S/DS: Development strategy

OBJECT

Mr Francis is promoting land off Ditton Lane in Fen Ditton 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 edge of Cambridge and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Fen Ditton.

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 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 Fen Ditton, which is a sustainable village.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for edge of Cambridge and 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.

Fen Ditton is designated as a Group Village and contains a range of services and facilities including a primary school, public houses, and restaurants. There are additional services and facilities and a wide range of employment opportunities available within Cambridge. Fen Ditton is accessible to Cambridge by walking, cycling and public transport, and is accessible to Cambridge North Station. In due course Fen Ditton will be accessible to the new services and facilities and employment opportunities to be provided at the new neighbourhoods at Cambridge East (Wing) and North East Cambridge. Therefore, additional development at Fen Ditton would be consistent with a development strategy to direct development to locations that are accessible by sustainable modes of transport where realistic alternatives to the car are available for most journeys. In addition, the site promoted off Ditton Lane for Mr Francis is not within the Green Belt.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 12 affordable dwellings in Fen Ditton 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 Fen Ditton. 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 Mr Francis at land off Ditton Lane in Fen Ditton 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 area on the edge of Cambridge including in Fen Ditton, 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 Fen Ditton, 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 Francis’ representations to Section 2.3: Edge of Cambridge, the land off Ditton Lane in Fen Ditton should be allocated in emerging GCLP for residential development.

OBJECT

Cambridge District Oddfellows is promoting land at Two Mill Field and land north of Oakington Road in Cottenham for residential development, and in representations has requested that these sites are 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 Cottenham, 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. Cambridge District Oddfellows 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.

Cottenham is designated as a Rural Centre; Cambridge District Oddfellows objects to the decision to reclassify Cottenham as a Minor Rural Centre in Policy S/SH: Settlement Hierarchy. Cottenham has a good range of services and facilities including a supermarket and convenience stores, post office, doctors surgeries, dentist, library, public houses, restaurant/takeaway, bank, primary schools and secondary school, village hall and meeting spaces. The promoted developments at land at Two Mill Field and at land north of Oakington Road would support the existing services and facilities in the village.

The promoted developments at land at Two Mill Field and at land north of Oakington Road would be accessible by walking, cycling and public transport to the services and facilities within the village. Cottenham is currently connected to Cambridge by frequent bus services. It is noted that the Greater Cambridge Partnership’s Making Connections project proposes substantial improvements to the bus services for Cottenham, including a bus every 10 minutes to Cambridge via Histon, a more frequent service to Oakington, and a more frequent rural service to Chatteris via Wilburton, Haddenham, Sutton and Mepal. These improvements to the bus service to and from Cottenham are not reflected in the decision to reclassify the village as a Minor Rural Centre or in the decision to not make any allocations in the village.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 52 affordable dwellings in Cottenham 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. It is acknowledged that the recent planning permissions for housing in Cottenham would meet most of the current identified affordable housing needs, although further affordable housing needs will arise during the plan period to 2041 and additional allocations should be made to meet those future needs. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Cottenham should seek to accommodate district-wide affordable housing needs and not just those from the village and the immediate surrounding area. The made Cottenham Neighbourhood Plan allocates three previously developed sites for housing, but it is noted that these sites fall below the site size threshold where affordable housing would be required, and as such no affordable housing would be delivered from these sites. There is a Cottenham Community Land Trust, but no schemes to deliver housing have been identified and the organisation appears to be having some difficulty in finding suitable sites. The promoted developments by Cambridge District Oddfellows at land at Two Mill Field and land north of Oakington Road in Cottenham could include a proportion of land for a community land trust scheme, in conjunction with a development for housing and affordable housing if the site is allocated in emerging GCLP.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Cottenham, 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 and community land trust housing in the village.

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 Cottenham, 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 and community land trust housing in those villages.

As requested in the Cambridge District Oddfellows representations to Section 2.6: Rest of Rural Area, the land at Two Mill Field and the land north of Oakington Road in Cottenham should be allocated in emerging GCLP for residential development.

OBJECT

It is proposed in Policy S/SH that Cottenham should be reclassified as Minor Rural Centre. The reason for this reclassification is because Cottenham does not have a high quality public transport in the form of a segregated transport route i.e. access to a Greater Cambridge Partnership scheme or the Cambridgeshire Guided Busway. Cambridge District Oddfellows object to the reclassification of Cottenham when the village has all of the other attributes of a Rural Centre, and the existing bus services are good and the Greater Cambridge Partnership is bringing forward a project to improve the services and connections.

Cottenham has a good range of services and facilities including a supermarket and convenience stores, post office, doctors surgeries, dentist, library, public houses, restaurant/takeaway, bank, primary school and secondary school, village hall and meeting spaces. Cottenham is currently connected to Cambridge by frequent bus services. The Cambridgeshire Guided Busway stop at Oakington is approximately 3.5km from the centre of Cottenham. The Greater Cambridge Partnership’s Making Connections project proposes substantial improvements to the bus services for Cottenham, including a bus every 10 minutes to Cambridge via Histon, a more frequent service to Oakington (including the Cambridgeshire Guided Busway stop), and a more frequent rural service to Chatteris via Wilburton, Haddenham, Sutton and Mepal. It is acknowledged that the public transport routes from Cottenham are not segregated, but the current bus service is good and the Greater Cambridge Partnership’s Making Connections project will improve the quality of the bus services from the village including connections to the Cambridge Guided Busway at Oakington. The Making Connections project has not been taken into account in the decision to reclassify Cottenham in the settlement hierarchy. The frequency of the bus services from Cottenham to Cambridge would be equivalent to those on a segregated bus route. For all these reasons, Cottenham should remain as a Rural Centre.

Requested Change

It is requested that the status of Cottenham in the settlement hierarchy is not altered, and it remains as a Rural Centre.

OBJECT

KG Moss Will Trust is promoting land off Home End and the Moss Family is promoting land at Court Meadow House off Balsham Road, both sites are in Fulbourn. In representations it is requested that the sites are allocated for residential development 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 Fulbourn 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 developments by KG Moss Will Trust/Moss Family in Fulbourn are located within the Green Belt, and in these representations it is requested that the sites are 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, Fulbourn is very well related to the employment opportunities within and on the edge of Cambridge including Peterhouse Technology Park and Capital Park, 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 emerging 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 of its close proximity to employment and the opportunity to travel by non-car modes of transport. Fulbourn is well served by public transport and is well connected with existing cycle routes, and there are plans to improve the walking and cycling connections to Cambridge. Therefore, the release of suitable land from the Green Belt on the edge of Fulbourn 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 Refs. 40522 and 40523), the land off Home End and the land off Balsham Road (as amended) in Fulbourn 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 Fulbourn, 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.

Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. It contains a good range of services and facilities, including a primary school, doctor’s surgery, pharmacy, library, post office, supermarket and other small convenience stores, village hall, and outdoor recreation and play facilities. The promoted developments by KG Moss Will Trust/Moss Family in Fulbourn would support the existing services and facilities within the village. There are regular bus services to Cambridge, Haverhill, and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The Greater Cambridge Partnership has proposed a greenway (walking and cycling route) between Fulbourn and Cambridge. The Greater Cambridge Partnership’s Making Connections project seeks to improve the frequency of bus services from Fulbourn, including to Cambridge, Cambridge Station, Cambridge Biomedical Campus, and the proposed Cambridge South Station. Therefore, there are numerous options for residents of Fulbourn to travel by sustainable modes of transport for most journeys to access employment, education, and leisure.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 65 affordable dwellings in Fulbourn for those with a local connection to the village, and affordable housing needs in the neighbouring villages of Teversham (21 dwellings) and Great Wilbraham/Little Wilbraham (6 dwellings) – 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 Fulbourn. It is noted that the emerging Fulbourn Neighbourhood Plan makes no new housing allocations despite the need for affordable housing being identified as an issue for the local community. There is no community land trust in Fulbourn. 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 developments by KG Moss Will Trust/Moss Family in Fulbourn 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 area on the edge of Cambridge including at Fulbourn, 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 only partially be met by other developments.

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 Fulbourn, 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 KG Moss Will Trust/Moss Family’s representations to Section 2.6: Rest of Rural Area, the land off Home End and the land at Court Meadows House off Balsham Road (as amended) in Fulbourn should be released from the Green Belt and allocated in emerging GCLP for residential development.

Given that the Greater Cambridge area includes vastly different spatial characteristics ranging from dense urban landscapes to rural village locations, Policy S/JH should ensure that housing is provided across the settlement hierarchies; so in larger settlements as well as smaller rural communities to ensure that the policy meets the objectives of supporting and promoting the provision of balanced and mixed communities. The current strategic approach to accommodating development is not considered to be in accordance with the principles outlined in the National Planning Policy Framework.
Concern is raised that insufficient land is being allocated to the rural area overall and too much emphasis is being placed on Cambridge City and new settlements and this focus could lead to problems associated with infrastructure and housing delivery.
Whilst it is recognised that the use of brownfield land is encouraged and this accords with the provisions of the Framework, this should not be at the expense of ensuring that the right sites are allocated in the right places. Not all brownfield land will be appropriate to allocate for development, as sites can be blighted by contamination, have complex ownership issues that affect delivery or be too small or inadequately accessed. There will be a need for greenfield development as well as consideration of Green Belt release to ensure that the demanding housing requirements for the LPA are met. Greenfield sites also offer the opportunity for good levels of affordable housing to be provided that often causes a viability issue in the development of brownfield sites. Furthermore, it is considered that a higher quantum of homes are allocated within the plan period. The current scale of growth is considered inadequate particularly within the rural area, the development strategy proposed is not effective and could threaten the long-term viability of villages.
The following sites have been promoted through previous iterations of the plan and through the Call for Sites process and should be allocated for development:
Land at Bannold Road Waterbeach (ref 40466)
Land off Kingfisher Way, Cottenham (ref 40472)
Land to the north of Cottenham (new site)
Land at Boxworth End Swavesey (ref 40506)
Land at Priest Lane, Willingham (ref 40468)

Given that the Greater Cambridge area includes vastly different spatial characteristics ranging from dense urban landscapes to rural village locations, Policy S/JH should ensure that housing is provided across the settlement hierarchies; so in larger settlements as well as smaller rural communities to ensure that the policy meets the objectives of supporting and promoting the provision of balanced and mixed communities. The current strategic approach to accommodating development is not considered to be in accordance with the principles outline in the National Planning policy Framework.
Concern is raised that insufficient land is being allocated to the rural area overall and too much emphasis is being placed on Cambridge City and new settlements and this focus could lead to problems associated with infrastructure and housing delivery.
Whilst it is recognised that the use of brownfield land is encouraged and this accords with the provisions of the Framework, this should not be at the expense of ensuring that the right sites are allocated in the right places. Not all brownfield land will be appropriate to allocate for development, as sites can be blighted by contamination, have complex ownership issues that affect delivery or be too small or inadequately accessed. There will be a need for greenfield development as well as consideration of Green Belt release to ensure that the demanding housing requirements for the LPA are met. Greenfield sites also offer the opportunity for good levels of affordable housing to be provided that often causes a viability issue in the development of brownfield sites. Furthermore, it is considered that a higher quantum of homes are allocated within the plan period. The current scale of growth is considered inadequate particularly within the rural area, the development strategy proposed is not effective and could threaten the long-term viability of villages.
The following sites have been promoted in earlier iterations of the plan and through the Call For Sites process and should be allocated for development:
Land at Dry Drayton Road, Oakington (ref 51617)
Land at Fen End Willingham (ref 40469)

These representations to Policy S/DS are focussed on the preferred development strategy for the rural area, and specifically the decision to allocate a very limited amount of development within/adjacent to villages.

The development strategy presented within the GCLP is reliant on the delivery of extensions to Cambourne (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 and the additional dwellings at Cambourne are proposed through the emerging GCLP and are associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy. These risks relate to housing delivery rates, whether delivery rates can be accelerated/increased at some of the new settlements as is proposed, 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 annual housing delivery rates for the new settlements. Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourne Airfield are predicted to deliver a combined total of 300 dwellings per annum.

By way of a comparison, 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 one of the highest annual delivery rates of current new settlements across the country is delivering at 295 dwellings per annum.

In the cases of Cambourne, Hampton and Cranbrook, these new settlements all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. Many new settlements are however unable to achieve annual levels of growth of 250 dwellings+ per annum with the number of new homes able to be delivered affected by many factors such as the number and geographical location of competing new settlement sites.

The Inspector for the Huntingdonshire Local Plan carefully considered the matter of delivery rates and the new settlement locations proposed within the neighbouring authority area of Huntingdonshire and recommended that the combined housing delivery rates for Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum. For St Neots East (Loves Farm and Wintringham Park) it was concluded that the combined housing delivery rates should be no higher than 200 dwellings per annum.

The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield are therefore already very ambitious and are at a level comparable to those new settlements whose annual delivery rates are amongst the highest in the country. The current predicted delivery rates are considered to be very optimistic and carry risk given they form such a significant part of the planned housing trajectory. With this in mind, there does not appear to be any credible evidence to support increasing these already ambitious housing delivery rates at Northstowe or Waterbeach to help further boost assumed delivery rates within the GCLP.

It is requested that the predicted housing delivery rates for the new settlements be reviewed in the context of 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 Adopted 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. The delivery of 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.

As well as the above concerns about the overall delivery of new homes, it is also 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 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 on the edge of Cambridge are unlikely to provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. In order to address any 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. Very few allocations in villages are however included in the GCLP

The preferred development strategy for the rest of the rural area is based on the assumption that the villages 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, particularly for those villages which contain a good range of services and facilities.

In addition, the preferred development strategy which limits growth in the rest of the rural area provides no support for existing services and facilities in villages and provides no strategy to meet the current identified affordable housing needs of the villages.

While MPM Properties (TH) Ltd and Thriplow Farms Ltd are not advocating a dispersed development strategy, a sufficient quantum of land does need to be allocated in the right locations at the more sustainable villages to support services and ensure that the identified affordable housing needs of local communities are met.

There are three paragraphs in the NPPF that support more growth being directed towards 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.

MPM Properties (TH) Ltd and Thriplow Farms Ltd are promoting the site known locally as the Grain Store Site that is located off Lodge Road in Thriplow. The Grain Store Site is land has been previously promoted by a different promoter through the call for sites process (site reference 47379). At the time of the call for the sites submission, the previous promoter identified the indicative capacity of the site as being up to 36 dwellings. The site area has since been reduced with the commercial building known as Revivals, located within the south east corner, being removed from the proposed development area, it being a local employment site.

Given the concerns expressed above about the development strategy for the emerging GCLP, it is considered that sites such as the Grain Store site in Thriplow are suitable and available for allocation within the GCLP. Such locations that enjoy good access to local facilities, can help support local services in the future, help address local housing need and deliver sustainable growth should be assessed for future allocation within the GCLP. The delivery of housing in such locations would not only support the delivery of new homes across the Greater Cambridge area, reducing the pressure/reliance on the small number of larger sites identified, but would also address local housing need.

On the subject of housing need, the draft Thriplow Neighbourhood Plan notes in paragraph 2.30 that a housing needs survey undertaken in 2018 identified 22 households in need of affordable housing with a local connection to Thriplow parish. The positive allocation of suitable and available sites to help address this housing need would contribute towards the delivery of sustainable growth.

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 annual delivery rates 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 where sustainable growth can be delivered

As requested in MPM Properties (TH) Ltd and Thriplow Farms Ltd’s representations to Section 6.2: Rest of Rural Area, the Grain store site as Lodge Road Thriplow should be allocated in the emerging GCLP for residential development.

SUPPORT

Mrs Johnson owns land included within the preferred allocation at land between Hinton Way and Mingle Lane in Great Shelford (Site Ref. S/RSC/HW), and the decision to identify the site as a preferred allocation for 100 dwellings is supported. In summary, the Rural Southern Cluster is an appropriate location for additional development because of the close proximity to employment opportunities and the good accessibility by sustainable modes of transport. There are exceptional circumstances to justify the release of 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 decision to release the land between Hinton Way and Mingle Lane from the Green Belt is consistent with national policy. There is a current identified need for affordable housing in Great Shelford and Stapleford, and no other realistic options have been identified to meet that current need within the villages other than through the release of land from the Green Belt through emerging GCLP. The assessment of the land between Hinton Way and Mingle Lane in the (Housing and Economic Land Availability Assessment (HELAA) identify some constraints to the promoted development at the site, but suitable and deliverable mitigation measures have been identified to address those constraints. The land between Hinton Way and Mingle Lane in Great Shelford scores well in the Sustainability Appraisal when assessed against the identified sustainability objectives and when compared against alternative site options.

The land between Hinton Way and Mingle Lane is currently located within the Green Belt, and it is proposed in the GCLP Preferred Options that the site should be released from the Green Belt and allocated for residential development. Chapter 13 of the NPPF sets out national policy for Green Belts.

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. Stapleford and Great Shelford 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. Stapleford and Great Shelford contain a very good range of services and facilities and are accessible by sustainable modes of transport. There is an identified need for affordable housing in Stapleford and Great Shelford, and no other realistic options have been identified to meet that current need within the villages other than through the release of land from the Green Belt through 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 preferred allocation at land off Hinton Way and Mingle Lane in Great Shelford 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 local area. Therefore, the release of the land off Hinton Way and Mingle Lane 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.

There are three other paragraphs in the NPPF that support the decision to identify land off Hinton Way and Mingle Lane as a preferred allocation in emerging GCLP. 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. 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.

Stapleford and Great Shelford contain a good range of services and facilities, reflecting their status as a Rural Centre in the settlement hierarchy. For example, they contain a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants. The preferred allocation at land off Hinton Way and Mingle Lane would support the existing services and facilities in Stapleford and Great Shelford. Shelford Station is located close to the site. There are bus routes on Hinton Way, Mingle Lane, Station Road and Cambridge Road, all of which are close to the site. There are cycle routes through Stapleford and Great Shelford into Cambridge. The route for the proposed Cambridge South East Transport project by the Greater Cambridge Partnership is located to the north west of the site, and there is a proposed stop at Hinton Way that would be within close proximity of the site. Therefore, the land off Hinton Way and Mingle Lane 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 28 affordable dwellings in Stapleford and 47 affordable dwellings in Great Shelford 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. It is not clear how the affordable housing needs of these villages would be met, other than through the allocation of a suitable site in emerging GCLP that is capable of delivering policy compliant levels of affordable housing. It is noted that in 2016 a Stapleford and Great Shelford Neighbourhood Plan Area was designated, but limited progress has been made since to produce a draft plan that might address identified affordable housing needs through site allocations. In any event, as Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Stapleford and Great Shelford should seek to accommodate district-wide affordable housing needs and not just those local needs arising in the villages. The preferred allocation at land off Hinton Way and Mingle Lane would include housing and affordable housing to meet local needs of the villages. The promoted development would be subject to a policy requirement to provide 40% affordable housing on site, and it is normal for planning permissions for major residential developments in South Cambridgeshire to include a planning obligation requiring a proportion of the affordable dwellings to be offered to those with a local connection to the village.

For all these reasons, it is entirely appropriate and consistent with national policy for the development strategy in Policy S/DS to release land from the Green Belt in the Rural Southern Cluster at Stapleford/Great Shelford, and to identify land off Hinton Way and Mingle Lane as a preferred allocation for residential development.

In addition, it should be noted that the key parts of the development strategy for emerging GCLP is the delivery of extensions to Cambourne, the planned new settlements at Northstowe, Waterbeach and Bourn Airfield, and the new communities on the edge of Cambridge at North East Cambridge and Cambridge East. These are all complex developments that also require the delivery of transport and community infrastructure. The predicted housing delivery rates at these developments are challenging. Most of these developments will provide less affordable housing than required by policy, at least in the initial phases, to reflect the amount of infrastructure that is needed. The proposed redevelopments at North East Cambridge and Cambridge East are complex and involves the relocation of the existing uses. Therefore, it is considered that the development strategy for emerging GCLP should also include small and medium allocations, such as land off Hinton Way and Mingle Lane in Great Shelford, that can be delivered easily and maintain a housing land supply and meet affordable housing needs.

No changes are required to Policy S/DS.

The proposed development strategy, in line with the Plan’s vision and aims, is to direct development to where it will have the least climate impact.
Alongside this, there is an aim to ensure that development is directed to areas where active and public transport is a “natural choice” and where new green infrastructure can be delivered alongside new development and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way. This proposed policy direction is supported and we consider that the sites we have previously submitted to the Council (land east of Cambridge Road, Sawston Ref: 531, and land east of Haverhill Road, Stapleford Ref: 530) are both capable of accommodating housing developments which would accord with the aims of Policy S/DS.
In terms of the rural area south of Cambridge, which Stapleford (with Shelford) and Sawston are a part, it is proposed that “some” development will occur within the area, where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links.
The proposed policy direction proposes that there will be “new smaller sites for housing and employment in villages that have very good public transport access and are close to jobs, some of which are through the release of land from the Green Belt”. In addition to this, allocations will be continued for existing sites allocated in previous plans.
We support the allocation of sites in villages with very good public transport access. This is particularly the case for Sawston and Stapleford. However, we consider the policy should also reflect on the merits of planned public transport provision also, as this further strengthens the sustainability of villages.
In the case of Stapleford and Sawston, both villages are proposed to be linked by Phase 2 of the Cambridge South East Transport project (which will run from Cambridge Biomedical Campus to a new travel hub near the A11, close to both Babraham Research Campus and Granta Park). This route will connect the villages with three existing strategic employment areas which are highly likely to continue growing and providing jobs throughout the plan period. We therefore believe the connections the Transport Project will provide to these villages, further emphasises why they should be considered appropriate locations of housing growth.

Huntingdonshire District Council support Greater Cambridge’s intention to continue development at existing strategic sites as allocated in previous plans, for example Darwin Green, North West Cambridge, Northstowe, Waterbeach, Cambourne, Bourn and The Genome Campus. These strategic developments will deliver housing and employment over an extended time period providing long-term certainty of delivery. The addition of a 10% buffer also provides security in the event of stalled or slowed delivery as a result of unexpected market fluctuations.

National planning policy says at least 10% of an Authority’s housing requirement should be accommodated on sites no larger than 1 hectare, unless it can be shown that there are strong reasons why this cannot be achieved. Greater Cambridge notes that “The site commitments we have and new proposals suggested in this consultation, together with windfall sites expected to come forward would mean we exceed this requirement by some margin.” Huntingdonshire District Council supports this statement as long as delivery on development sites for the plan period can be achieved.


There appears to be some uncertainty regarding the delivery of the strategy set out in the First Proposals Document. Two key examples included in the document are identified on:
• page 44, where it is stated that the proposed strategy is “heavily informed by the location of existing and committed public transport schemes. For example, locating growth at Cambourne takes advantage of the proposed East West Rail station and Cambourne to Cambridge Public Transport Scheme; equally, North East Cambridge is made more sustainable by the presence of Cambridge North Station, the proposed Waterbeach to Cambridge North Public Transport Scheme, and Waterbeach Greenway. Beyond this, we have undertaken transport modelling to understand whether additional infrastructure and policies, beyond these proposals, would be required to address the transport impacts of the preferred development strategy. Transport infrastructure and policy requirements associated with specific proposed allocations are set out in each allocation policy within this chapter.”;
• Page 42 which notes that “The Councils have been, and continue to, engage with the relevant bodies responsible for water supply planning, including Water Resources East, the Water Companies and the Environment Agency to ensure they understand the significance of the issue. We are taking every opportunity to raise this at the most senior level with all key parties, including government through its focus on the Oxford-Cambridge Spatial Framework, that will also have to address this issue. If it is concluded that it is not possible to demonstrate an adequate supply of water without unacceptable environmental harm to support development ahead of strategic water infrastructure being in place, there may be a need for the plan to include policies to phase delivery of development; and
• Relocation of Marshall Airport to fully deliver Cambridge East (Policy S/CE)

Taking these key delivery issues into consideration it is suggested that a stepped trajectory and phased delivery of development would be the best approach to delivering the strategy for Greater Cambridge and the surrounding areas. This is especially so in relation to the issue regarding water supply, this is not solely a Greater Cambridge issue and will be likely to affect all surrounding districts to varying degrees, therefore it would be difficult to justify that level or speed of delivery in or around the Greater Cambridge area, if the issue is not resolved.

Additionally, any unresolved issues regarding the transport impacts of the preferred development strategy, would also provide similar issues in neighbouring authorities.

Huntingdonshire District Council supports Greater Cambridge’s focus on employment uses such as Life Sciences (including healthcare, biotechnology and biomedical activities) associated research and development laboratory space and life science related advanced manufacturing.

We disagree with the current amount and distribution of development within the Development Strategy, we believe it does not allow for enough growth and is disproportionate. More growth should be considered and other sustainable corridors such as the South West railway corridor and this should be reviewed in much the same way as the Rural Southern Cluster approach. The area between Melbourn and Cambridge not only benefits from the railway but also is an area which will also take advantage of the GCP Melbourn Greenway project which will help Active Travel choices between settlements and to the nearby railway stations. The amount of development which has been considered appropriate in this location seems inconsistent with the vision and aims set out for the area.
The Development Strategy also does not accord with the NPPF paragraph 69 a) which requests that all Local Plans have at least 10% of their overall housing target ‘identified’ on sites of less than 1 ha. We understand that the First Proposals document states that existing commitments and windfall developments within the area already result in this figure being achieved, but the NPPF is clear that these sites should be ‘identified’ within the Local Plan. This appears not to have been demonstrated within this document and within the Strategy Topic Paper. Within this evidence base document, the figure quoted at page 45 has included windfall sites as well as sites with planning permission which were not identified as allocations. We believe there are sites included within this figure where planning permission was achieved through a lack of 5-year housing supply at the time and not through allocation in previous plans. We believe Greater Cambridge should identify at least 4,440 homes on allocated smaller sites of less than 1ha and, as a result, more smaller sites need to be identified through this plan making process. We would like to see a further breakdown of the smaller sites and an indication as to whether these are, in fact, identified as allocations in previous plans.
Further Clarification Needed:
The table of proposed housing allocations on page 32 of the First Proposals paper seems unclear as to which sites are proposed allocations and what are existing commitments. For example Cambourne is included within this table but within the commentary for this policy (S/CB) it would appear that these 1,950 homes already have planning permission within the West Cambourne proposal and surely this is therefore an existing commitment?
The proposed allocations within the Rural Southern Cluster are not clear as Duxford (S/RSC MF) and Great Shelford (S/RSC site HW) are included in the table at page 32 but Comfort Café (S/RSC/CC) is excluded. More clarification is required on what actual new allocations are proposed.

These representations are submitted by Pegasus Group on behalf of Clarendon Land and Development Ltd who has land interests in land west of Long Lane, Fowlmere (LPA ref: 40327). We have previously submitted responses to the Call for Sites exercise (March 2019) and Regulation 18 Consultation (February 2020). These representations should be read in conjunction with these previous comments.

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 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 modest development to meet their needs will ensure that these villages will never grow, prosper or adapt to changing needs and they will stagnate.

The Plan acknowledges that affordability is a key concern in Great Cambridge and the area contains some of the least affordable areas in the country outside of London. It is likely that this pattern will continue to increase in villages if new development is not allowed and therefore people with connections to the area may not be able to afford to buy homes in villages and the choice of suitable accommodation will be limited. The provision of new housing has the ability to provide opportunities to create a more balanced local population by providing opportunities for young people to stay in the community they grew up in or for older people seeking to move within the community. This lack of housing and choice will have serious implications on the social-economic make-up of the villages.

A Local Plan objective is "Making Places better" but it is unclear how this objective will be achieved in rural communities with no housing growth allowed and no strategy included to improve the sustainability of these locations by improving public transport, facilities or services which will assist in the viability and vitality of these locations. 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% as set out table 9 in Housing & Employment Relationships (G L Hearn Nov 2020). 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. Rural communities should be embraced rather than forcing all future needs to be met in an urban environment.

Sustainability

The Local Plan does not acknowledge the changing patterns to sustainable living and the basis of the Development Strategy is on an old-fashioned definition of sustainability whereby people need to travel to work, leisure or essential facilities from their home in a private car. The COVID-19 pandemic has acted as a catalyst to changing patterns of how people live and work. Increased working from home has resulted in differing commuter patterns and less reliance on car-borne journeys. Where car journeys are required, people have become more carbon conscious and more are choosing electric modes of transport (e-bikes, electric cars). With the increase in superfast broadband to these rural communities, a variety of options are available for ecommerce, online shopping, virtual GP appointments, prescription deliveries, supermarket essential shopping deliveries. These varied digital and e-commerce opportunities ensure that individuals no longer need to be within walking or cycling distance of these services and facilities to access them and the reliance on a private car will be reduced further. There is no assessment of these changing living/working/shopping patterns in the Local Plan and the consignment of these rural villages to a no-growth option is based on old-fashioned views on car ownership and use with no acknowledgement of these changing digital opportunities and how they can significantly improve sustainable rural living.

The National Planning Policy Framework ('Framework' 2021) sets out in paragraphs 78-79 that housing should be located where it will enhance or maintain the vitality of rural communities. Policy S/DS will not meet this objective of the Framework and the policy will significantly impact the vitality of these communities. Additional development in villages will help to sustain the available services by maintaining population numbers. New residential schemes will propose additional households, all of which can use the local services, facilities, clubs and societies within the village resulting in greater levels of patronage and custom. This will support the ongoing provision, vitality and viability of these services.

The Framework acknowledges that sustainable transport solutions will vary between rural and urban areas and this should be taken into account in both plan making and decision making. The Local Plan has declared that these communities are not sustainable and are therefore not suitable for any development (regardless of any existing need or to address catastrophic affordable issues) and has not offered a solution as to how to deal with this to improve this situation or to acknowledge the changing patterns of working/living and how this may result in allowing these communities to grow sustainably. The Sustainability Appraisal (SA) for the Local Plan does not adequately account for this change in sustainable characteristics as set out in our detailed comments on the SA.

Over-reliance on large sites

A further flaw in the Development Strategy is the over reliance on large complex schemes to meet the housing needs of the District which will impact on immediate housing delivery. South Cambridgeshire has previously relied on strategic sites for housing delivery; challenges and subsequent delays that have arisen with such schemes have resulted in a housing shortfall. This is evident from the numerous planning appeals which have been allowed in South Cambridgeshire Group Villages over recent years which have proven that development in these locations has been deemed sustainable and suitable to meet the needs of the District. It is evident therefore that the allocation of smaller sites within the Local Plan, such as those within Group Villages will ensure a more robust and flexible delivery strategy for the District in the short term. The NPPF requires local planning authorities to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to meet their objectively assessed housing need. Paragraphs 60 and 68 of the Framework make specific reference to the need for a mix and variety of land to be identified for housing. Paragraph 69 specifically sets out that development plans should identify land to accommodate at least 10% of their housing requirement on sites no larger than 1 hectare.

The First Proposals document sets out that 96.5% of new dwelling allocations are proposed at sites which have a capacity of 750 dwellings or more. New Settlements are proposed to provide 38% of the total housing growth over the plan period (existing and new allocations), this is a 15% rise on the current adopted Plans and a 20% rise on the old Structure Plan.

The Development Strategy Topic Paper provides the current Housing Trajectory as of April 2021. The existing Northstowe new settlement allocation delivers new housing at a range of 204-365 dwellings per annum between 2020/21 and 2025/26, before dropping to 250 dwellings per annum for the rest of the plan period. The existing Waterbeach new settlement allocation is scheduled to commence housing delivery in 2022/23 at 80 dwellings per annum before rising to 250 dwelling per annum for the rest of the plan period. The GCLP carries forward these existing new settlement allocations and seeks to increase housing delivery at both sites by an additional 50 dwellings per annum from 2026/27 all the way through to 2040/41. Accordingly, both new settlements will be required to deliver dwellings at 300 dwelling per annum for a 15-year period. This increased delivery accounts for 13% of new housing growth proposed to be allocated by the GCLP (1,500/11,596).

The four proposed new allocations in Cambridge urban area and the edge of Cambridge account for 67% (7,762/11,596 dwellings) of the new allocated growth through the GCLP.

It is acknowledged that the allocation of new settlements and large-scale strategic sites can form a key part of a balanced spatial strategy to bring forward sustainable growth in a district. However, the approach put forward by the Councils does not represent a flexible and balanced approach capable of responding to changing circumstances (Framework paragraph 33) or providing a mix and variety of sites. The 10% target set out in paragraph 69 of the Framework is not met.

Furthermore, the per annum housing delivery targets for the new settlements are very high, particularly at Waterbeach which is yet to deliver dwellings. Bringing forward new settlements and large strategic sites is a complex process which often requires the delivery of significant up-front infrastructure which can sometimes be subject to different funding mechanism and complex land ownership constraints. These issues often impact and delay the delivery of strategic sites, accordingly, the GCLP needs to allocate a variety of different types of sites. The delays in delivery of new settlements in the Greater Cambridge area, along with the necessary strategic infrastructure are well documented and there continues to be a significant lag in the delivery of new homes required at these locations. There is nothing within the proposed plan that provides comfort that these issues will be satisfactorily resolved.

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 more balanced development strategy will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP should take the lead by positively planning for new housing at established sustainable rural settlements 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.

Site Selection

It is also questionable as to how the small number of allocations which have been identified in Group Villages have been chosen in comparison with the sites which have been put forward during the Call for Sites exercise. The only proposed allocations in group villages are:
• Hunts Road, Duxford (S/RSC/MF) – 60 homes
• Land at Highfields, Caldecote (S/RRA/H) – 64 homes
• Station Road, Oakington (S/RRA/MF) – 20 homes

There is no assessment as to why these three sites have been chosen over the other available sites in group villages. Only Oakington group village is highlighted as having good sustainable links in Topic Paper 1: Strategy. Duxford and Highfields, Caldecote are identified as group villages with the same sustainability characteristics as Fowlmere, where any development has been deemed as unsustainable. It is not understood as to the rationale used to differentiate the settlements or development proposals. All of the proposed three allocations were also ranked as amber in the HELAA same as a number of sites in Fowlmere including our site at Long Lane, therefore it is unclear as to how they were selected for allocation over and above other amber-ranked sites.

The Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) (2021) listed a number of acceptable sites in Fowlmere which had been submitted as part of the Call for Sites exercise (5 were ranked amber and 9 were ranked red). There were no sites which were ranked green due to the preconceived judgement that the settlement (or any group village) is not a sustainable location. However, some amber-ranked sites have been selected for allocation (Oakington, Duxford and Caldecote). The accessibility to services and facilities criteria is heavily skewed to traditional access to facilities and services with no understanding or acknowledgement of digital ecommerce or changing patterns of living and working as set out above.

The site suitability appraisal for land off Long Lane, Fowlmere in the HELAA (LPA ref: 40327) has a number of positive factors including its relationship with existing development and that is available and achievable for development within the first 5 years of the plan period. It is considered that these are significant benefits which have not been adequately accounted for or taken into consideration.

The other comments in the HELAA appraisal for the Long Lane, Fowlmere site are summarised below:
• Not located with a flood risk area (green);
• Landscape impact can be mitigated by boundary planting, buffer planting on north and west boundaries, form
of development to reflect existing settlement and to have rural approach (amber);
• Any biodiversity/geodiversity impact can be mitigated or compensated (amber);
• Not an open space designation (green);
• 100m outside the Conservation Area (Green)
• Potential for archaeology as located on edge of historic village but can reasonably be mitigated (Amber);
• Site access constraints can be overcome (Amber)
• Any impact on functioning of trunk roads can be mitigated (Amber);
• The site is capable of being developed to provide healthy internal and external environments in relation to
noise/vibration/odour and light pollution (amber);
• Site is not located within an Air Quality Mitigation Area (AQMA) (green);
• There is potential for historic contamination which will require conditions (Amber)

It is considered that the technical aspects of developing this site are positive and any potential issues can be mitigated for. The site is well related to the settlement and is considered to be a logical extension to the built-up development. This site represents a good opportunity for modest residential development which is immediately available with limited environmental impact. It is deemed unreasonable to discount or rank a site amber due to the need for additional technical documents to further investigate issues such as contamination or archaeology which would be a requirement for all sites.

In Greater Cambridge, housing is less affordable than the national average and is getting worse. As such, it is imperative that housing delivery is a priority for the Council in an attempt to ease the affordability pressures in the District. Development of this site will widen the choice of different housing types in Fowlmere itself.

The development of this site will give rise to economic and social benefits. New residents will use the existing local community services, facilities, clubs and societies within the village. This will support the ongoing provision, vitality and viability of these services. As part of the development proposals, financial contributions could be made, if required, towards these local facilities including education, health and public transport provision to enhance these facilities further; in line with paragraph 79 of the Framework and the intention of supporting local services through development in rural areas.

As such it is considered that modest development in the group villages, including Fowlmere, should be permitted to allow for immediate housing delivery, flexibility within the Plan and to allow these villages to meet their future housing needs whilst maintaining and enhancing their existing services.

OBJECT

Bloor Homes Eastern is promoting land east of Ridgeway and Old Pinewood Way, Papworth Everard 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 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 for 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 Papworth Everard, 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. Bloor Homes Eastern 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.

Papworth Everard is defined as a Minor Rural Centre in South Cambridgeshire District Council's current settlement hierarchy, and no amendment is proposed to this by the current consultation document. The settlement therefore sits towards the top of the Council’s settlement hierarchy. Papworth Everard contains an extensive range of services and facilities including a convenience store, hairdressers, fish and chip shop, coffee shop and a restaurant, a primary school, children’s nurseries, post office, library, doctor’s surgery/health centre, veterinary surgery, churches and village hall. Development has also commenced to deliver a bakery, microbrewery and Public
House on the former print works site, south of Church Lane. This demonstrates the site is very well connected to existing services and facilities within the village.

Papworth Hospital has previously been the main employer in the village although the facilities and functions of the hospital have now been relocated. The former hospital site is however positively promoted within the adopted plan for future employment generating uses. The First Proposals consultation document maintains this policy approach. Papworth Business Park, located at the southern edge of the village, is the main employment area. The services, facilities and employment opportunities which exist within Papworth Everard are all reflective of its designation as a Minor Rural Centre.

Where people do need to travel out of the village, there is access to an established bus service which provides connections from the village to Cambourne, St Neots, Cambridge, Huntingdon and St Ives. The main bus route is provided by the X3 bus. While this currently provides an hourly service, there are gaps in the timetable during the AM and PM peak hour. As a result, it is difficult for residents of Papworth to utilise this as a commuter service. It was therefore agreed with the operator during the consideration of the previous applications on the site that the development would deliver enhancements to the service to provide additional services in the AM and PM peak hours.

However, an enhanced bus network was discussed at the Greater Cambridge Partnership’s Executive Board committee meeting on 30 September 2021. The report pack associated with this meeting identifies Papworth Everard as being within the Northstowe to St Ives corridor and states that the proposals could include a new hourly service for Papworth Everard with potential implementation in 2023.

Cambridgeshire County Council are also currently delivering a cycle and pedestrian link from Papworth to Cambourne. This will provide a 2m wide cycle path along the eastern side of the A1198 to provide a link between the existing cycle path located north of the A1198/A428 junction, and the existing footpath network at the southern point of Papworth. The works are currently scheduled to be completed by February 2022. This will provide a direct cycle link to Cambourne, and all of the facilities provided within it.

East West Rail is a major infrastructure project which is proposed to connect Oxford and Cambridge.
Consultation took place from March to June 2021 on route alignment. All of the five routes proposed for the Bedford to Cambridge section of the route include a new station at Cambourne. Although the exact location of this is to be determined, this would provide significantly improved rail connections to the residents of Papworth Everard.

Upgrades are also proposed to the A428 between the Black Cat roundabout and Caxton Gibbet roundabout with a new 10-mile dual carriageway and a number of junction improvements. A Development Consent Order application was submitted on 26 February 2021. This entered the examination stage on 18 August 2021 and the draft examination timetable has now been published and it is currently anticipated that the examination will close in February 2022.

Papworth Everard and land to the east of the Ridgeway and Old Pinewood Way, Papworth Everard are sustainably located to accommodate much needed new housing development which will also ensure the existing facilities and services within the village are supported. The proposed development would also deliver a number of benefits including significant areas of public open space, green infrastructure and biodiversity enhancements. The protected trees within the site would be retained and significant new woodland planting would take place.

The proposals would also include for the benefits that were associated with the previous proposal for the site including: reserve land for a pre-school facility; contributions towards primary and secondary school provision; library contribution; contribution for improvements to Papworth Surgery; enhancements to off-site public footpaths; enhancements to bus services to deliver an additional service in the peak hour.

The Masterplan submitted with these representations also demonstrates how additional benefits could be delivered including a scout hut/community facility. The proposed development is landscape led, with significant areas of open space and planting. Bloor Homes Eastern are also committed to ensuring the suitability of the proposed development, not just in terms of its location, but also through the inclusion of EV charging points, air source heat pumps, PV panels and a car club with associated car club spaces throughout the proposed development.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 41 affordable dwellings in Papworth Everard. This identified need would not be met without allocations in Papworth Everard. 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 Bloor Homes Eastern at land east of Ridgeway and Old Pinewood Way, Papworth Everard would include market housing and affordable housing to meet local needs of the village. Given the age of the document referenced above it is also likely that affordable housing need in the village is now greater than that stated above.

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.

The proposed Development Strategy will create a very restrictive policy to the edge of village developments that would otherwise bring significant benefits to a local community.

The policy refers to “Small new sites for housing” at villages, with “very good public transport access”. This approach however limits the opportunity where a perfectly sustainable medium sized scheme of between 15 to 50 No. dwellings could be delivered to meet local need at a Group and higher tier Village.

More flexibility should be created within the Strategy to allow village development that would deliver private, affordable, and self-build dwellings, which would meet the local need and that is highlighted within an up-to-date Village Housing Needs Survey. This alternative approach would be more supportive than the current proposed Strategy in relation to meeting the objectives set out in Paragraph 60 of the NPPF 2021 and in particular the importance that a sufficient amount and variety of land should come forwarded where it is needed.

Through a restrictive approach on directing self-build housing to a proportion of major development schemes, this again prevents the delivery of this form of development to where it can be demonstrated there is a local need and would support the vitality of a village and its services and facilities. The current proposed Strategy lacks flexibility and strategic direction to support villages and their local needs.

Development on land east of Cambridge Road, Sawston (Ref: 531) would achieve new development in close to jobs, either accessible via the new transport route, or within the village (the site adjoins an existing commercial unit and is within a 20-minute walk of the South Cambridge Business Park).
The release of Green Belt land in Sawston is supported. Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. We consider that the need to deliver new homes in sustainable locations, close to public transport routes and employment opportunities comprises an appropriate justification for Green Belt release.

Given the need for high skilled jobs and the express high level of high skilled jobs provision within Cambridge, combined with the need to balance such employment opportunities more widely across the Greater Cambridge area, we suggest that a high priority and degree of support should be given to Research and Development related proposals. The following text is suggested to be included within Policy S/DS as a strategy proposal:

"Supporting proposals for Research and Development employment-related schemes, particularly within sustainable settlements across South Cambridgeshire District."

Please see attached letter.

We note that the proposed policy direction is to direct development to locations that have the least climate impact, where active and public transport is the natural choice, and where green infrastructure can be delivered alongside new development.

The department supports this approach, and would like to emphasise the importance of proactive planning of educational facilities when sites are actively being sought. The Local Plan provides an opportunity to plan strategically for education uses that maximise sustainable transport choices and create an employment pipeline for the Greater Cambridge area.

CMS is an approved specialist maths school for up to 200 16-19 year olds. The government has committed to having a maths school in every region, building upon the success of Exeter, King’s and the University of Liverpool Maths Schools, which have already opened in partnership with their local universities. The University of Cambridge, Isaac Physics and Cambridge Mathematics are strategic partners to CMS. Please see the attached letters of support from the University of Cambridge and Cambridgeshire County Council.

The department has secured a temporary site for CMS at 119 Mill Road, with the intention of opening at reduced capacity until a permanent site can be delivered. This should demonstrate our commitment to opening CMS, and we request that the councils work with us to deliver the permanent school building in the best available location and with minimal delay. The department makes use of permitted development rights where appropriate, but also wishes to explore options for strategic site allocations with the best public transport connectivity, as outlined in our response to the North East Cambridge Area Action Plan consultation. We believe it is in everyone’s best interests to deliver CMS in the most sustainable location.

If CMS is delivered as a freestanding new build, it will require a site of 0.5 acres (minimum 0.2 acres). Ideally there would be an area of external space but as a sixth form college CMS will not need sports provision/playing fields. If the school is delivered in an existing building, there is a space requirement of 2,450 square metres GIFA.

Cambridgeshire County Council as landowner has interests in land across the GCLP area and has promoted a number of sites for development within Cambridge, the edge of the city, and across the rural area.

Cambridgeshire County Council as landowner supports the focusing of development on Cambridge City and the city hinterland. 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 County Council is promoting a number of sites within Cambridge City: Hawthorn Community Centre (ref 40166) and Bellersby College (ref 40172), and the new submissions of the Cambridge Professional Development Centre and Horizon Resource Centre sites. These are all existing sustainably located brownfield sites which are either currently available or can be made available within the plan period.

Land at Chandos Farm adjacent to Babraham Park and Ride (ref 40141) is similarly an underutilised mixed-use site that could be more effectively developed as employment land.

Cambridgeshire County Council as landowner supports limited Greenbelt release in edge-of-city locations. The site at Newbury Farm, Worts Causeway (ref 40139) is situated between the Babraham Park and Ride to the east, an already committed housing development to the west, and a proposed expansion of the Biomedical Campus to the south. This site could be developed to provide new housing, including key worker housing, and green infrastructure to link with these existing and planned growth areas.

However, the overall development strategy set out in the emerging GCLP 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 are 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 predicts high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Camboure West and Bourne 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 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 many villages, which contain a good range of services and facilities and are 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. Cambridgeshire County Council as landowner is 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.

Cambridge County Council supports the allocation of Mansel Farm, Oakington (reference 40455). Oakington contains a good range of services and facilities, and the site is highly accessible to the Cambridge Guided Busway. This is reviewed further in representations to policy S/RRA/MF.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Sawston (ref 40146), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified 1,222 applicants on the housing register, including 88 in urgent need (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 further allocations in the larger villages of the Plan area. The sites promoted by the County Council 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, 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.

1 The GCLP Development Strategy Topic Paper (October 2021) outlines that a strategy "focused on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure." Consequently, villages are not the primary focus for growth within the development strategy.

2 The First Proposal identifies that 11,640 additional dwellings are needed to meet the housing need target within the plan period, after considering the committed housing supply. The proposed development strategy identifies four new sites in rural Greater Cambridgeshire to accommodate the additional housing need, which includes two sites in the "Group Villages” of Caldecote and Oakington. In total, the four sites can deliver 224 dwellings, which equates to only 1.9% of the new housing supply being met within rural areas. In contrast, 62% of the total supply is focused on the delivery of new settlements and strategic sites.

3 During the current plan period there has been significant scrutiny and pressure on the five-year housing land supply of the Greater Cambridge authorities. This is in part due to the current over reliance on new settlements and strategic sites to deliver housing numbers and the failure to allocate proportionate growth at sites on the edge of established rural settlements which have fewer delivery constraints. Delivering new settlements and large strategic sites often requires investment in significant up-front infrastructure. The funding and delivery of such infrastructure can significantly increase lead in times before dwellings are delivered and occupied. A Local Plan which establishes a balanced approach to the distribution and allocation of new housing sites will safeguard against the potential for shortfalls in five-year land supply upon the Plan’s adoption and during the plan period. Like the current adopted Local Plans, the GCLP will again deliver an imbalanced and ridged housing supply which exposes the Greater Cambridge authorities and their residents to considerable risk in terms of potentially facilitating the opportunity for speculative planning applications for housing development to come forward as and when there is a shortfall in supply. A more flexible and varied supply is required to boost sustainable rural communities and small and medium sized house builders; and to ensure a robust supply of housing is maintained in Greater Cambridge.

4 The Council’s development strategy approach for rural areas appears to be one which largely 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. To provide a more flexible and balanced housing supply, and to deliver the variety of sites the market demands the Councils should identify additional available and deliverable small and medium sized sites from a range of locations capable of accommodating housing growth within the plan period. The content of the Housing Economic Land Availability Assessment (HELAA) demonstrates that there are a number of suitable and available sites, located at sustainable settlements such as Group Villages, capable of being allocated for residential and mixed use development. This includes the Village of Foxton, which is a highly accessible location with its connectivity to the national rail network. Thereby the village is potentially more sustainable than some of the other rural area locations on the proposed Settlement Hierarchy.

In respect of providing new housing the proposed distribution of growth is too heavily focused on the delivery of New Settlement and Strategic Sites. Figure 10 of the First Proposals document indicates that only 18% of housing need in the plan period is directed to rural areas. This approach threatens the stagnation of rural communities in terms of their housing offer and may in time undermine the viability of the current service provision and the longer-term sustainability of the rural economy.

Allocating proportionate housing growth at established rural settlements through the GCLP or a future Local Plan document will assist in safeguarding the vitality and viability of existing rural services and can stimulate new businesses to come forward and support communities. Moving forward the GCLP should be amended to provide a balanced and more deliverable housing supply which can support established rural communities. This will ensure that rural communities thrive over the plan-period.

The development strategy of Densification is not supported. This strategy puts the Aims & Objectives of the Local Plan at risk. : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance here for both existing and growth populations here. As stated in the CPIER report (2018) if Cambridge does not remain an attractive place to live , the high levels of economic growth aspired to may fail.

A greater focus on bringing sustainable transport initiatives to the fore from outside the Greater Cambridge Area within the plan period, for example in addition to East West rail, improved rail links eg Newmarket /Ipswich line are recommended and good services to the Market Towns in the Region. The latter will assist both existing employees/commuters and new, reducing CO2 emissions (key aim of densification strategy) .  Increase in home working  will benefit local communities (levelling out) far from ‘dormitory towns’, with good transport networks for the odd commute day and more affordable housing, the wider region could benefit from Cambridge’s economic growth with working populations employed in Greater Cambridge but in the main remaining ‘local’.

The CPIER (2018) report which informed the Densification strategy advises young people will still wish to be in a centre where they can physically group together, this may be so for those in their first 5 years of work but, beyond this high density living, with restricted car use, a home working opportunities and affordable housing in the wider region means living in high density housing  is unlikely to remain attractive for those in stable relationships and seeking family accommodation.

The impact of large population increases in Greater Cambridge as a result of an unprecedented  amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase of existing homes in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further, in the case of North East Cambridge, with’ high densification housing at unprecedented levels for Cambridge’. The Aims of the Local Plan : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here. 

The housing development at North East Cambridge is not supported, a focus on employment growth in the area, services to support commuters and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region to bring employees in is recommended as an alternative.

Pursuing housing development at North East Cambridge as a result of the relocation site selected by Anglian Water in the Green Belt and within close proximity to Conservation Areas etc. is contrary to Policies: listed under ‘Bio-diversity & Green Spaces’; Great Places to Live’; Wellbeing & Inclusion.’ And is a high risk strategy. See comments under S/NEC.

The case has been made for an alternative Minimum or Medium Growth Option in section S/JH. If adopted it is recommended the additional homes (Min 3000; Medium 8,000) required in the Plan Period could be ·         accommodated by Cambridge Airport with forward planning and mixed development to assist build out rates (4000) and the Bio-Medical Campus (up to 4000) without the need for housing at North East Cambridge. In addition,  areas identified for Major change within the City boundary S/AMC may also bring opportunities for housing within  the plan period and beyond assisting with requirements of a 5 year land supply.  Cambridge airport with an allocation of 7000 to full build out will also be able to offer homes beyond the plan period. The Bio-Medical Campus has been identified for growth but has not had housing no’s. allocated ; housing development  could be achieved here within the plan period with a mixed development and forward planning(S/CBC).

The reference is 40297 (Land adjacent to Babraham, CB22 3AF, CB22 3AP, CB22 3AG, CB22 3AZ). The boundary has not changed. Please see document attached S/DS Comments (1of 4 submissions due to high level of documents).

The reference is 40297 (Land adjacent to Babraham, CB22 3AF, CB22 3AP, CB22 3AG, CB22 3AZ). The boundary has not changed. Please see document attached S/DS Comments (1of 4 submissions due to high level of documents).

The reference is 40297 (Land adjacent to Babraham, CB22 3AF, CB22 3AP, CB22 3AG, CB22 3AZ). The boundary has not changed. Please see document attached S/DS Comments (1of 4 submissions due to high level of documents).

The reference is 40297 (Land adjacent to Babraham, CB22 3AF, CB22 3AP, CB22 3AG, CB22 3AZ). The boundary has not changed. Please see document attached S/DS Comments (1of 4 submissions due to high level of documents).

Growth assumptions appears unimaginative, more of the same. At no point do you consider alternative growth rates that may be appropriate for future changes, or the hopes of current residents, orbthe existing housing deficit, with its associated high prices.
If the model of growth adopted in The Plan is used for the next 100 years, 40% growth becomes 440%. This is around 700,000 homes. You cannot just assume inexorable growth, like Stalinist planners. What about the external effect eg of Covid on growth?
It is not unreasonable to ask: “At what point might the current model be forced to change?”

OBJECT

Dudley Developments is promoting land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road, Cambridge 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 edge of Cambridge, and specifically the decision to not release additional land from the Green Belt at sustainable locations on the edge of Cambridge.

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 Dudley Developments at land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road in Cambridge 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 cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high too. The Housing Needs of Specific Groups Report (GL Hearn October 2021) provides further information on affordability and affordable housing needs. Table 42 of the GL Hearn Report identifies an affordable housing need of 199 dwellings per annum for Cambridge and 105 dwellings per annum for South Cambridgeshire, which equates to a combined total of 304 affordable dwellings per annum or a total of 6,384 dwellings during the plan period from 2020 to 2041. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely those journeys are undertaken by car this would add to traffic congestion and air pollution. 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. The site at land off Limekiln Road in Cambridge is in a sustainable location for development in transport terms. It is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to Cambridge. Cherry Hinton contains a very good range of services and facilities.

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 promoted development at land off Limekiln Road in Cambridge is accessible by sustainable modes of transport. Queen Edith's Way and Cherry Hinton Road are on bus routes. The Greater Cambridge Partnership’s Making Connections project identifies Cherry Hinton as a key location on a bus corridor, with improved bus links to Addenbrooke’s and Cambridge Station. There is a dedicated cycle path on Cherry Hinton Road. The Greater Cambridge Partnership’s proposed Fulbourn Greenway project, which includes new dedicated walking and cycling routes and improvements, passes through Cherry Hinton. Therefore, the release of the land off Limekiln Road in Cambridge 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 2.3: Edge of Cambridge and the HELAA Site Assessments (for Site Ref. 40528), the land off Limekiln Road in Cambridge 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, and should be released from the Green Belt in emerging GCLP.

There are two other paragraphs in the NPPF that suggest additional allocations should be made in on the edge of Cambridge. 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. 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.

The site at land off Limekiln Road in Cambridge is in a sustainable location for development in transport terms. It is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to Cambridge. There are primary and secondary schools in the local area and elsewhere in Cambridge. Cherry Hinton contains a range of services and facilities, including convenience stores, health facilities including doctor’s surgeries and dentists, public houses, and restaurants. The promoted development would support the existing services and facilities in Cherry Hinton. As set out above, the site is highly accessible by walking, cycling and bus services. Therefore, the promoted development at land off Limekiln Road in Cambridge is accessible by a range of sustainable modes of transport and is accessible to an excellent range of services and facilities and to employment opportunities. It would be consistent with national policy to direct additional development to this site.

As highlighted above, there is a significant need for affordable housing in Cambridge and across Greater Cambridge. There are limited previously developed land opportunities within and on the edge of Cambridge that have not already been identified. It is considered that all opportunities should be identified to meet housing and affordable housing needs, including small Green Belt sites on the edge of Cambridge and well-related to existing neighbourhoods where no significant constraints to development exist. The smaller sites in the Green Belt are always overlooked for potential release to meet housing and affordable housing needs. The promoted development by Dudley Developments at land off Limekiln Road in Cambridge would include housing and affordable housing.

For all these reasons, small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge, including small sites within the Green Belt.

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 locations on the edge of Cambridge including land off Limekiln Road in Cambridge which is close to Cherry Hinton, because it is accessible by sustainable modes of transport, it could support the existing services and facilities, and it would deliver affordable housing to meet identified needs in Cambridge.

As requested in Dudley Developments’ representations to Section 2.3 Edge of Cambridge, the land off Limekiln Road in Cambridge should be released from the Green Belt and allocated in emerging GCLP for residential development.

The development strategy of Densification is not supported. This strategy puts the Aims & Objectives of the Local Plan at risk. : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance here for both existing and growth populations here. As stated in the CPIER report (2018) if Cambridge does not remain an attractive place to live , the high levels of economic growth aspired to may fail.

The Plan refers heavily to one aspect of required infrastructure, namely potable water supplies, but for a successful extensive development it is essential that all aspects of infrastructure are available in a timely (that is earlier than the bulk of the development) manner, including
◦ Public transport
◦ High quality Broadband (with more home working people moving into new developments should expect this from move date)
◦ Social facilities (including schools, health provision, education, informal open space, formal open space, recreational provision and social indoor meeting places)
◦ (In the larger developments), local convenience stores established early in the development and not waiting until the full development is complete so the developer can get a higher price for the sale of the land for the provision of such shops
We anticipate policies to be added to the draft plan to enforce the requirements on timing of infrastructure to be conditioned in any detailed planning permissions. We note this was possible for Northstowe (by limiting the development to Phase 1 until the A14 upgrade was completed).
We would expect that such polices would apply to all large developments, not just the new ones in this new plan.