It is noted that North East Cambridge and Cambridge Airport, Waterbeach and existing new town development lead to better performance in transport terms and greater internalisation of trips. Generally, the larger the development the greater the chance of trips being internalised, and the settlement is likely to have a greater chance at being able to provide key services and facilities.
Cambourne was the best performing in transport terms of the free-standing new settlements of those tested at stage one- with the Cambourne to Cambridge public transport scheme and East West Rail included. Any development in the Cambourne / Bourne Airfield area needs to have good links to the existing community to enable greater access to services and to reduce the potential transport impacts of any new development.

Policy S/DS: Development Strategy
The GCLP aims to deliver the majority of development in and around the City of Cambridge and through new settlements. A small amount of development is proposed in the Rural Southern Cluster area in South Cambridge, including Green Belt land. The GCLP does not allocate any growth to sustainable villages such as Gamlingay. I have some concerns regarding this approach as it does not offer the chance for rural villages to continue to thrive and sustain their local services. Sustainable and logical sites have been omitted from the plan in favour of large sites and some Green Belt release.
Housing allocations should serve to maximise housing supply through the widest possible range of sites, including smaller sustainable sites in villages. Though the new settlements and urban extensions could have multiple housebuilders and outlets, these do not provide local, smaller housebuilders the opportunity to acquire sites. I have reservations that the over reliance on large schemes will delay much needed housing coming forward and would encourage the Councils to consider a more balanced approach to their spatial strategy, including allocations in smaller villages such as Gamlingay, Linton, Melbourne, Gransden etc.
With regards to development in smaller sustainable villages, I refer to paragraph 79 which states
‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.

There is very little residential development proposed for the rural areas which questions whether the Council will meet the NPPF target of delivering at least 10% of their housing requirement on small and medium sized sites (as set out within paragraph 69 of the NPPF). Land to the rear of 89 Rampton Road, Cottenham would provide a sustainable small site with potential for self-build properties. The GCLP needs to provide for a range of different housing needs which allows smaller settlements and rural areas to continue to thrive. This is in accordance with Paragraph 79 of the NPPF which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

The Trumpington Residents' Association supports the policy's approach of placing limits on further development within and on the edge of Cambridge within the proposed Plan, apart from already approved sites and specific areas to the north west, north and north east of the city centre, but not around Trumpington (page 32). We support the statement that housing needs alone do not provide the 'exceptional circumstances' to justify removing land from the Green Belt on the edge of the city (page 39). We support the emphasis on growth in new settlements (page 40).

We refer again to the sites to which we had objected in the Call for Sites process and our strong support for the omission of most of those sites from the proposed developments within the Plan.

Our greatest remaining concern is site 056 (the so-called 'Cambridge South'), one part of which was between Hauxton Road and Shelford Road to the south of Addenbrooke's Road and another part adjacent to the Cambridge Biomedical Campus, land which has been partly incorporated in Policy S/CBC (see S/CBC and the Development Strategy Topic Paper, pages 129-136).

Local sites included in the Call for Sites process:

131: Land west of Trumpington Road: 540 homes
592: Clare College Sports Ground, Bentley Road, Cambridge: 110 homes
091: Telephone Exchange and Car Park, Long Road, Cambridge: 100 homes (see R14, page 72)
089: Cambridge 'D' Telephone Exchange, High Street, Trumpington: 50 homes
160: Trumpington Park and Ride site, Trumpington: 290 homes
042: Land north of M11 and west of Hauxton Road, Trumpington: 750 new homes
056: Land south of Addenbrooke's Road and east of M11 plus land south of the Cambridge Biomedical Campus, 'Cambridge South': revised proposal for c. 5000 homes and 436,000 sqm of employment space, incorporating the original sites 132, 590, 127, 129, 128;
132: Land south of Addenbrooke's Road, Trumpington: 280 homes (see Site 056)
590: The Davey Field, Cambridge Rd, Great Shelford: 72 to 87 new homes (see Site 056)
398: Land off Cambridge Road, Gt Shelford: c. 120 homes
099: Land east of Cabbage Moor, Great Shelford: 400 homes
054: 144 Cambridge Road, Great Shelford: 25 homes
488: Land at 6 Cabbage Moor, Great Shelford: 5 homes
514: Land off Cabbage Moor, Great Shelford: 70 homes
subtotal: c. 500 homes
603: Addenbrookes Hospital Extension [part of Cambridge Biomedical Campus, phase 2]
127: Land at Granham's Road, Cambridge and Great Shelford: 990 houses (see Site 056)
129: Land south of Babraham Road, Shelford Bottom, Cambridge and Great Shelford: 880 homes (see Site 056)
128: Land south of Worts Causeway, Cambridge and Great Shelford: 490 homes (see Site 056)

If Trumpington had been identified as one of the 'edge of Cambridge' locations, this would have resulted in even more housing for this area. Another option of large scale building in villages south of Trumpington would have resulted in even worse traffic congestion in Trumpington, as people commuted into Cambridge or to the Park & Ride sites.

We have a strong concern that the policy includes support for the release of land for the Cambridge Biomedical Campus, including homes and employment. The sources of housing supply to meet the projected demand does not seem to include figures within the proposed Cambridge Biomedical Campus expansion (second table on page 32) (site 056). We challenge this omission.

We note that the number of additional homes includes a 10% buffer which accounts for 40% of the total number of additional homes (first table on page 32): we are very concerned by this approach.

We query the failure to provide clear information about where employment land is located and to categorise this land into different potential uses. There apparently is a considerable amount of employment land already identified (page 33).
[Appendix H of the Greater Cambridge Employment Land and Economic Needs Study meets this point in part. Policy S/CBC does not refer to this supply at all.] [see Jobs, Pages 228-232]

We reiterate the reference to housing needs alone not providing the 'exceptional circumstances' to justify removing land from the Green Belt and challenge the additional statement that 'limited release' might be justified for Cambridge Biomedical Campus (page 39). If it is proved to be justified, why is it on such a scale and so detrimental to the Green Belt and high-quality agricultural land. If there is a justification for the limited release of land from the Green Belt to enable life sciences businesses to expand and grow, including at Babraham and Cambridge Biomedical Campus (page 36), the land should be used for these purposes and not for additional homes.

We challenge the sustainability argument used to support continued development in/on the edge of Cambridge in the spatial strategy. Looking beyond the period of the current plan, there must be a limit to this type of growth if Cambridge is to survive as a liveable and compact city.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.
It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Meldreth, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in Hastingwood Developments’ representations to Section 2.6: Rest of Rural Area, the land at Bury End Farm in Meldreth should be allocated in emerging GCLP for residential development.

OBJECT

Hastingwood Developments is promoting land at Bury End Farm off North End in Meldreth for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The preferred development strategy for the rest of the rural area is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for some villages, including Meldreth, which contain a good range of services and facilities and is accessible by sustainable modes of transport. In addition, the preferred development strategy for the rest of the rural area provides no support for existing services and facilities in villages and provides no strategy to meet current identified affordable housing needs of villages. Hastingwood Developments are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages to support services and ensure that identified affordable housing needs are met.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Meldreth contains a good range of services and facilities, including a primary school and special education needs school, convenience store, and public house. There are additional services in Melbourn, including a secondary school. There is a train station at Meldreth providing services to Cambridge and London. Meldreth is also on a bus route with services to Royston. The Greater Cambridge Partnership has identified a potential rural travel hub at the railway station, which would provide additional cycle parking facilities. The site promoted by Hastingwood Developments at Bury End Farm in Meldreth is accessible to all of the services and facilities in the village by walking, cycling and public transport. There are realistic alternatives to the car for travel to and from Meldreth. It is considered that additional housing in Meldreth would support the existing services and facilities.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 36 affordable dwellings in Meldreth for those with a local connection to the village – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdfT. This identified need would not be met without allocations in Meldreth. It is noted that there is no neighbourhood plan being prepared for the village, no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Hastingwood Developments at Bury End Farm in Meldreth would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

In addition, Paragraph 120(d) of the NPPF expects planning policies to promote and support the development of under-utilised land and buildings and to use sites more effectively including for housing. The site at Bury End Farm in Meldreth is currently occupied by a turkey factory. The promoted development would remove the existing use from the site, which would provide benefits to the neighbouring residential properties and to the village generally in terms of removing noise, odour and traffic movements associated with the existing turkey factory operation. The redevelopment of the site at Bury End Farm in Meldreth for housing would be consistent with Paragraph 120(d).

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.
It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Meldreth, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in Hastingwood Developments’ representations to Section 2.6: Rest of Rural Area, the land at Bury End Farm in Meldreth should be allocated in emerging GCLP for residential development.

Object – whilst we have no objection to the principle of the proposals, we object to the detail. The table showing the ‘Sources of the Housing Supply’ should be amended to cover the number of houses developable under site JDI number 40509; Land to the south of Babraham Road and east of site H1c, Sawston which has incorrectly been omitted from the assessment. The site meets the threshold set by the Council itself and indeed, is more sustainable in terms of access to amenities than some of the other sites allocated within the rural southern cluster and the rest of the rural area and should therefore be included on the table. If site 40509 is not included going forward, then we object to the inclusion of the other rural southern cluster sites and the rest of the rural area on the grounds that the sites are not being equitably assessed with site 40509 which is located in a more sustainable location with better access to amenities than some of these allocations. The reason the claim that the site has been omitted is being made is set out below:

We submitted a site under the original call for sites JDI number 40509; Land to the south of Babraham Road and east of site H1c, Sawston. It appears on the First Conversation Site Submission Map.

On review of the Greater Cambridge Local Plan – First Proposals documentation we have concerns that there has been an error in the assessment of this site.

On review of the HEELA in the First Proposals Document Library,:
• Site 40509 is Listed in Appendix 1 – Full List of Sites.
• It is not included in Appendix 2 which is the Not Deliverable/Developable lists. One therefore assumes it is considered to be a deliverable/developable site.
• A version of the site reference (40509a) appears in Appendix 3 which are the discounted sites, with the justification of it being a ‘duplicated site’.
• It appears in Appendix 4 with a detailed proforma showing it as having one Amber and two Green assessments – see attached extract.

In accordance with the information in the HEELA, we have then reviewed the Strategy Topic Paper. The Strategy Topic Paper confirms that all sites which met the Key Criteria for assessment should be:

‘• Locations with sustainable access: Rural Centres and Minor Rural Centres, but also Group villages with very good Public Transport Access.
• Sites with a green or amber rating in the Housing and Employment Land Availability Assessment’

both of which site 40509 complies with, being on the edge of Sawston which is a Rural Centre with good access to amenities and having met the Amber/Green HEELA threshold.

However, the Strategic Topic Paper makes no reference to site 40509. The site location falls under the ‘Other Site Allocations in the Southern Rural Cluster’ section but does not appear in either the ‘New Allocations’, ‘Continuing Allocations’ or ‘Allocations Not Proposed to be Taken Forward’ subsections. As a new site which met the threshold for assessment within the Strategic Topic Paper, presumably it should be referenced somewhere as either included or not included?

The Strategic Topic Paper assessment refers to the need to continue with the allocation of site H/1:c. Site 40509 abuts Site H/1:C and could therefore reasonably be confused with being part of it. We had assumed the reference within the Appendix 3 of the HEELA to site 40509a being a duplicate was an administration error and that the site was inputted twice, however, with it not appearing within the Strategic Topic Paper, it appears that it has been confused as being part of Site H/1:C and therefore incorrectly removed from assessment going forward.

To address this issue and remove our objection:
• the site should be removed from the HEELA Appendix 3 as a duplicate.
• It should then appear within the Strategic Topic Paper as a site which meets the Key Criteria.
• It should appear in the assessment of ‘Other Site Allocations in the Southern Rural Cluster’
• Based on the fact that it performs equally in terms of Amber and Red and is in a more sustainable location than some of the currently allocated sites within the Southern Rural Cluster, on the basis of the best performing sites being taken forward, it should be included as an allocated site.

Given the amount of development (which I challenge), then this policy sounds very sensible. I do not like the support for East West Rail as a Given the amount of development (which I challenge), then this policy sounds very sensible. I do not like the support for East West Rail as a means to solve connectivity from Cambourne to Cambridge. It is an incredibly expensive solution to a problem which can be solved using the £500M city deal looked after by the GCP. EWR will cause unnecessary environmental damage and planning blight. It has a BCR of 0.6 at best. The only way it has a business case is with housing growth way beyond this plan and in different places. GCSP should not be implicitly supporting it.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Orwell, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in the CEMEX representations to Section 2.6: Rest of Rural Area, the land west of Malton Road in Orwell should be allocated in emerging GCLP for residential development.

OBJECT

CEMEX UK Properties Ltd (CEMEX) is promoting land west of Malton Road in Orwell for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The preferred development strategy for the rest of the rural area is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for some villages, including Orwell, which contain a good range of services and facilities and is accessible by sustainable modes of transport. In addition, the preferred development strategy for the rest of the rural area provides no support for existing services and facilities in villages and provides no strategy to meet current identified affordable housing needs of villages. CEMEX are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages to support services and ensure that identified affordable housing needs are met.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Orwell contains a primary school, village store including a post office, a public house, a hairdresser, a village hall, church hall, recreation facilities and a mobile library service. There is a currently a limited bus service to Cambridge, but it noted that the Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service including for Orwell. Shepreth Station is located approximately 4.5km to the south east of the village. The proposed development would support the existing services and facilities in the village.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 12 affordable dwellings in Orwell for those with a local connection to the village – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without allocations in Orwell. It is noted that there is no neighbourhood plan being prepared for the village, no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by CEMEX at land west of Malton Road in Orwell would include housing and affordable housing to meet local needs of the village, and there will be a policy requirement for a proportion of the housing to be provided as self/custom build plots.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Orwell, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in the CEMEX representations to Section 2.6: Rest of Rural Area, the land west of Malton Road in Orwell should be allocated in emerging GCLP for residential development.

Policy S/DS: Development Strategy sets out where the homes and jobs identified in the Plan should be provided in order to meet the vision and aims of the Local Plan. It is considered that this development strategy is flawed as it concentrates a significant amount of development in new settlements and large edge of Cambridge sites. Less than 4% of the total additional homes and employment sites planned for are to be located within existing villages.

This is not an appropriate response to allow these villages to grow and thrive during the plan period. It is acknowledged that a sustainable strategy is required in relation to the location of new development however, to define all villages in South Cambridgeshire as unsustainable and not allowing any new housing and employment development to meet their needs will ensure that these villages will never grow, prosper, or adapt to changing needs and they will stagnate. In particular the decision to exclude Melbourn from any major employment development is major missed opportunity given the sustainable credentials of the village.

The proposed development strategy in respect of employment is to direct development to where is has 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 close to where people live.
We understand to focus the majority of growth around Cambridge and the other major settlements however there is a particular opportunity we consider has been overlooked at Melbourn. We have made representations to this consultation that Melbourn (along with Meldreth) should be moved up the hierarchy as it is already performing as a Rural Centre.

The land identified in SHLAA: Site Reference 40262 to the east and west of the A10 at Melbourn is perfectly positioned to deliver employment development in a sustainable location without the need to impact on the green belt. The proposed site meets all the criteria outlined in the development strategy criteria above and can deliver a roadside services scheme with B1; B2;B8 employment uses. It would provide job opportunities, commutable by sustainable modes, not only for Melbourn and Meldreth but other surrounding villages as well, supporting the reduction in car dependency and commuting into Cambridge. Other aspirations for a care village identified in our earlier representations have now been replaced with employment development as shown on the amended masterplan.

Melbourn needs to deliver further jobs to provide a balance with existing and proposed future housing growth in the village which includes the two Melbourn sites in the Housing land supply assessment at The Moor (20 dwellings) and Cambridge Road (120 dwellings). The village is more than capable of sustaining larger scale windfall development which is why it should be moved up the settlement hierarchy accordingly.

A Local Plan objective is "Making Places better" but it is unclear how this objective will be achieved in rural communities with no housing and employment growth allowed. It is not adequate to ignore the needs of these communities by cutting them off and stunting their growth. South Cambridgeshire District is a rural authority, and a large proportion of the current population resides in rural areas. This population is anticipated to grow significantly in the plan period by 27.4% .

This population growth and investment cannot all be directed to new settlements at the cost of the existing villages. Investment should also be directed towards improving public transport for rural communities to improve their sustainability and access to a range of services and through delivering appropriate levels of employment growth at the most sustainable rural villages such as Melbourn, which sits on a primary route network and has the best public transport links of any village of its size in the district. This would reduce car dependency, support the adoption of sustainable modes of transport and reduce commuting in to Cambridge, by providing high-quality job opportunities closer to where people live.

OBJECT

Mr Meadows is promoting land r/o 113 Cottenham Road in Histon for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Histon and the decision to not release additional land from the Green Belt.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The promoted development by Mr Meadows off Cottenham Road in Histon is located within the Green Belt, and in these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

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 land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation and not just the Rural Southern Cluster as indicated in emerging GCLP. For example, Histon contains a business park and is very well related to employment opportunities within and on the edge of Cambridge, it contains a very good range of services and facilities and is accessible by sustainable modes of transport, and there is an identified need for affordable housing which is not being addressed through the made neighbourhood plan or by the emerging GCLP.

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.

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 if its close proximity to employment and the opportunity to travel by non-car modes of transport. Histon is well served by public transport and is well connected with existing cycle routes. Therefore, the release of suitable land from the Green Belt on the edge of Histon would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

As set out in representations to Section 2.6: Rest of Rural Area and the HELAA Site Assessments (for Site Ref. 40256), the land off Cottenham Road makes a limited contribution to openness and the purposes for including land within the Green Belt and should be released from the Green Belt in emerging GCLP.

The preferred development strategy for the rural area on the edge of Cambridge is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for Histon, which is a sustainable village.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Histon is defined as a Rural Centre in the settlement hierarchy. It contains supermarkets and other small convenience stores and shops, a post office, doctor’s surgery and pharmacy, dentist, library, public houses and restaurants, banks, primary and secondary schools, and village halls, and a business park and other small businesses. The promoted development off Cottenham Road would support the existing services and facilities within the village. There is a stop at Histon on the Cambridgeshire Guided Busway. Histon is connected to Cambridge and Ely by a frequent bus service. There are existing on and off-road cycle routes within Histon and to and from neighbouring areas. Therefore, there are numerous sustainable modes of transport available in Histon so that residents can choose not to use a car for most journeys for employment, education, and leisure purposes.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 58 affordable dwellings in Histon for those with a local connection to the village – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without additional allocations in Histon. It is noted that the made Histon and Impington Neighbourhood Plan makes no new housing allocations despite the housing affordability and affordable housing being identified a priority in the document. A Histon Community Land Trust has been set up but it currently at an early stage and no sites have been identified for a community housing scheme. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Mr Meadows would include housing and affordable housing to meet local needs of the village, and could provide a proportion of community land trust housing.

For all these reasons, small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including at Histon, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is an identified need for affordable housing in the villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including Histon, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

As requested in Mr Meadows’ representations to Section 2.6: Rest of Rural Area, the land at r/o 113 Cottenham Road in Histon should be released from the Green Belt and allocated in emerging GCLP for residential development.

1.1 The detail of the case for this representation is provided in the objection to the Settlement Boundary for Linton representation by Impact Planning Services Limited on behalf of our Clients Abbey Developments Limited.
1.2 The Policy S/DS has supporting text and under the heading: ‘Identifying how much new land for jobs and homes needs to be found’. The third paragraph which is on page 34 of the Plan states: ‘For homes, we already have almost 31,000 homes in our adopted Local Plans or with planning permission set to be delivered by 2041’.
1.3 Because our Client’s (Abbey Developments Ltd) sites at Bartlow Road, Linton are included in the Housing Trajectory and Five-Year Land Supply report published in April 2021 it is requested that the Greater Cambridge authorities confirm in writing that the 55 new homes on the above sites are included within the figure of 31,000. If this is incorrect then an explanation about these sites should be provided for further consideration and submissions.

1.1 The detail of the case for this representation is provided in the objection to the Settlement Boundary for Linton representation by Impact Planning Services Limited on behalf of our Clients Abbey Developments Limited.
1.2 The Policy S/DS on page 29 of the Local Plan requires an amendment and this objection is that without such an amendment the Policy is unsound. An addition to the text on page 31 is required to make the Plan sound.
1.3 The addition requested is an additional bullet point to be added in the second paragraph on this page which begins with: ‘We propose some development in the rural area south of Cambridge, the Rural Southern Cluster’…
1.4 The additional bullet is necessary to ensure that planning policy and in particular settlement boundaries are revised and kept up to date to include housing commitments with planning permission and windfall commitments.

OBJECT

Shelford Investments is promoting land off Cabbage Moor in Great Shelford for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster, and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Great Shelford and the decision to not release additional land from the Green Belt.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The promoted development by Shelford Investments off Cabbage Moor in Great Shelford is located within the Green Belt, and in these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

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 land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation, and it is proposed that other land in Great Shelford/Stapleford and within the Rural Southern Cluster is released from the Green Belt for these reasons. The land off Cabbage Moor and Great Shelford generally are very well related to Addenbrooke’s Hospital, Royal Papworth Hospital, Cambridge Biomedical Campus, and other employment opportunities within and on the edge of Cambridge. Great Shelford and neighbouring Trumpington contains a very good range of services and facilities and is accessible by sustainable modes of transport, and there is an identified need for affordable housing in Great Shelford would not be met by the emerging GCLP.

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.

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. The land off Cabbage Moor is well served by public transport (bus and rail) and is well connected with existing cycle routes, and there are future public transport improvements proposed in the surrounding area. Therefore, the release of the land off Cabbage Moor from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

As set out in representations to Section 2.5: Rural Southern Cluster and the HELAA Site Assessments (for Site Ref. 40529), the land off Cabbage Moor in Great Shelford makes a limited contribution to openness and the purposes for including land within the Green Belt, and does not contribute towards the wider landscape of Cambridge or Great Shelford, and should be released from the Green Belt in emerging GCLP.

There are three other paragraphs in the NPPF that suggest additional allocations should be made in Great Shelford and the Rural Southern Cluster. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Great Shelford contains a good range of services and facilities, reflecting its status as a Rural Centre. For example it contains a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants. There are additional services and facilities located in Trumpington. The promoted development by Shelford Investments would support the existing services and facilities. Great Shelford contains a railway station. The proposed Cambridge South Station would be located to the west of Cambridge Biomedical Campus. Shelford Road is on a bus and cycle route. Trumpington Park & Ride and the Cambridgeshire Guided Busway are within close proximity of the site. The Cambridge South East Transport project by the Greater Cambridge Partnership includes a stop at Great Shelford and at Cambridge Biomedical Campus. Therefore, the promoted development by Shelford Investments at land off Cabbage Moor is accessible by a range of sustainable modes of transport, and it would be consistent with national policy to direct additional development to this site.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 47 affordable dwellings in Great Shelford for those with a local connection to the village, and an identified need in Stapleford for 28 affordable dwellings – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. The identified need for Great Shelford would not be met without an additional allocation. It is noted that a Stapleford and Great Shelford Neighbourhood Plan Area was designated in 2016, and it appears that there has been some evidence gathering since then but a draft plan has not yet been published. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Great Shelford should seek to accommodate district-wide affordable housing needs and not just those local needs arising in the village and the immediate surrounding area. The promoted development by Shelford Investments would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages in the Rural Southern Cluster and on the edge of Cambridge including at Great Shelford, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is an identified need for affordable housing in the villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including Great Shelford, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

As requested in Shelford Investment’s representations to Section 2.5 Rural Southern Cluster, the land off Cabbage Moor in Great Shelford should be released from the Green Belt and allocated in emerging GCLP for residential development.

OBJECT

RO Group is promoting land south of Hall Lane in Great Chishill for a small infill residential development of approximately 21 dwellings including affordable housing, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

It is considered that current predicted delivery rates at the existing and planned new settlements are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is considered that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East taking into account the complexity or these developments and the need for existing uses to be relocated. It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, and in order to address that under-delivery it is considered that the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The preferred development strategy for the rest of the rural area is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for some villages, including Great Chishill where rural bus services are due to be improved. The preferred development strategy for the rest of the rural area also provides no support for existing services and facilities in villages and provides no strategy to meet current identified affordable housing needs of villages. RO Group are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at some villages to support services and ensure that identified affordable housing needs are met.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Great Chishill contains a public house, places of worship, a village hall, and sports and recreation grounds. It would be beneficial for additional development to support these services and facilities. There is a currently a limited bus service to Royston and Cambridge, but it noted that the Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service for Great Chishill in the future.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 9 affordable dwellings in Great Chishill and Little Chishill for those with a local connection to the villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without allocations in Great Chishill. It is noted that there is no neighbourhood plan being prepared for the village, no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by RO Group at land south of Hall Lane in Chishill would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Chishill, because there are planned improvements to the rural bus service, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

As requested in the RO Group representations to Section 6.2: Rest of Rural Area, the land south of Hall Lane in Great Chishill should be allocated in emerging GCLP for residential development.