S/DS: Development strategy

OBJECT

Endurance Estates is promoting land off Old House Road in Balsham for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

The overall development strategy is very reliant on the delivery of an extension 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.

There is monitoring data, evidence from other examinations, and national research (see Start to Finish Report and updates by Lichfields for example) that provides information on housing delivery rates. 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. According to monitoring data 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 approx. 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. Based on the evidence and examples set out above, it is clear 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 (i.e. what site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings a year, consistently over a prolonged period of time. 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 statutory 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 that have come forward on major strategic sites to date are as follows: 20% at Northstowe (Phases 1 & 2), 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 should be noted that the three objectives of sustainable development – environmental, economic, and social – are interdependent and one objective is not more important than the others. It is considered that the assumption about unsustainable travel is incorrect for some villages, including Bassingbourn which contain a range of services and facilities, are in close proximity to other centres and employment opportunities, and are accessible by sustainable modes of transport and the bus services are due to be improved. 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. Endurance Estates 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 opportunities are identified to make villages more sustainable through the delivery of housing development and services/ facilities alongside, to 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.

Balsham contains a good range of services and facilities, including a primary school, village shop, post office, and public houses. The promoted development by Endurance Estates at land off Old House Road would support the existing services and facilities in the village, which are all within walking distance of the site – see attached Services & Facilities Plan including walking distances. Balsham is also on a bus route, with regular services to Haverhill and Linton and a limited daily service to Cambridge. There is a school bus service from Balsham to the secondary school at Linton Village College. It noted that the Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service including for Balsham, providing alternatives to car travel for some journeys. Balsham will have a direct link to the ‘A11 Travel Hub’ significantly increasing the opportunities for use of sustainable modes.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 21 affordable dwellings in Balsham 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 Balsham. 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 Endurance Estates at land off Old House Road in Balsham 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, including for affordable housing, 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 Balsham, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in the Endurance Estates representations to Section 2.6: Rest of Rural Area, the land off Old House Road in Balsham should be allocated in emerging GCLP for residential development.

OBJECT

Endurance Estates is promoting three sites in Bassingbourn for residential development (off Poplar Farm Close, off The Causeway and off Elbourn Way), 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 extension 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.

There is monitoring data, evidence from other examinations, and national research (see Start to Finish Report and updates by Lichfields for example) that provides information on housing delivery rates. 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 Bourne Airfield are predicted to deliver a combined total of 300 dwellings per annum. According to monitoring data 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 approx. 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. Based on the evidence and examples set out above, it is clear 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 (i.e. what site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings a year, consistently over a prolonged period of time. 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 statutory 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 that have come forward on major strategic sites to date are as follows: 20% at Northstowe (Phases 1 & 2), 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 should be noted that the three objectives of sustainable development – environmental, economic and social – are interdependent and one objective is not more important than the others. It is considered that the assumption about unsustainable travel is incorrect for some villages, including Bassingbourn which contain a range of services and facilities, are in close proximity to other centres and employment opportunities, and are accessible by sustainable modes of transport and the bus services are due to be improved. 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. Endurance Estates 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 opportunities are identified to make villages more sustainable through the delivery of housing development and services/ facilities alongside, to 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.

Bassingbourn is identified as a Minor Rural Centre in the defined settlement hierarchy for South Cambridgeshire. It contains a good range of services and facilities, including a secondary school (Bassingbourn Village College), primary school (Bassingbourn Primary School), convenience store, post office, doctor's surgery, dentist, pharmacy, public houses, mobile library, sports centre, and outdoor recreation areas. Bassingbourn is on existing bus routes, with regular services to Royston and a less frequent service to Cambridge. It noted that the Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service for Bassingbourn, with better bus connections to the railway stations at Royston, Meldreth and to the proposed travel hub at Foxton. Therefore, Bassingbourn would in the future be better served by public transport, with bus services connecting the village to train stations, and providing residents with realistic alternatives to the car for some journeys including for access to employment opportunities.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 65 affordable dwellings in Bassingbourn 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 Bassingbourn. 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 developments by Endurance Estates in Bassingbourn 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, including for affordable housing, 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 Bassingbourn, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in the Endurance Estates representations to Section 2.6: Rest of Rural Area, the land off Poplar Farm Close, off The Causeway, and off Elbourn Way in Bassingbourn should be allocated in emerging GCLP for residential development.

The emphasis on dense settlements is good. Particular emphasis should be given to possibly higher dwelling unit provision the new towns so they become vibrant self-sustaining communities with good facilities (including entertainment provision) within easy walking and cycling distance for most residents.
Both here and in any other location where development is proposed, considerable emphasis should be given to placemaking and ensuring the character of existing communities is not harmed but rather enhanced

I don't support the policy of densification. It risks the current and future population having a poor quality of life and is not in keeping with the objectives of Wellbeing & Social inclusion” and ˜Great Places” .
it is especially important to rethink the policy on North East Cambridge S/NEC. This should not be included in the local plan - it is premature and inappropriate because there will be no decision on the proposed move of the sewage works to Honey Hill until 2023. You have said you will need to defer the consultation Reg. 19 on NECAAP until the CWWTP DCO outcome is known. All the development on NEC should not be in this Local Plan as there is no guarantee it can happen".

Policy S/DS – Development strategy

2.34. As set out above, it is essential, not just for the prosperity of those living in the area, but also for the wider region within the Oxford-Cambridge Arc and the UK in general, that Greater Cambridge plays its part in delivering economic growth.
2.35. The obligation is on the LPAs to properly plan for and match the provision, and manage the impacts, of housing, including affordable housing, and jobs. The failure to co-ordinate and plan sufficient land for development would result in the Local Plan being found unsound and in turn potential unplanned development arising, in the absence of a 5-year housing land supply. In turn this would have external implications for infrastructure delivery, worsening housing and employment land affordability, increased commuting and carbon impacts. Clearly this is not sustainable in terms of social, economic and environmental impacts. In other words, not delivering sufficient land for jobs and housing would be contrary to climate mitigation strategies.
2.36. The evidence base is, we accept, currently blurred by the effects of COVID-19, but Greater Cambridge is in a strong position given its sectoral mix and there is still high demand for workspace.
2.37. The consultation document makes clear the existing commitments and allocations within the emerging Plan. Northstowe and Waterbeach are progressing, of course, and the hope from the joint authorities is for accelerated pace there. However, there are no changes proposed to overall numbers in those locations, and it is difficult to know how the LPAs expect to force that pace anyway.
2.38. MGH argue that a better pace overall is likely to be delivered by opening up new locations around Cambridge, including those supported by new infrastructure such as a rail station, and other public transport provision. Policy S/DS recognises the opportunity for “Evolving and expanding Cambourne into a vibrant town alongside the development of the new East West Rail station, which will make it one of the best connected and most accessible places in the area”, and identifying the delivery of 1,950 homes in the plan period.
2.39. We understand that Cambourne is identified as a broad location for growth, but with no specific sites identified at this point. The LPA has left the zone for Policy S/CB as, what has been referred to in one of the consultation sessions as a “mysterious circle” because the sites are not yet defined, and suggesting that the delivery of the development here would be later in the plan period. However, MGH can start delivering development at North Cambourne before the rail connections are all in place, because new sustainable transport infrastructure (C2C and Park & Ride) will be delivered in advance of the rail and provide a sustainable mode of transport as an alternative to the car. The C2C scheme will connect Cambridge to Bourn Airfield New Village and Cambourne, and therefore residents of North Cambourne would also be able to utilise this new infrastructure for travel.
2.40. Moreover, whilst Paragraph 23 of the NPPF states that “Broad locations for development should be indicated on a key diagram…” MGH considers that the opportunity exists for greater precision and therefore greater certainty (both spatially and in terms of the tests of soundness) compared to the loosely positioned circle over the existing settlement. At present the uncertainty risks raising concern with local residents unnecessarily as well as making planning for new infrastructure, such as the MRT more difficult.
2.41. The consultation rightly recognises the prospects for Cambourne as one of the best-connected places in the area, due to the planned preferred EWR route and station at North Cambourne. Our vision document and illustrative masterplan shows how these new place-making components can be delivered. The vision document, along with the transport paper that supports this representation, also explore how the new community at North Cambourne can be well connected to the existing settlement by the creation of ‘green bridges’ supporting active travel and high levels of permeability. The proposed location of the North Cambourne railway station will also add significantly to the impetus for these improved connections.
2.42. We also note that, in the transport modelling of the new settlement location options tested, the Cambourne area performed best in terms of active mode share for trips generated and equal best for car trips per dwelling. Again, our transport paper identifies more detailed information to further support these measures and thus further reduce carbon emissions.
2.43. The Development Strategy Topic Paper highlights that future development at Cambourne will address a series of key issues:
• How to integrate with and maximise the opportunity provided by East West Rail;
• The role of the new development in Cambourne as a place, and how it can contribute towards the achievement of net zero carbon;
• The relationship with Cambourne and Bourn Airfield, and how to make the area more sustainable, through the mix of services, employment and transport opportunities offered by the area as whole;
• The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy;
• How the place will develop over time, and the infrastructure needed to support different stages during its development;
• Making effective connections within the new development and with Cambourne for public transport and active travel, as well as connections to surrounding villages so they can also benefit;
• Be structured around, and have local and district centres that can meet, people’s day to day needs within walking distance, including responding to changing retail and working patterns;
• How it can help deliver the Western Gateway Green Infrastructure project, and in doing so positivity engage with its landscape setting, as well as recreation and biodiversity enhancement opportunities such as woodland planting; and
• Take opportunities to reduce flood risk to surrounding areas, that take innovative solutions to the management and reuse of water.
2.44. In addition, the Council’s evidence indicates that large scale development at Cambourne could have landscape impacts and that these would be hard to address. We consider this point further in our response to the HELAA assessment, in the vision document and in a supporting landscape paper prepared by Cooper Landscape Planning.
2.45. Landscape factors will be explored further as part of preparing the draft Local Plan, but the Councils are clear that the design of North Cambourne will need to be ‘landscape led’ in order to minimise impacts in the wider landscape and to have a focus both on place making for the expanded town, and the delivery of the wider vision for green infrastructure set out in the plan. This includes supporting the objectives for ‘Strategic Green Infrastructure Initiative 8: Western gateway multifunctional GI corridors’
2.46. Notwithstanding the issue of landscape, the consultation paper also highlights that, in the context of the significant economic and carbon benefits of locating development at the proposed new rail station at Cambourne, it is considered that the benefits are likely to outweigh the level of landscape harm..
2.47. The supporting text to draft policy S/CB says that, nevertheless, it is ‘too early to identify a specific development area and amount of development’ (hence the ‘mysterious circle’). The document does though go on to provide suggested provisional amounts and timescales associated with Cambourne as follows;
• “..anticipated to start delivering in 2032/2033 after opening of the new railway station, with build out rates based on Housing Delivery Study assumptions for new settlements of gradual increase in annual completions to maximum of 300 dwellings a year;
• 1,950 dwellings anticipated in 2020-2041
• Noting as above that it is too early to identify a specific development area and amount of development for Cambourne broad location, for the purpose of transport and other evidence testing we needed to include a specific number of total dwellings assumed to be present once development is fully built out. We therefore included an assumption of 10,000 dwellings.
Use of this figure is a proxy for a strategic scale development for the purposes of testing at this point, and does not mean that the Councils have made any decisions about the level of housing that should be located in this area.”
2.48. Building on the points set out in earlier sections, MGH advocates that the joint authorities plan for a level of growth that is informed by the economic strategy, and which is noted as plausible, should be pursued. This involves matching the provision of jobs with homes in locations that are capable of higher levels of self-containment and where the options to reduce reliance on private cars are highest.
2.49. The GL Hearn Employment Land Review that forms part of the evidence base stated that the higher employment scenario places greater weight on the fast jobs growth seen in the recent past, particularly in key sectors. By implication, this higher-level outcome is considered possible in the report but not the most likely. As such, the maximum level of homes, associated with the higher employment scenario, is not considered by the report to represent the objectively assessed need for homes in Greater Cambridge.
2.50. Importantly though the Employment Land Review makes recommendations to plan positively for growth and provide for more than the medium level of jobs, in order to provide flexibility (Section 5.3 of the Development Strategy Topic Paper refers).
2.51. In planning positively for growth, MGH agrees that it is appropriate that the new Local Plan provides new land for the identified undersupply in particular types of employment and where those are most suitable to meet sustainable development targets. This is particularly the case where there is a more blended market demand between Research and Development and office uses (former Class B1 b and a).
2.52. The GL Hearn supplementary paper identifies that spreading employment outside of Cambridge would be contrary to prime office market preferences for the city centre and city fringe locations. However, the paper also acknowledges that secondary offices and lab development is likely to be successful around Cambourne with improved accessibility.
2.53. It is also highlighted that industrial and warehousing tend to have a greater reliance on strategic road access rather than public transport and would benefit from the A428 connection. If higher growth is achieved over the next two decades, then it is suggested by the GL Hearn review that the current pipeline of supply is likely to be insufficient without further supply being made in the new plan.
2.54. It is noted that there is a likely undersupply in general industrial premises (Class B2). These premises are required and any losses, particularly in the city, would require re-provision that would need to be either on alternative sites within Cambridge or more likely elsewhere in South Cambridgeshire. Further provision should therefore be made in the new plan to address this anticipated undersupply.
2.55. The GL Hearn paper also anticipates undersupply in warehousing and distribution (Class B8) space, and it is suggested that suitable locations should be identified for small and mid-sized light industrial and distribution units with the drive-in e-commerce further increasing the need for smaller scale warehousing opportunities (final mile centres). This positive approach will ensure a flexible supply, supporting a healthy local economy over the plan period and beyond. Again, the GL Hearn paper recognises the opportunity that Cambourne provides for this sector.
2.56. The GL Hearn analysis therefore allows the expansion of Cambourne to be planned in a way that anticipates the sort of employment spaces that would be likely to be successful in the area, and is well aligned to the mixed employment strategy that the plan is seeking.
2.57. The consultation document states that having identified the objectively assessed need for housing to support the medium level jobs, the next consideration is whether it is appropriate and possible to meet those needs in full within the plan area. The total homes arising from the forecast jobs is identified in section 4 of the strategy topic paper as the objectively assessed need. In translating jobs to homes, this is represented by the scenario whereby the additional homes above the standard method are calculated with a 1:1 commuting ratio (‘consume our own smoke’). The evidence also considered the implications of following existing commuting patterns, which would have the effect of some of the additional homes having to be provided outside of Greater Cambridge.
2.58. Given the Councils’ aims of limiting global carbon emissions, and the key acknowledged role that the location of development plays in carbon emissions, the principle of limiting longer distance commuting is particularly important. In this context, as a matter of principle, the Councils’ intention is to meet the objectively assessed needs for housing identified within Greater Cambridge over the plan period, unless evidence identifies an insurmountable problem with achieving that in a sustainable way.
2.59. In the spatial options for the Western Cluster, including Cambourne, the consultation paper says;
“Headline sustainability benefits noted include:
• Further develops and enhances a new settlement where the groundwork has already been laid, providing access to services and facilities within Cambourne and likely provision of new services and facilities, resulting in positive effects for accessibility, equalities, health, climate change mitigation and air quality.
• Good access to public transport and services, facilities and employment centres elsewhere, once strategic transport infrastructure is complete.

Headline sustainability challenges noted include:

• Access to jobs and services outside Cambourne are beyond reasonable walking and cycling distance, which could encourage car use, despite public transport provision and investment.
• Could result in damage to or degradation of biodiversity assets and green infrastructure.”

MGH fully endorses the first two points, and does not consider that the latter two represent substantial risks in the overall balance. The vision document, and our responses to the HELAA and the Sustainability Appraisal in the following sections of this representation explain why.

The additional 11,640 dwellings required to cover a 10% buffer have already been provided for elsewhere, so S/CBC/A area is not needed for housing. It should not be included in this Plan.

Whilst recognising the need for new homes, we are concerned that there is a spiral of development that will continue to put pressure on housing. Limiting commercial development could break this spiral. In any event the aim of providing policies protecting green spaces, important for people’s quality of life, and protecting the qualities that makes Cambridge City a great and unique place to live are vital policy aims. The setting of the historic centre, and its relationship with the countryside with a network of green spaces complementing the built environment must be preserved

see attached

The development strategy is broadly supported however opportunities for densification of existing urban areas in locations well served by public transport should be maximised wherever possible and the approach supported by Local Plan policy.

Additional employment space at Babraham Research Campus will support the Southern Cambridge Research Cluster and ensure the Councils provide additional space for life science businesses to cluster and grow. This is in direct response to guidance contained within the NPPF regarding the need to plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, create or high technology industries. The Policy also responds to the identified unmet need for additional research and development laboratory space as evidenced in the Council’s Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020).
Babraham Research Campus is fully occupied and continues to experience high demand for space from both existing and prospective occupiers, with demand significantly outstripping supply. However, the rapid success of the Campus has now stalled and this has become a significant barrier to growth. Therefore, a key priority for the Campus is to enhance support to enable companies to continue to start-up, scale-up, grow and be retained in the UK.
Growth at Babraham Research Campus also has the ability to make best use of existing and committed sustainable transport infrastructure. The committed infrastructure proposals being progressed by the Greater Cambridge Partnership (GCP), notably the Cambridge South East Transport Scheme (CSET), will provide significant transport capacity to support the future expansion of Babraham Research Campus.
Policy S/DS is therefore supported.

I oppose releasing land from the green belt for the Cambridge Biomedical Campus. Their needs should be met through regeneration and higher density use of their current campus. Alternatives should also be sought, eg collocate common services and new demand at off-site research campus.

The development strategy is broadly supported in terms of directing development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.

The plan states “Our new development strategy aims to meet our increased need for new homes in a way that minimises our environmental impacts and improves the wellbeing of our communities.”

As argued above (in the new jobs and homes section), the primary driving force in the Cambridge housing market is for external investors to profit from the bubble that is the housing market. It is this which should be regulated, as it is so heavily resourced that it will always outpace any feasible increase in housing supply. Understanding this is critical to having a planning strategy that works. The “need” for new homes will be met with higher and higher prices paid by investors, which will push home ownership and even rental out of the reach of an increasing number of Cambridge residents.

Additionally, the plan will not improve community wellbeing. The plan will create increased capital growth for landowners, developers, and business owners. As described in the book “The Spirit Level” (2010), this has been conclusively and objectively shown to drive up inequality, and drive down community wellbeing. It is widely publicised that Cambridge is the UK city with the highest level of income inequality. This is a clear and direct consequence of the economic growth strategy which the plan presents as “good” for the city.


We also question the strategy, which is already very heavily reliant on new build housing, to allow for 10% more housing than the objectively assessed needs using a high-end estimate. Why should there be a contingency for an under-estimate by the plan (so ask for more), instead of an over-estimate (so ask for fewer), when the strategy is already taking a more optimistic view of growth than the Standard Method? Surely the “contingency” for high growth is already factored in the very use of a jobs-drive model vs the Standard Method? There is no objectively-supportable argument for this extra 10% “contingency”.

Policy S/DS is not supported. It fails to provide a balanced view of the land use options going forward, particularly the corresponding impacts of Policy S/NEC which is promoted as ‘brownfield’ with no reference to the corresponding Green Belt dependency for use of the North East Cambridge site or the capital carbon / climate impact of rebuilding a fully functional and future proofed Waste Water Treatment Works into the Greenbelt.
The Development Strategy doesn’t appear to include a balanced option on delivery of local housing needs for comparison, with an aligned transport strategy, which excludes the over densification and corresponding penalties of the S/NEC proposal.
This appears at odds with the general principles set out in the NPPF.
Map Fig 6: shows the Policies being proposed in the Cambridge Urban Area, including North East Cambridge (Policy S/NEC).
As outlined within proposed Policy S/NEC, the corresponding Waste Water Treatment Works relocation is being led by Anglian Water under a separate process.
However, map Fig 6 should also display for reference the proposed relocation site for the Waste Water Treatment Works to provide proper context for the S/NEC Policy in terms of future land use and corresponding Green Belt cost.

OBJECT

Mr James Manning is promoting land off Station Road in Willingham for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

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

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and 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 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 Willingham, 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. Mr James Manning 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.

Willingham contains a good range of services and facilities, including a variety of convenience stores, a post office, library, primary school, doctor's surgery and pharmacy, public houses and restaurants. The proposed development would support the existing services and facilities in the village. The promoted development at land off Station Road in Willingham is accessible by walking, cycling and public transport and there are bus stops nearby, and the site is well-related to the Cambridge Guided Busway stop to the south of the village. There are bus services to and from Willingham, but it is noted that the Greater Cambridge Partnership’s Making Connections project proposes a more frequent bus service from the village in the future. As such, there sustainable modes of transport are available in Willingham, providing a realistic alternative to car travel for some journeys including for access to employment.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 35 affordable dwellings in Willingham 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 the village. 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 James Manning at land off Station Road in Willingham would include housing and affordable housing to meet local needs of the village, and there will be a policy requirement for a proportion of the housing to be provided as self/custom build plots.

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

Requested Change

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

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

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

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

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

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

As requested in Mr James Manning’s representations to Section 6.2: Rest of Rural Area, the land off Station Road in Willingham should be allocated in emerging GCLP for residential development.

"Supporting the nationally important Cambridge Biomedical Campus, including through a limited release of land from the Green Belt". This doesn't make sense. The proposed release is land that is half a mile from the current edge of the Campus. That isn't a coherent development policy ensuring a dense, efficient Campus, but a sprawl across a mile of land that currently supports a wide range of wildlife and provides an essential green boundary to the city. Force the Campus to use efficiently the area it already has and then consider Green Belt release in a future Local Plan.

I agree with the focus of development in areas with good public transportation service and good provision of active travel. This has benefits in terms of the climate impact of development but also has a positive impact on the true affordability (cost of living) for residents living in affordable housing. Affordable housing in locations that require the ownership of one/two cars is not affordable.

OBJECT

Enterprise Residential Development Ltd and Davison Group are promoting land at Meadow Drift, Elsworth for residential development and community facilities including a school car park and drop off area, new allotments and ecological enhancement area, 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. 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 Elsworth, which contains some services, facilities and employment opportunities suitable to support some additional development. In addition, the preferred development strategy for the rest of the rural area provides no support for existing services and facilities, including schools, in villages and provides no strategy to meet current identified affordable housing needs of villages. Enterprise Residential Development and the Davison Group are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at 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.

Elsworth contains some services and facilities, including a primary school, public houses, church and sport and social club. Cambourne and Papworth Everard provide additional services and facilities not provided within Elsworth. There is also a successful commercial area to the south of the village offering employment opportunities. The site promoted by Enterprise Residential Development Ltd and the Davison Group at Meadow Drift, Elsworth is in the heart of the village and is accessible to all of the services and facilities in the village by walking and cycling. The local transport services available are such that future residents would have a realistic choice of travel modes.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 12 affordable dwellings in Elsworth for those with a local connection to the village. This identified need would not be met without allocations in Elsworth. 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 Enterprise Residential Development Ltd and the Davison Group at Meadow Drift, Elsworth would include housing and affordable housing to meet local needs of the village.

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

Requested Change

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

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

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

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

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

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

As requested in Enterprise Residential Development Ltd and the Davison Group’s representations to Section 6.2: Rest of Rural Area, the land at Meadow Drift, Elsworth should be allocated in emerging GCLP for residential development.

SmithsonHill recognises the benefit of a proposed development strategy for Greater Cambridge which seeks to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live.

Furthermore, it is right for the strategy to be realistic around the locational limits of some new jobs floorspace which is centred upon national and global economic clusters.

Knowledge-intensive firms and technology clusters compete on the world stage. It is the correct approach to deliver an objective to support economic growth and maintain Greater Cambridgeshire’s position as world leader in research and technology based industries by continuing to support proposals that build on the successful employment clusters.

Clusters typically refer to a collection of parks or small developments in close proximity that contain multiple occupiers carrying out similar functions.

It is worth noting that, whilst the ‘Cambridge cluster’ may be taken very broadly to include an area of about 20 miles around the city, in terms of the reality on the ground, and the commercial market, there are distinct clusters with perhaps the most notable being the concentration of life sciences sector activity to the south of the city (as acknowledged by the plan’s employment evidence) with major facilities in south Cambridgeshire including Babraham Research Campus, the Wellcome Trust Genome Campus and Granta Park.

A key aspect of clustering is the way in which co-location allows businesses and other institutions that operate in the same sector to collaborate and draw on each other’s knowledge and expertise. Access to the best scientific talents as well as to complementary skills offered by workers in allied fields is also critical.

Whilst the current development strategy proposes “some” development in the rural area south of Cambridge, the rural southern cluster, “where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links”, it is considered that the scale of the proposals and ambition is inadequate – both in terms of employment and housing sites.

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

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

On page 39 of the first proposals consultation document is it stated that:
“We also have evidence that locating homes close to existing and proposed jobs at the cluster of research parks to the south of Cambridge would help reduce commuting and associated carbon emissions and congestion. We are supporting both jobs and homes growth in this area, through rolling forward a number of existing housing allocations, and by identifying new allocations, including for jobs at Babraham Research Campus, jobs and tied homes confirming the existing planning permission at Wellcome Genome Campus, and a number of housing sites at well-connected villages in the area.”

It is considered that the plan should also consider the additional employment potential of SmithsonHill’s Hinxton site to support the continuing growth of the economic cluster in life sciences and technology related activities, together with a scale of new homes in the wider area that is commensurate to the existing and future economic growth potential of the rural southern cluster.

Countryside support the principle of the proposed development strategy for Greater Cambridge and the approach to directing development to locations where active and new public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live. This approach is consistent with the NPPF, which at paragraph 11.a) states that all plans should promote a sustainable form of development.

Countryside support the inclusion of allocations for housing and employment in the rest of the rural area as part of the proposed development strategy. The Local Plan should seek to allocate a component of its housing needs towards growth at existing villages. Sustainable development in rural areas makes an important contribution to ensuring the vitality of villages and supporting existing rural services and facilities.

This approach is supported by the National Planning Policy Framework (NPPF), which at paragraph 79 states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Land to the west of Cambridge Road, Melbourn aligns with approach taken to the development strategy and will support the objectives of the Local Plan through:

● Delivery of affordable housing, including the potential for an element of build to rent. This would allow people to up scale and downsize subject to their needs over time whilst also meeting affordable housing need within the District;
● Locating residential development adjacent to one of the village’s largest employment sites, Melbourn Science Park. Melbourn Science Park is now delivering a recently granted permission for a substantial extension and provides a unique employment source which is of great importance to Melbourn and the surrounding area. Furthermore, the site presents an opportunity to expand or support the Science Park, providing additional local employment opportunities. The development would provide people with the opportunity of living and working in the same village and encouraging sustainable modes of transport;
● Countryside has recently committed to becoming a net zero company by 2030 and have released a report ‘Pathfinder: Marking out the route to Net Zero’2 which sets out the principles that Countryside will follow to respond to the global call to arms for climate action. Land to the west of Cambridge Road, Melbourn will benefit from the action plan set out within Pathfinder report .
● The delivery of a walking route which is easily accessible to current and future residents and employees of the village. It will create a new recreation asset for the village and provide a walking opportunity for those that may have otherwise considered the need to travel to SSSIs for that activity, therefore protecting nearby SSSI’s from increased recreational pressure;
● The delivery of a pedestrian route from the West of the site along ‘the Drift’ which links to Moat Lane. This will provide new residents with enhanced pedestrian connectivity to the adjacent Science Park and the Melbourn High Street, encouraging the use of sustainable modes of transport;
● Locating development in a sustainable location, whereby future residents would not be reliant on the private car for their daily needs. Melbourn is one of the largest villages in the District and has a wide range of services and facilities, including Meldreth station, which are within walking and cycling distance of the site; and
● Supporting Melbourn’s economy, including local shops and services. The Economic Benefits Statement submitted with the outline application, found that there would also be a significant and positive impact upon Melbourn's economy with residents of the new development supporting existing local shops and services within the village. This benefit is recognised in the Delegation Report at page 30. As a result of the proposed development, approximately £248,000 per annum is expected to be spent at local shops and services, potentially supporting an additional three jobs. This assessment was based on a residential only scheme of up to 160 dwellings, nevertheless a mixed-use scheme which delivered approximately 120 homes would still provide a comparable and substantial economic benefit locally.

The site will therefore support active and public transport being the natural choice of travel, deliver on-site green infrastructure and provide homes close to jobs, services and facilities.

2 https://www.countrysideproperties.com/sites/default/files/2021-11/Pathfinder%20-%20Marking%20out%20the%20route%20to%20net%20zero.pdf

Hallam Land Management (HLM) request the Development strategy be amended in the following two respects.

Firstly, as a general point, whilst the proposed development strategy outlined under ‘Proposed policy direction’ is for the most part supported, it is generic and lacks any spatial interpretation.

It is acknowledged that the strategy goes on to identify areas of growth, and then specific locations. However, there isn’t an overarching spatial strategy that explains the rationale behind the distribution of future development, and why the areas and locations identified will help achieve the Vision and Aims.

There is significant planned investment in sustainable transport infrastructure to the west of Cambridge (Cambourne to Cambridge Better Public Transport Project (C2C) and East West Rail). This should be referenced in the strategy, with recognition that this investment should be shaping the future growth of the area in terms of homes and jobs to 2050.

Further, the strategy should be setting out how this investment will be used to benefit and connect with the wider Greater Cambridge area. The strategy appears on the Map at present as a number of distinct locations separate from each other with no inter-connectivity. Indeed, feedback from the public to earlier consultations highlighted the disconnect between the new settlements and major employment sites to the south.

The strategy should be setting out how these growth areas will be connected to each other, particularly the new towns of Northstowe, Waterbeach new town, Cambourne, and the rural southern cluster, and how these areas will connect with East West Rail and C2C. This is illustrated within the Emerging Vision submitted in support of the new settlement promoted by HLM at Scotland Farm (HELAA Site Reference 56252).

It is requested therefore the Councils consider adding a more specific spatial strategy that explains how Greater Cambridge will grow in the future, and why, and how its existing growth areas will benefit from the substantial investment of East West Rail and C2C

The second point made in respect of the strategy is that HLM consider the locations identified for accommodating growth should be amended to include a new settlement at Scotland Farm (HELAA Site Reference 56252).

Paragraph 11a of the Framework defines what sustainable development means in terms of plan-making, much of which is reflected in the proposed strategy.

One aspect of paragraph 11a that is particularly important is aligning growth and infrastructure. It is clearly vital to make the best use of public investment in infrastructure (existing and new), as well as using new development to support longer term viability. Moreover, utilising existing or planned infrastructure can reduce the financial burden on new development and improve its viability and speed of delivery. In the context of ever increasing pressure on public finances and the need to maximise benefits from development, these are important considerations.

The proposed strategy does recognise this where it states ‘the proposed strategy … responds to opportunities created by proposed major new infrastructure.’

However, the locations for growth identified do not reflect the opportunity created by C2C, and in particular the Scotland Farm Travel Hub.

C2C is a key part of the Greater Cambridge Partnership’s sustainable transport programme. Whilst this is responding in part to existing planned growth, it must also shape future growth given the level of investment.

Scotland Farm Travel Hub is a key element of the C2C route. Work is already underway in preparing the planning application, and the site is expected to be operational by 2024. It will transform the accessibility of this area in terms of its connectivity by sustainable modes of travel with a service every 10 minutes to Cambridge City Centre and Cambourne, and every 15 minutes to Cambridge Biomedical Campus. With a direct service to the City Centre and a likely journey time of less than 20 minutes, it will become one of the most accessible locations in Greater Cambridge outside of the urban area.

Further, there is the potential as illustrated above for this development to support connections between the Travel Hub with Northstowe and Waterbeach beyond by active and sustainable modes.

It is entirely appropriate therefore to align that investment in public transport infrastructure with new development. To do otherwise, would not be consistent with national policy and thereby not sound.

Through careful masterplanning as illustrated within the Emerging Vision submitted with these representations, active travel and public transport would be the natural choice for residents and workers within the new settlement.

It is in this context that HLM consider the proposed strategy should be amended to include a new settlement at Scotland Farm. This should either be in addition to the selected locations in order to bolster supply to meet the housing and employment requirement, or as an alternative to those selected that are not taken forward in the Plan.

Further information in support of the allocation of land at Scotland Farm (HELAA Ref: 56252) and in response to the assessment in the HELAA is provided under New Settlements – General Comments.

Policy S/DS is broadly supported in terms of directing development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.

Broadly we support the spatial strategy for locating new development:

The policy of development in a relatively small number of large new settlements, rather than green belt release or a scatter-gun approach across all the villages of South Cambs is supported.

The policy of seeking to keep Cambridge a compact city through support for its green belt against city fringe expansion is supported, however we object to two areas of green belt release.

The sustainability of this strategy will depend on the adequacy of the transport links between the new settlements and the main centres of employment. Northstowe is served by the guided busway (both public transport and active travel), Waterbeach New Town will be served by rail and a new greenway and ‘greater Cambourne’ will be served by East-West Rail and a new greenway. Some of the plans by the Greater Cambridge Partnership to provide busways to these settlements and employment sites would be damaging to the green belt, landscape, ecology and heritage and are not supported.

The transport modelling for the Preferred Option assumes that Cambridge would need to increase the number of Park & Ride parking spaces from just over 7,000 now to over 26,000 in 2041 (Table 41 in the Transport Evidence report: 20,687 Park & Active trips plus 32,239 Park & Ride trips). This is acknowledged nowhere in the draft Local Plan policies, despite it potentially harming the landscape and ecology of the green belt far more than the proposed new and extended settlements.

We act for various landowning clients and we are promoting sites in their ownership for residential development (please see separate representations to chapter S/RRA Allocations in the Rest of the Rural Area).

On behalf of our clients, we make the following comments on the Regulation 18 Preferred Options Consultation

This policy direction is supported in trying to achieve sustainable development. Site reference 40302 is located in Linton which is one of the better served villages with a host of facilities, shops and services, far in excess of most villages throughout the District. There are significant committed funds to improve the A1307 corridor and provide for better sustainable travel infrastructure. The improvements to the sustainable transport routes along the 1307 include proposals for a new rural hub (Bartlow Road Roundabout and Rural Hub), further supporting the east side of Linton
as an appropriate location for development.

Pigeon supports a strategy which looks to allocate a greater number of new sites in locations where active and public transport is the natural choice, and where new housing would support services and facilities in existing communities.

The strategy should be amended in the ‘Rest of the Rural Area’ by identifying a greater number of new sites which have very good public/active transport access. Hardwick is one such example of a sustainable settlement which benefits from good cycle links and a bus services to Cambridge, and is proposed to benefit from improved sustainable transport connections as follows:.

• A new Park and Ride facility is proposed at Scotland Farm directly opposite Hardwick, from where existing and new residents will be able to cycle/walk to this transport interchange.
• Cambridge is approximately a 20min cycle ride from the village via an improving cycle network.
• Cambourne, and the new East-West railway station, is less than a 20 min cycle, again via good quality cycling infrastructure.

Amending the strategy by allocating a greater proportion of new growth to locations served by sustainable transport infrastructure will meet the wider sustainability objectives of the plan, whilst providing a more resilient strategy.

Adopting such an approach will help sustain existing services and facilities in rural villages, and offers the opportunity to meet local community aspirations. In the case of Hardwick there is local support for the construction of a new village hall, although a recognition that this would result in the loss of much sought after public open space which is already in short supply. By bringing forward sustainable housing growth outside of the Green Belt there is the opportunity to help facilitate the delivery of the new village hall through S106 contributions, in addition to providing new much sought after public open space.

We support the key principles of the proposed development strategy to direct development to
where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way. We also support the need to be realistic around the locational limits of some new jobs floorspace which is centred upon national and global economic clusters.
We also agree that sites should be developed at densities, and using appropriate forms
and patterns of development, which make best use of land while creating well-designed,
characterful places.
In particular, we support the principles of:
■ the development of Cambridge East as a new mixed-use district on the existing safeguarded land at Cambridge Airport;
■ the continued development of the nationally important Cambridge Biomedical Campus, including through a
limited release of land from the Green Belt;
■ Using land more effectively at North West Cambridge through intensifying development;
■ Development of an Innovation District at West Cambridge
■ Evolving and expanding Cambourne into a vibrant town alongside the development of
the new East West Rail station

We consider, however, that the Councils’ preferred option forecasts of jobs and homes are low, and that more realistic forecasts should be adopted along with the identification of land to meet higher assessed needs for development. We support CBC Ltd’s responses relating to the future development and growth of Cambridge Biomedical Campus, and the North Barton Road Landowners Group’s proposals for development at South West Cambridge.

The consultation document outlines the preferred development strategy for Greater Cambridge and defines the intention to direct development where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.

The strategy notes that development will therefore make use of brownfield opportunities within the Cambridge Urban Area, urban extension and new settlements but only proposes a very limited amount of development in rural areas.

At this early stage in the Local Plan preparation process (Regulation 18), further consideration of sites suitable for potential development of specialist housing for older people (including Extra Care development) in sustainable locations should be undertaken. The former Papworth Hospital site provides an excellent opportunity to deliver Extra Care development in a sustainable location which will support rural services, improve the vitality and viability of Papworth Everard and the local shops and facilities whilst also enhancing local amenities including healthcare. The proposed development strategy focuses on a number of larger, strategic developments which will not support the existing villages and will not deliver the type of housing required to meet the housing needs of specialist groups (such as older people) and the needs of the local community.

Caxton Parish Council notes that the recommendation is for more housing than the government minimum required for the whole area. The Parish Council feels that the Local Plan should be endeavouring to maintain the character of Cambridgeshire and keep developments to the minimum within villages.

Toft Parish Council is supportive of the strategy that the proposed new developments be attached to the existing new developments that already have better transport links, rather than distributing them among the smaller villages that may not have the infrastructure to support them.