S/DS: Development strategy

The proposed development strategy for Greater Cambridge directs the vast majority of growth to the Cambridge Urban Area, the edge of Cambridge and new settlements. Only a very small level of growth is directed to the Rest of the Rural Area. Of the allocations proposed, the majority of these are existing commitments (adopted allocations, sites with planning permission etc.). The Council are only proposing a need for an additional 11,640 homes to be allocated through the emerging Local Plan.

As part of their strategy, the Council have stated that their top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes. Some villages within South Cambridgeshire are in very close proximity to Cambridge; benefit from close proximity to employment opportunities; and are well placed in terms of existing and proposed public transport routes. Hauxton is such a settlement.

The allocation of the FWWTW for a greater quantum of housing and/or employment would help meet the needs of smaller settlements over the Plan period, providing greater variety in the types and location of development delivered and co-locating homes and jobs in close proximity to one another, reducing the need to travel.

With respect to the delivery of housing, it is important to highlight that the NPPF is clear in paragraph 69 that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly’ and that local planning authorities should ‘promote the development of a good mix of sites’. It is considered that the Council strategy focuses on the delivery of very large sites with a much lesser number of small and medium allocations.

Furthermore, paragraph 79 of the NPPF is clear that in order 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.’ By delivering more housing and/or employment florrspace in settlements such as Hauxton, development will continue to support local services and facilities, supporting their retention and growth.

In respect of delivering employment provision, paragraph 85 of the NPPF is clear that ‘planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport’. Whilst the Site is presently beyond the settlement boundary, opportunities close to the Site will significantly improve the public transport and sustainable modes of transport options to access the Site, not just from the City but from the surrounding settlements too. These same opportunities will also significantly change the Site setting and will place it instead, within a dynamic transport and growth corridor, linking directly to the City Centre and the Cambridge Biomedical Campus.

Paragraph 85 of the NPPF goes on to say that ‘the use of previously developed land, and sites that are physically well-related to existing settlements should be encouraged where opportunities exist.’ Bridgemere Land Plc consider that their Site at Hauxton represents such an opportunity and that it will also provide the opportunity to remediate a highly contaminated Site, which will have wider environmental and/or employment and housing benefits.

Bridgemere Land Plc are therefore of the view that the Council should look to deliver a greater number of smaller and medium allocations to ensure that there is a supply of housing that can be built out sooner within the Plan period, but that the FWWTW site is also highly suited to deliver employment floorspace, or a mixture of the two. The Site in Hauxton comes with environmental constraints which will need to be addressed in full and would constitute an environment benefit to the wider area. It could be remediated and developed within the first half of the Plan period.

General agreement

The options for the distribution of homes and employment were tested in the suite of evidence base documents that the GCSP published in November 2020 documents and through the latest Preferred Options documents.

Marshall considers that, in order for the GCSP to plan at a scale necessary to generate investment for significant infrastructure and to meet the housing and employment needs of the area, the GCSP are right to adopt a strategy that combines different locations for focusing growth. Densification of existing urban areas is a logical place for development in sustainability terms; however, this option alone will be insufficient in terms of land capacity to accommodate the housing and employment needs for the area.

Therefore, the GCSP has opted for a blended strategy which directs new development towards locations that generate the least climate impacts, in line with the aims and objectives of the Local Plan. In locational terms, this objective to direct development to the locations that generate the least climate impacts means that the majority of the proposed growth is directed toward the Cambridge urban area, edge of Cambridge sites and new settlements. Marshall strongly supports the GCSP’s blended approach and the selection of proposed sites based on their ability to contribute to climate change objectives.

Pages 41 and 42 of the ‘First Proposals’ document, in relation to Policy S/DS, identify that there is a need for new strategic water supply infrastructure in Greater Cambridge to provide for the longer term needs of the preferred growth trajectories. It is indicated that a suitable solution may not be forthcoming until the mid-2030s and that the Local Plan may look to limit development levels until such a time that the strategic infrastructure is operational and able to support full delivery rates.

An integrated approach is required from all the key stakeholders in order to have a positive effect on the potential impacts of growth on the water environment. In particular, the onus is on Water Resources East and the water companies, through their obligations in the Water Industries Act 1991, to plan for and provide water to meet the requirements. Developments, including Cambridge East, will also have an important role to play and will need to make a more meaningful contribution to a sustainable future through the implementation of integrated water management regimes. The legal obligation and responsibility is on the water companies to address the expected water supply shortage and ensure that a suitable solution is identified to maintain the delivery rates required to meet housing and employment needs in Greater Cambridge. This matter should not influence the approach that the GCSP take to meeting the area’s needs. Marshall are keen to work with the water companies and the local authorities to understand and explore this matter further.

Having regard for the transport strategy outlined a part of Policy S/DS (pages 43 – 46), Marshall are supportive of the committed infrastructure proposals that are being progressed by the transport bodies and the objective of seeking to achieve a modal shift away from the use of the private car. As set out in the NPPF, the supply of large numbers of new homes can often be best achieved through planning for large scale development, provided that this development is supported by the necessary infrastructure. In order to ensure there is a genuine switch from car use towards sustainable modes of transport, new development must be supported by convenient, regular and affordable public transport, as well as safe and accessible pedestrian / cycle links.

Cambridge East provides a significant opportunity to address the current lack of cross-city connectivity through the provision of a transformational transport strategy linking the eastern side of the City with Cambridge Station, the city centre, Cambridge North Station and Addenbrooke’s and other key locations to the south. The greater the scale of development at Cambridge East, the greater the footfall, capacity and opportunity to deliver a transformational transport system that is a step change in transport in Greater Cambridge. Cambridge East has the potential to unlock mobility solutions that will make living, working and travelling in Cambridge easy, affordable and better for the environment.

Marshall and its consultant team are continuing to work closely with the GCSP, Cambridgeshire County Council, the Greater Cambridge Partnership and the Cambridgeshire & Peterborough Combined Authority to test and develop the most suitable and sustainable transport solution to support Cambridge East and beyond, exploring schemes that can be funded through already existing funding streams (e.g. City Deal), as well as more ambitious proposals which could be delivered through funding that the scheme itself can help to leverage given the scale of housing and economic potential.

We object to the very limited amount of development in the rural area that is proposed as further development is needed to allow villages to thrive. Focusing the allocations within the Cambridge urban area, on the edge of Cambridge, in Cambourne and new settlements ignores the need to sustain the rural villages and support their vitality. The delivery of small sites can deliver quicker than larger developments and there is more certainty of delivery.

S/C/SMS Garages between 20 St. Matthews Street and Blue Moon Public House, Cambridge. I object to this provision. The St Matthews Area is already at capacity for on street parked cars and the demolition of these recently constructed garages will be to the detriment of residents amenity.

Please see representations

OBJECT

Hawkswren Ltd is promoting land off Leaden Hill in Orwell for residential development and representations have requested that this site is allocated in the emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

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

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and 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 Orwell 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. Hawkswren are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages to support services and ensure that identified affordable housing needs are met.

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

Orwell is identified as a Group Village in the defined settlement hierarchy for South Cambridgeshire. It contains a good range of services and facilities, including a Primary School, Village Store, Post Office, pub, village hall and outdoor recreation areas. It also benefits from a regular bus service with Cambridge which is due to be improved.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 12 affordable dwellings in Orwell for those with a local connection to the village – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without allocations in Orwell. It is noted that there is no neighbourhood plan being prepared for the village, no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Hawkswren in Orwell would include self-build 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 Orwell, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in the Hawkswren representations to Section 2.6: Rest of Rural Area, the land off Leaden Hill, Orwell should be allocated in emerging GCLP for residential development.

OBJECT

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

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

The most recent housing trajectory for Greater Cambridge (published April 2021) already predicts high average annual housing delivery rates for the new settlements: Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum; and 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, and 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 more 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, including the Mill Lane, Site, Sawston, that are capable of providing policy compliant levels of affordable housing.

The promoted development by NW Bio, the Mill Lane Site, Sawston, is located within the Green Belt. In these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation, and it is proposed that other land within the Rural Southern Cluster is released from the Green Belt for these reasons. The Mill Lane Site and Sawston generally are very well related to Addenbrooke’s Hospital, Royal Papworth Hospital, Cambridge Biomedical Campus and other employment opportunities within and on the edge of Cambridge.

Additionally, the Mill Lane Site is owned by Northwest Biotherapeutics (NW Bio), a biotechnology company developing novel immune therapies to treat cancer. NW Bio’s DCVax®-L immune therapy for Glioblastoma brain cancer is in the NIHR's Priority Portfolio, and was the first product to receive PIM designation as a Promising Innovative Medicine from the Medicines and Healthcare products Regulatory Agency (MRHA). NW Bio currently has offices in London and is developing an advanced manufacturing and technology development facility in Sawston, where they are working together with Advent BioServices to develop the Vision Centre on the former Spicers site. Advent is one of only a small number of companies in the world that specializes in technology/process development and advanced manufacturing for cell and tissue therapies for cancer and other diseases.

Since our previous submission, significant progress has been made in the physical development of the Vison Centre. Most importantly, it is expected within the next week or two that the Medicines and Healthcare products Regulatory Agency (MHRA) will be granting certification of Phase One of the production facility to ramp-up production to 45 self paying patients per month under their Specials/Compassionate Treatment Program. This milestone approval represents 7 months of testing and MHRA reviews and inspections involving all of the now 39 staff and growing. In turn, this major event for the entire area has been facilitated by the following developments at the plant itself over since our previous submission of representatives, including the following:

• Significant upgrade to two clean room suites to enable these to be Medicines and Healthcare product Regulatory Agency (MHRA) compliant
• Warehouse incorporating Goods in/quarantine and a temperature controlled store
• Two process development laboratories
• Quality control laboratory
• Freezer facility incorporating room for 60 x -80C freezers (currently 30 freezers in place)
• Construction of further office to support freezer facility
• State-of the-art Ultra cold Liquid Nitrogen facility with the capacity to store up to 3,000,000 samples at -196C for third party clients
• Installation of a nitrogen generator which removes and liquifies N2 from the atmosphere – removes the need for weekly deliveries of gas to site
• Cell therapy product goods in/out rooms
• Data management centre containing 3 towers loaded with processers and other essential IT equipment
• Installation of lift shafts and stairs to upper floor
• Fitting out of additional office space
• Creation of corridors for materials, staff and waste

The following infrastructure also has now been put in place to serve the Vision Centre:

• Installation of emergency generator, boiler, uninterrupted power supply, air handling units
• Installation of BT fibre network
• Installation of environmental monitoring equipment and software – monitors temperatures, pressures, air changes, humidity 24/7
• Installation and implementation of a quality management system and the writing of over 1000 regulatory documents
• Installation of electricity supply to futureproof the building and remove the VC from the larger site network
• Implementation of a laboratory information management system
• Development of website
• Awarded licences from the Human Tissue Authority for cell storage
• Underwent inspection from MHRA -awaiting licence to manufacture advanced therapy products for UK Specials programme and for clinical trials

The Vision Centre is located just across the A1301, a 5 or 10-minute walk from the proposed residential site on Mill Lane. The Vision Centre is an advanced manufacturing facility that will produce cell therapy products for the UK and for export to the European Union and other geographies. The development of the Vision Centre will involve the creation of up to 450 new high-value jobs across a wide range of skill levels in phases over the next few years.

Recruitment has also taken place since the submission of previous representations and the total number of employees at the Vision Centre is now 40. These include manufacturing scientists, QA and QC staff, facilities management, IT, clinical coordinator, administration, validation experts, HR and finance personnel. This also includes the recruitment of three apprentices as part of the national network ATAC scheme in cell and gene therapy, with a fourth apprentice to be taken on shortly.

Some of the staff that have been taken on to date are from the local area but other are from elsewhere in UK including London, Stevenage, Bedfordshire, Kent, Berkshire, and Suffolk. It is not possible for all staff to be recruited from the local area as a result of the need to recruit Qualified persons (for regulatory purposes).

A key factor which will affect the pace at which personnel can be hired for these jobs will be the availability of housing nearby to the Vision Centre. A proportion of Vision Centre employees will have to live close to the site because producing and managing living cell products requires unpredictable and varied hours (e.g., when tissues are received from hospitals for processing at any time of the day or evening). The jobs at the Vision Centre are and will continue to be for a range of employees, from school leavers through to PhD level. This will result in increased employment and learning opportunities within Sawston and South Cambridgeshire as a whole, which will have benefits for social inclusion.

The ability of other employees of the Vision Centre to live in close proximity to the site will also have clear benefits for their mental health and well-being, by avoiding the need for significant commuting and promoting opportunities for active forms of travel, such as walking and cycling. The residential development of the Mill Lane Site, Sawston would also provide additional housing that is much needed for nearby surrounding employment sites, including existing sites to the east and north of Sawston; Huawei’s emerging business and research campus at the former Spicers site; Granta Park; Cambridge Biomedical Campus; and the expanding Wellcome Genome Campus.

The Mill Lane Site is also in a location with extensive existing transport access by walking, cycling, bus and train and the Site has good accessibility (a 15 minute or so walk or a short cycle ride) to existing services and facilities within Sawston including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. Having all of these services and facilities within close proximity of the Site will allow future occupants to access these services using sustainable travel modes, thus reducing emissions associated with use of the private car, and will assist the development, and its occupants, in integrating into the wider Sawston community. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

There is also an identified need for affordable housing in Sawston that would not be met by the emerging GCLP.

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

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The Mill Lane Site, Sawston is well served by public transport (bus and rail) and is well connected with existing cycle routes, and there are future public transport improvements proposed in the surrounding area. Therefore, the release of the site from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

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

Sawston contains a good range of services and facilities including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. The promoted development by NW Bio would support existing services and facilities. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

The nearest bus stops are located on Cambridge Road within an acceptable walking distance of the site via the existing footways on Mill Lane and New Road, and provide access to Bus Services Citi 7 and 7A, and are likely to be used by future residents of the site to access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance of the site, and likely to be used by future residents of the site to access existing services and facilities in Cambridge and the wider area surrounding the site.

Therefore, the promoted development by NW Bio at the Mill Lane Site, Sawston is accessible by a range of sustainable modes of transport, and it would be consistent with national policy to direct additional development to this site.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 115 affordable dwellings in Sawston for those with a local connection to the village. The emerging GCLP contains one allocation for residential development in Sawston that it is proposed will be carried forward from the South Cambridgeshire Local Plan (2018) (S/RSC/H/1 (c): land south of Babraham Road, Sawston) for 80 dwellings. Assuming that this site comes forward and delivers a policy compliant level of affordable housing (40%), it can be assumed that this site would deliver 32 affordable dwellings. Accordingly, there would be a residual need for 83 affordable dwellings within the village. The identified need for Sawston would not be met without an additional allocation. It is noted that a Sawston Neighbourhood Plan Area was designated in 2018, and it appears that there has been some evidence gathering since then but a draft plan has not yet been published. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Sawston should seek to accommodate district-wide affordable housing needs and not just those local needs arising in the village and the immediate surrounding area. The promoted development by NW Bio would include housing and affordable housing to meet local needs of the village.

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

Requested Change

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

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

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

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

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

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

As requested in NW Bio’s representations to Section 2.5 Rural Southern Cluster, the Mill Lane Site, Sawston should be released from the Green Belt and allocated in emerging GCLP for residential development.

We support the need for a strategy to locate development where travel can be minimised. It is also important to recognise that villages have social and economic needs, in order to meet their affordable housing needs and provide a sense of community, to support their local shops, schools and community facilities. Further consideration needs to be given to some limited growth at sustainable villages which can support those settlements and deliver early in the plan period. Foxton is one such village where supporting some limited growth will support the local village but in a location which is accessible by public transport (train) to key destinations.

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

We support the proposed development strategy for Greater Cambridge in seeking 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 do not agree however that this should dictate that the plan promote few strategic sites at the expense of all other existing centres in the District. The development strategy as proposed is overly reliant on strategic allocations. It does not consider what may happen to 5-year housing supply if these limited locations encounter delivery issues. Equally it does not consider the impact of both limiting growth in existing settlements such as Cottenham and promoting it elsewhere.

Very few sites for housing are identified outside of the strategic allocations. No sites are identified to contribute to Cottenham’s future vitality and viability. It is evident that existing planning permissions in Cottenham will be built out over the next few years. The Plan then envisages no further development in Cottenham through to 2041.

This is not a proactive strategy for maintaining and enhancing the vitality of a sustainable
location. The Plan must set out options for the longer term future of sustainable locations such as Cottenham
Delivering extensions to existing communities and continuing to build on the strong cultural and social aspects of the larger settlements is vital in the progress towards achieving healthier communities. Proposing modern homes that create improved sustainable credentials and add vitality to existing neighbourhoods is not only a requirement of local and regional policy, but one that is adopted within the National Planning Policy Framework.

Limiting growth to just a few strategic allocations presents risks with disproportionate settlement growth presenting a real threat to settlements such as Cottenham resulting in stagnated growth and poor support for local facilities. Furthermore the over reliance on strategy allocations is high risk in terms of continual supply and draw down for 5 year land supply. It is suggested that at the very least Green Belt is reviewed and where sites may be suitable for removal from this designation this should be identified and acknowledged and such sites should safeguarded for future residential development should it be required.

As per the proposals presented in the Vision Document submitted alongside these representations it is proposed that Land off Beach Road, Cottenham is identified in the Greater Cambridge Local Plan for the development of up to 80 houses.

It is considered that the development of the site could contribute substantially to the social and economic growth of Cottenham Its significance as an important settlement within the district. Extensive assessments of the site have concluded that its development would result in minor impacts to the character and openness of the Green Belt and the wider landscape, whilst also outlining the opportunity to provide policy compliant levels of biodiversity
enhancement and affordable housing.

It is clear that development of this site will not impinge on the environs of Cambridge. A Green Belt review has been undertaken having regard the potential development of the site concluding that the release of the parcel for residential development would have no impact on 4 of the 5 functions of Green Belt and only minor impacts on the purposes of the Cambridge Green Belt as identified in the Greater Cambridge Local Plan.

Similarly, given the nature of the site and the surrounding landscape, a Landscape Visual Impact Assessment has also been prepared for the site. It notes that the site is within a transitional area at the edge of the Fen Edge Village and bordered by a series of orchards, hedges and trees to the southeast, by (mostly modern 2-storey brick) housing on Brenda Gautry Way to the north and further residential areas to the west. To its northeast and eastern
edge, the site fronts Beach Road and includes a number of dwellings on the road frontage, with further estate development beyond. It is considered that development of the site can be managed sensitively so as to be read as part of the existing settlement and minimise any impacts on the local landscape.

The vision document demonstrates that the site can accommodate new rural housing in an environmentally sensitive, sustainable and responsible manor. It is proposed that development of the site can deliver approximately 80 new homes offering opportunities across a range of house types, sizes and tenures including an appropriate proportion of affordable housing and green open space. The proposals as outlined through the Vision Document would deliver new high quality homes and open space in a sustainable and deliverable location, with access to essential local services and facilities, employment, public transport, education and leisure.

To conclude, Cottenham’s sustainable location within the district, in combination with the highly accessible transport connections, make the village an appropriate location for future growth. The site itself represents a wholly viable option for residential development and it is recommended therefore, that this site be allocated for residential development in the emerging Greater Cambridge Local Plan.

OBJECT

Bloor Homes Eastern is promoting land west of Linton for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster, and specifically the decision to allocate a very limited amount of development to the more sustainable villages and no development to sustainable villages such as Linton.

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

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

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

The preferred development strategy for the rural southern cluster is based on providing additional employment land at existing business clusters and a limited amount of additional housing at villages that are well connected to jobs by walking, cycling and public transport. It is considered that Linton contains a very good range of services and facilities, is accessible by sustainable modes of transport with new walking, cycling and public transport routes planned, and is very well related to employment opportunities at Granta Park and Babraham Research Campus. The decision to allocate housing sites at a limited number of villages in the rural southern cluster provides no support for the existing services and facilities in other sustainable villages provides no strategy to meet current identified affordable housing needs of those villages, and ignores the close proximity of major employment sites to Linton. Bloor Homes Eastern are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages including Linton 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 rural southern cluster. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Linton contains a very good range of services and facilities, including primary schools, secondary school, convenience stores and post office, village hall, health services including a medical centre, public houses, cafes and restaurants, and bus services. The promoted development at land west of Linton would support the existing services and facilities in the village. The promoted development would also provide land for a GP surgery and early years facility.

The promoted development by Bloor Homes Eastern at land west of Linton is accessible by walking, cycling and public transport to the services and facilities within the village and to employment at Granta Park and Babraham Research Centre. The promoted development would provide additional facilities including a GP surgery, early years facility, play areas, and open space including allotments. The site would be well-related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership’s Cambridge South East Transport project, which includes a new public transport route into Cambridge, a greenway/cycle route through Linton to Granta Park and Babraham Research Campus, and a rural travel hub at Linton. The Greater Cambridge Partnership’s Making Connections project also proposes a more frequent bus service for Linton.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 50 affordable dwellings in Linton 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 Linton. It is noted that no draft neighbourhood plan has been published for the village, there is no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Bloor Homes Eastern at land west of Linton 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, additional medium scale housing allocations should be made in the more sustainable villages within the rural southern cluster , including at Linton, because it is accessible by sustainable modes of transport, it is well-related to the employment sites at Granta Park and Babraham Research Centre, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the 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 additional medium scale housing allocations should be made in the more sustainable villages within rural southern cluster, including at Linton, 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 Bloor Homes Eastern representations to Section 2.5: Rural Southern Cluster, the land west of Linton should be allocated in emerging GCLP for residential development.

The Council should consider allocating a greater number of small to medium size sites which can be delivered early on in the plan period where they are located in or adjacent to settlements that can offer a good supply of shops and services, schools along with access to sustainable transport. Paragraph 79 of the NPPF is clear that in order 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.’

The focus of development in the new settlements and strategic sites in Cambridge and to the north of the GCLP is generally appropriate, however, this needs to be balanced against the need for providing homes and jobs in areas, including the rest of the rural area which makes use of existing infrastructure, and where there is access to existing public transport links.

Please see additional written representations submitted in relation to sites 40088 and 40089 for further details.

Spatial Strategy

1 Paragraph 20 of the National Planning Policy Framework (NPPF) requires strategic policies to set out an overall strategy for the pattern, scale and design quality of places to deliver housing (including affordable housing).

2 Page 29 of the First Proposals document that development strategy for the GCLP “is to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.”

3 In the context of the above statement, it is important to note that Greater Cambridge possesses a network of established sustainable settlements, such as Histon & Impington, which are well served by a wide range of shops and services, significant employment and education opportunities and highly sustainable transport links to the city and beyond. Histon & Impington is unquestionably a sustainable settlement capable of accommodating proportionate growth whilst reducing the impact on climate change. Histon and Impington is to continue its position in the settlement hierarchy as “Rural Centre” a Tier 2 (out of 5) settlement.

4 As set out at page 43 of the First Proposals document Greater Cambridge possess an excellent range of existing public transport connections, with new investment and projects coming on stream now and throughout the Plan period. The existing Guided Busway, bus network, rail network and numerous Park & Ride facilities allow the Councils the opportunity to identify new housing allocations at established rural settlements which benefit from convenient access to these sustainable travel measures. Indeed, the Councils confidence in making sustainable allocations in rural areas should be further enhanced through the investment in other proposed public transport initiatives such as East West Rail, Travel Hubs, further Park & Ride facilities and the new multi modal link to Cambourne. Page 44 of the First Proposals document contends that the proposed development strategy is “heavily informed by the location of existing and committed public transport schemes”.

5 The development strategy pursued by the GCLP is described as a “blended strategy” taken from the development strategy in the adopted Local Plans and four new strategy choices. The blended strategy covers the following: Cambridge urban area, edge of Cambridge, new settlements, villages, public transport corridors, providing homes close to jobs in research parks to the south of Cambridge, integrating development with infrastructure improvements to the west of Cambridge and a further hybrid option which involves Green Belt release.

6 The GCLP contends that this blended strategy will make “best use of existing and committed key sustainable transport infrastructure” and support “rural communities to thrive and sustain services”. In respect of specifically planning for the rural area of Greater Cambridge the development strategy proposes a “a very limited amount of development” at small sites at villages which have “very good public transport access”. The First Proposals document does not define “very good public transport access”. In terms of making specific new allocations in the rural area the GCLP makes a “limited number of new sites for housing at our more sustainable villages”. In this regard, we wish to highlight that Histon & Impington is only separated from the urban area of Cambridge by the A14 and thus has excellent physical and public transport links to the city.

7 To meet the housing need target proposed by GCLP (44,400 dwellings + 10% buffer) the First Proposals document states that there are 37,200 dwellings in the current supply comprising planning permissions, existing allocations and windfall allowance. This leaves a need to identify sites to deliver 11,640 new dwellings. A total of 224 dwellings are proposed for allocation in the rest of rural area, across sites in Melbourn (x2), Caldecote and Oakington. Melbourn is a “Minor Rural Centre”, with Caldecote and Oakington being “Group Villages”, tiers 3 and 4 of the Settlement Hierarchy. Of the new dwelling allocations proposed by the GCLP only 1.9% are directed towards the rest of rural area. This figure rises to 3.2% if the housing delivery associated with supporting jobs at research parks to the south of Cambridge is included.

8 Figure 10 of the First Proposals documents states that 18% of the total housing growth (including existing allocations, planning permissions and windfall allowance) will be directed to the rural area through the GCLP. The 18% is a 5% reduction on growth afforded to rural areas through the current adopted Plans and a 12% drop on the old Structure Plan.

9 It is contended that the blended development strategy and approach to making new allocations will not facilitate the delivery of thriving rural communities or sustain key services over the plan period, supposed aims of the strategy and the GCLP. The blended strategy results in a rather confused and contrived approach to making new housing allocations heavily reliant on strategic sites and New Settlements. The approach taken to allocating new sites for housing in rural settlements appears to be led by the availability of the Councils preferred available sites, rather than one which focuses allocations on the most sustainable settlements and capitalising on the sustainability and climate change benefits provided by existing and proposed public transport infrastructure. Rural Centres such as Histon and Impington are not afforded any new housing growth, with the GCLP instead identifying allocations at lower ranking settlements in the hierarchy. There is no clear rationale provided as to why the development strategy focuses on these lower ranking settlements and seemingly dismissing the prospect of making new allocations at more sustainable settlements. In addition, there is no clear rationale provided as to why growth has been directed to the selected Minor Rural Centre and Group Villages, and not other settlements in the same classification.

10 As stated above, the GCLP will deliver only 3.2% of housing at new allocations in the rural area. Evidently this is not a balanced and flexible strategy which supports established sustainable rural communities. The proposed strategy also stifles the role of Neighbourhood Planning in Greater Cambridge by not allocating specific levels of growth to guide the review of or preparation of Plans in designated Neighbourhood Plan Areas which possess an established sustainable settlement. The approach to guide Neighbourhood Plans by identifying indicative levels of growth from Windfall numbers is not a sound or robust way to proceed.

11 The First Proposals document and accompanying evidence base aims to support rural communities and sustain their existing service provision, but its current approach to making new housing allocations and Neighbourhood Planning will clearly not deliver on this aim. The approach taken to allocating the limited growth in rural areas is site led, disregards the settlement hierarchy, sustainable transport connections and the aim of GCLP which is to locate development in the most sustainable locations to reduce the impact of climate change. Over the plan period the blended development strategy will see the stagnation of sustainable settlements in the rural area through the failure to deliver housing choice (market and affordable) which in turns supports rural businesses and services and the vitality of key rural infrastructure such as bus routes, GPs and schools. The proposed development strategy is not robust and thus unsound in its approach to delivering proportionate and sustainable growth in rural areas.


Housing Supply

12 The NPPF requires local planning authorities to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to their objectively assessed housing need. Paragraphs 60 and 68 of the NPPF make specific reference to the need for a mix and variety of land to be identified for housing.

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

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

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

16 It is acknowledged that the allocation of new settlements and large-scale strategic sites can form a key part of a balanced spatial strategy to bring forward sustainable growth in a district. However, the approach put forward by the Councils does not represent a flexible and balanced approach capable of responding to changing circumstances (NPPF paragraph 33) or providing a mix and variety of sites. Furthermore, the per annum housing delivery targets for the new settlements are very high, particularly at Waterbeach which is yet to deliver dwellings. Bringing forward new settlements and large strategic sites is a complex process which often requires the delivery of significant up-front infrastructure which can sometimes be subject to different funding mechanism and complex land ownership constraints. These issues often impact and delay the delivery of strategic sites, accordingly, the GCLP needs to allocate a variety of different types of sites. The delays in delivery of new settlements in the Greater Cambridge area, along with the necessary strategic infrastructure are well documented and there continues to be a significant lag in the delivery of new homes required at these locations. There is nothing within the proposed plan that provides comfort that these issues will be satisfactorily resolved.

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

Windfall Sites

18 To deliver the Councils current proposed objectively assessed needs figure the First Proposals document states that 5,345 of this need will be met by Windfall Sites. This is an increase on 1,125 dwellings on the current adopted Plans. Accordingly, 11% of the total housing need (44,400 – plus a 10% buffer) over the plan period will be met by Windfall Sites and 9.7% (1,125/11,596) of the new housing growth proposed by the GCLP is accounted for by Windfall Site.

19 The Development Strategy Topic Paper explains that the increase in Windfall rates is because the Windfall figures associated with adopted Plans has proven to be an underestimate. It is contended that the new Windfall figure is very high and that an increase is not necessary. Windfall levels in Greater Cambridge are artificially high because of the extended period in the previous decade where a large number of speculative development proposals were approved in a period when the Councils were unable to demonstrate a five-year housing land supply. The significant number of permissions granted in this period are now being delivered and has led to the inflation in Windfall numbers. Many of these permissions, some delivered at appeal, recognised the important role other sustainable settlements can play in delivering housing need and supporting vital local services. This is not recognised in the emerging plan and settlements close to Cambridge and with excellent connectivity are well placed to support the plans wider growth aspirations.

20 The GCLP can plan positively and sustainably by re-allocating windfall numbers to make allocations at established rural settlements or by assigning an overarching housing target to designated Neighbourhood Plan Areas (which contain a sustainable settlement). This approach will assist in guarding against future drops in five-year supply and allow the Council and Neighbourhood Plan Groups to take the lead in planning positively for new housing whilst being mindful of the challenges of climate change.

21 The 10% buffer to be applied to the proposed objectively assessed housing need amounts to 4,400 dwellings. This buffer is largely accounted for by the total Windfall allowance of 5,345 dwellings. Accordingly, it is contended that the 10% is not a true buffer as it is largely accounted for by dwelling numbers which aren’t allocated at specific sites or settlements.

Water Supply Infrastructure

22 The First Proposals document and associated evidence base outline that there is a need for new strategic water supply infrastructure to support growth proposals and to protect the integrity of the chalk aquifer south of Cambridge. It is understood that Water Resource East will publish its Water Management Plan for the region (covering the period to 2050) in 2022. This Plan will likely include significant new infrastructure in the form of a new Fenland reservoir which will be available to supply water from the mid 2030’s.

23 It is noted that the ‘GCLP Integrated Water Management Study) (November 2020) (IWMS) states that higher growth option is not compatible with the planned delivery of new water supply infrastructure. The central growth scenario is considered achievable from a water supply perspective subject to regional scale water supply solution being operational by the 2030s. In this regard the DSTP states that “evidence in November 2020 had indicated that there may be potential for interim measures to support the medium growth level and potentially more, but that the maximum growth level was not possible”. These conclusions further heighten the need for the Councils to undertake further employment forecasting work to identify an appropriate point with the central and higher growth ranges set out by the HERR.

24 The IWMS and DSTP refers to interim measures being available to support growth in the short to medium term of the plan period, however, it is unclear from the published evidence as to what extent these interim measures are being examined and scrutinised as options to assist in the delivery of growth over the short to medium term of the plan period.

25 Whilst continuing to pursue this key matter with Government and the relevant authorities significant work needs to be undertaken to further identify and programme practical interim solutions to overcome this potential constraint to growth in the area. The need to programme interim measures to a specific timescale will become vital in the eventuality that a stepped approach to housing delivery is required to overcome this constraint.

Sections 3 and 4 of the representation attached address these policies. There has been an imbalance in strategic spatial planning with growth, mainly housing, weighted to the north, west and east of the City. This contrasts with the rapid growth in research parks located to the south of the City. The Spatial Strategy recognises this problem but does not go far enough to tackle the imbalance between employment growth and new housing.
The proposal by Grosvenor will help to redress this imbalance by promoting 300 new homes in Whittlesford in a highly sustainable location.

“The proposed development strategy takes up opportunities to use brownfield land and responds to opportunities created by proposed major new infrastructure.”

• The proposed development strategy does not respond sufficiently and most effectively to the opportunity created by the A428/E-W Rail/OxCam Arc corridor.
• The strategy only makes one allocation within the A428/E-W Rail/OxCam Arc corridor (at Cambourne).
• This does not capitalise fully on the opportunity because:
> Further growth could be delivered along the corridor in a sustainable manner; and
> To be reliable, any growth delivered within the corridor should be delivered in more than just one location in order to provide:
- Greater choice in terms of the location, size, type and tenure of housing that the emerging local plan can offer.
- Greater flexibility and resilience in this arm of the emerging local plan’s housing/development strategy.

“For our new settlements, we propose:
• Evolving and expanding Cambourne into a vibrant town alongside the development of the new station, which will make it one of the best connected and most accessible places in the area; and …”

• Like Cambourne, Papworth Everard will be one of the best connected and most accessible places in the area.
• It too should be allowed to evolve and expand in a proportionate and sustainable manner.
• Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096) could accommodate such, as demonstrated in the updated vision document for the site (December 2021 – submitted through the ‘Submit additional site information’ part of the ‘First Proposals’ consultation).

“We propose 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, including:
• Employment and tied housing at the Wellcome Genome Campus expansion – confirming the existing planning permission;
• Additional employment at Babraham Research Campus, through releasing the Campus and a modest area of additional land from the Green Belt;
• New smaller sites for housing and employment in villages that have very good public transport access and are close to jobs, some of which are through release of land from the Green Belt; and …”

• It is not clear why the cluster approach has been adopted only in the southern rural area of Greater Cambridge and not other rural parts of plan area.
• The rural southern area is not the only area which lends itself to such an approach. Another obvious location for the adopting the cluster approach to allocating new development is the A428/E-W Rail/OxCam Arc corridor. Significant employment exists in both Cambourne and Papworth Everard already and there is clear logic in allocating new employment and housing to support it.
• Both Cambourne and Papworth Everard have very good public transport links (one of the key criteria applied in the Rural Southern Cluster allocation approach).
• Accordingly, growth should be allocated to Papworth Everard in the same manner as it is proposed to be allocated to villages in the Rural Southern Cluster in order to:
> support and grow the existing employment provision in the area;
> help meet the plan’s housing requirement (which should be based on the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes);
> provide greater choice in terms of the location, size, type and tenure of housing that the plan can offer; and
> provide greater flexibility and resilience in the Councils’ housing/development strategy.

“In the rest of the rural area, we propose a very limited amount of development:
• Small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive; …”

• The proposed development strategy involves growth in only a very limited selection of the settlements in Greater Cambridge.
• Papworth Everard will have excellent public transport access following the delivery of several committed transport infrastructure projects. It is therefore a settlement where housing and employment growth should be being allocated in order to:
> Help the village thrive;
> Support the local economy;
> Help meet the plan’s housing requirement;
> Provide greater choice in terms of the location, size, type and tenure of housing that the plan can offer; and
> Provide greater flexibility and resilience in the Councils’ housing/development strategy.

“In order to provide greater confidence that the identified housing needs in Policy S/JH New Jobs and Homes can be met, and that a continuing supply of housing can be demonstrated, we are proposing to allocate enough sites to provide approximately a 10% buffer so we have the flexibility to deal with unforeseen circumstances. We also propose to provide flexibility in the amount and type of employment land supply to help enable the Greater Cambridge economy to continue to flourish.”

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

“The total additional homes to be identified is set out below, taking into account the identified housing need for the period 2020-41, application of the approximate 10% buffer, and current committed housing supply.”


"Homes to provide for Homes 2020 2041
Housing need (rounded) 44,400
Approximate 10% buffer for flexibility 4,440
Total number of homes to provide for 48,840
Current housing supply: comprising adopted allocations, windfall allowance, and dwelling equivalent from communal accommodation allocated or with planning permission 37,200
Total additional homes to be identified 11,640
The sources of housing supply to meet the requirement set out above include the following sites (note some sites will continue to build out beyond 2041 – see individual site sections):"


• Despite being significant, the level of growth proposed is insufficient.
• Through their ongoing extensive and detailed research, Cambridge Ahead (likely the foremost authority on the mater of Cambridge’s economy and growth), have concluded/demonstrated as follows with respect to the ‘First Proposals’:
> If planned for well, higher growth rates than those proposed can be accommodated in a way that improves quality of life for existing and new residents in balance with the needs of the environment and the economy (i.e. in a sustainable way).
> The most recent growth data does not support the projections expressed in the ‘First Proposals’. This raises concerns that the Councils will again serially underestimate the opportunities that high growth creates.
> Cambridge Ahead’s view is that the long run rates in the ‘First Proposals’ are adopting an under-estimate and do not provide the best possible objective assessment of the area’s growth. As a result, the ‘First Proposals’ risk repeating the previous errors in the EEFM forecasts and ignoring the warnings flagged by the Cambridge Ahead’s CPIER.
> The three complementary arguments underlying the recommended annualised growth scenarios for the emerging Plan – KS3/1.1%, with the possibility of the slightly higher KS2/1.5% - have clear flaws, as set out in GL Hearn’s analysis. The historical reversion to the regional mean was notably higher than the recommended figure. The reasons put forward for discounting the recent performance of the higher exogenous sectors have not provided supporting evidence and therefore lack a credible evidential basis. In addition, the suggestion that the high growth between 2011-17 was peaking and is likely to regress to a future regional or national mean has not only been unconvincingly argued, but has now been convincingly rebutted by the continued high growth of the region.
> Accordingly, Cambridge Ahead do not feel that the recommended Plan annualised growth rates stand up to the test of providing an objective assessment for the region’s proposed future growth.
• Having regard to Cambridge Ahead’s findings therefore, higher rates of growth not just can be provided for (because they can be delivered sustainably) but should be provided for (in order that the levels of growth that current trends show are most likely to occur over the plan period are catered for).
• The growth in jobs and homes proposed in the ‘First Proposals’ and subsequent drafts of the emerging local plan should therefore be increased to the higher jobs and homes scenario (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes).


"Location Policy reference / Site name Homes 2020 2041
New settlements S/CB Cambourne 1,950"

• New housing along the A428/E-W Rail/OxCam Arc corridor should not be allocated to Cambourne alone.
• Papworth Everard provides an excellent location for new housing and relates equally well to the A428/E-W Rail/OxCam Arc corridor.
• Allocating land at Papworth Everard for housing would provide:
> Greater choice in terms of the location, size, type and tenure of housing that the plan can offer.
> Greater flexibility and resilience in this aspect of the Councils’ housing/development strategy.


What alternatives did we consider?


“… Our evidence showed that these performed well against our core evidence and better than most other alternative options when considered against key aims of:
• Reducing climate impacts through compact development located to connect homes and jobs, and where active and sustainable travel can be maximised;
• Making best use of suitable safeguarded and brownfield land;
• Making best use of existing and committed key sustainable transport infrastructure; and
• Supporting rural communities to thrive and sustain services.”

“Consideration was given to the provision of a range of sizes and types of sites to give flexibility and help with delivery over the plan period, reflecting our evidence, and a modest element of housing was in principle considered to be an appropriate element of the strategy. Drawing on our evidence, a wide range of sites were considered but many were not preferred due to their impacts, with only a limited number of sites being preferred in Cambridge, close to centres of employment in the southern cluster, and in villages well served by public transport in the rest of the rural area. Allocating large numbers of sites in villages was not a preferred approach, as evidence demonstrated how poorly dispersed strategy performed with regard to a number of issues, but particularly in relation to transport and carbon impacts.”


• Despite what is claimed, the development strategy which has been selected does not perform well against the key aims of:
> Making best use of existing and committed key sustainable transport infrastructure; and
> Supporting rural communities to thrive and sustain services.
This is because:
> it does not capitalise fully and most effectively on the committed key sustainable transport infrastructure along the A428/E-W Rail/OxCam Arc corridor.
> It involves and therefore supports very few rural communities and, therefore, far from thriving, most rural communities will stand still or stagnate during the plan period, rather than growing in a sustainable manner.

• Further, the development strategy is insufficiently diversified because:
> It does not include enough small-medium size allocations to:
- Provide a reliable, smooth supply of housing land over the whole plan period; and
- Provide a suitable level of choice in terms of the location, size, type and tenure of housing that the emerging local plan will deliver.

• As a result the development strategy risks:
> further concentrating growth and wealth in a limited number of areas within Greater Cambridge.
> Not sufficiently capitalising on the significant opportunity offered by the A428/E-W Rail/OxCam Arc corridor.
> Failing to support the successful delivery of the A428/E-W Rail/OxCam Arc corridor as a result of not allocating development which will help fund, support and connect with it.

OBJECT

These representations are submitted on behalf of Endurance Estates, who has promoted land at Crow Green to the north-east of Caxton Gibbet for employment uses. The promoted development comprises mid-tech and advanced manufacturing employment uses and strategic logistics development. The site is located to the north of Cambourne, and the promoted development would increase employment opportunities at Cambourne. The site located at a junction that is due to be upgraded as part of the proposed A428 Black Cat to Caxton Gibbet Improvements project being brought forward by National Highways. The site would also be well-related to the Cambourne to Cambridge Better Public Transport project being delivered by the Greater Cambridge Partnership and the preferred routes for the East West Rail project including the proposed station at Cambourne.

These representations to Policy S/DS are focussed on the part of the development strategy that relate to Cambourne because of the location of the site promoted by Endurance Estates; separate representations are submitted to Policy S/CB: Cambourne. The development strategy for Cambourne states “For our new settlements, we propose: 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”. The principle of expanding Cambourne to make it a vibrant town is supported. However, the delivery of additional employment land at Cambourne must be part of any strategy to make it more vibrant.

In summary, there is a need for additional industrial (Class B2) and storage and distribution (Class B8) land in Greater Cambridge, but a limited supply and strong market demand. The promoted development by Endurance Estates at Caxton Gibbet would meet the demand for mid-tech and advanced manufacturing units and strategic logistics units, and would provide a range of unit sizes to meet the needs of different occupiers. The promoted development is well-related to Cambourne and to the strategic road network, and would provide employment opportunities for current and future residents closer to where they live. It is requested in these representations that the development strategy for Cambourne makes specific reference to increasing the supply of employment land at Cambourne. The representations to Policy S/CB: Cambourne seek an allocation of the land at Caxton Gibbet for industrial and storage and distribution uses. The representations to Policy J/NE: New Employment Development comment on the employment land evidence prepared for emerging GCLP and specifically the decision to not allocate land for warehouse and distribution centres in Greater Cambridge despite the identified need and demand.

Paragraph 8 of the NPPF identifies the three objectives of sustainable development. The economic objective specifically identifies the need to build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity. Paragraph 20 notes that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for employment and other commercial development amongst other matters. Paragraph 81 expects planning policies to create the conditions in which businesses can invest, expand and adapt, and to support economic growth and productivity and to meet the needs of business. Paragraph 82 expects planning policies to have regard to local industrial strategies and other local policies for economic development and regeneration, and to identify strategic sites to meet economic strategies and anticipated employment needs. Paragraph 83 expects planning policies to recognise and address the specific locational requirements of different sectors including high technology industries and storage and distribution operations. Paragraph 031 (ID: 2a) of the Planning Practice Guidance explains how local planning authorities should identify the need for logistics and allocate land to meet that need. The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020 GL Hearn) was prepared to inform the economic development and employment land needs for emerging GCLP, including the approach to the provision of land for Class B2 and B8 uses. As explained below, it is considered that the evidence base for the emerging GCLP underestimates the need for Class B2 and B8 uses, and does not reflect the market demand for these uses in Greater Cambridge.

The Need for Employment Land Report (prepared by Savills on behalf of Endurance Estates) assessed the employment land evidence for emerging GCLP; the Report is attached to the representations to Policy S/CB: Cambourne that includes a request for land at Caxton Gibbet to be allocated for industrial (mid-tech/ advanced manufacturing) and storage and distribution (logistics) uses. In summary, Savills conclude that the employment land evidence base underestimates the actual need for Class B2 and B8 uses, does not properly take into account existing supply or market signals, and ignores the wider region/functional property market area relevant to Greater Cambridge. The current and emerging policies for industrial development are restrictive, and suppress demand. Savills estimate that between 270,000 sqm and 461,000 sqm of industrial floorspace is required over the plan period.

The Market Demand Report (prepared by Carter Jonas on behalf of Endurance Estates) assessed the supply, demand and need for high technology manufacturing and logistics floorspace; the Report is attached to the representations to Policy S/CB: Cambourne. In summary, Carter Jonas conclude that there is limited supply of floorspace suitable for high technology manufacturing and logistics uses, and the supply is not being provided in Cambridgeshire. There is strong demand for floorspace in Greater Cambridge and along the A428 corridor, but that demand is not being met.

The Savills and Carter Jonas reports identify the benefits of the logistics sector and of the promoted employment development at land at Caxton Gibbet, which are explained in more detail in the representations to Policy S/CB: Cambourne.

Paragraph 104 of the NPPF expects transport issues to be considered at an early stage of plan-making, so that impacts and opportunities can be assessed. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. Paragraph 106 expects planning policies to support an appropriate mix of uses across an area, and within larger scale sites, to minimise the number and length of journeys needed for employment, amongst other matters.

There are a number of transport infrastructure projects already planned at an in the vicinity of Cambourne that will improve accessibility along the A428 corridor in South Cambridgeshire. Those transport projects are the proposed A428 Black Cat to Caxton Gibbet Improvements project, the preferred routes for the East West Rail project including the proposed station at Cambourne, and the Cambourne to Cambridge Better Public Transport project. Therefore, in due course Cambourne and the promoted development at Caxton Gibbet will be very well connected by road, rail and bus. The improvements to the A428 include the delivery of pedestrian routes and connections across the Caxton Gibbet junction, south to Cambourne West, as well as improvements further east at the ‘Cambourne Junction’. In all respects, additional employment development at Cambourne/Caxton Gibbet would deliver on the sustainable transport objectives of national policy.

Cambourne has a good range of services and facilities, but it lacks land for employment which means that residents need to travel elsewhere to access job opportunities. Cambourne with approved expansion will have 6,600 dwellings and a further potential 1,950 dwellings in the future proposed through the emerging Greater Cambridge Local Plan, and Bourn Airfield will have 3,500 dwellings. . Cambourne is currently the largest settlement in South Cambridgeshire. A more sustainable outcome would be delivered if a higher proportion of Cambourne’s existing and future residents could access employment opportunities locally, commuting via sustainable modes and reducing commuting into Cambridge. Irrespective of potential future housing growth at Cambourne there is already a significant case to be made for providing more jobs close to existing houses in this location. The promoted development by Endurance Estates at Caxton Gibbet would provide some of those employment opportunities.

In conclusion, the development strategy ignores the opportunity for additional employment to be provided at and in the vicinity of Cambourne, and does not properly reflect the need and demand for Class B2 and B8 uses.

Requested Change

It is requested that the development strategy for Cambourne makes specific reference to increasing the supply of employment land at and in the vicinity of Cambourne, including at land at Caxton Gibbet as promoted by Endurance Estates.

The development strategy set out in the consultation document is based around a need for 11,640 additional homes to be identified over the period 2021-41. In keeping with our response to S/JH, we consider that this is inadequate to support the realistic growth objectives of the Greater Cambridge area over the next two decades.

In order to ensure choice, affordability and diversity, the Local Plan must make provision for a sufficient quantity of housing. It must also include a range of housing types and sizes, across a variety of sites and locations. In accordance with the NPPF (paragraph 68), strategic policy-making authorities should identify a sufficient supply and mix of sites over the local plan period. This should include small and medium sites (NPPF, paragraph 69), in addition to large and strategic sites, to ensure the ongoing delivery of housing throughout the plan period.

In terms of the spatial strategy, we strongly object to the approach set out in the consultation document.

We believe that there is an over-reliance on North East Cambridge (the North East Cambridge Area Action Plan – NEECAP Area), the edge of Cambridge and a limited number of new settlements. Whilst some development is proposed in the rural area south of Cambridge (‘Rural Southern Cluster’) the consultation document sets out the following approach for the ‘rest of the rural area’ (page 31, emphasis added):
“In the rest of the rural area, we propose a very limited amount of development:
• Small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive;
• New employment sites in the countryside meeting specific business needs; and
• Windfall development - an allowance for homes on unallocated land, which would need to be consistent with policy requirements in the Plan, including Policy SS/SH: Settlement Hierarchy, which sets out scales of development in different categories of village.”

We strongly object to the proposed development strategy, and in particular the lack of site allocations for the rural areas. The Site at ‘land east of Cambridge Road, Hardwick’ (Site No. 40414) would clearly has the potential to deliver housing and employment that is well-connected to public transport and local services, and that can help the village thrive – fulfilling the objectives for rural areas set out in the first two bullet points as quoted above. The lack of allocations and general approach is considered to lack any sense of forward planning for the existing village settlements, some of which are highly sustainable and represent excellent locations for growth. Existing village settlements make up a significant proportion of the Greater Cambridge area, and form the majority of South Cambridgeshire District. By adopting a reactive-only approach (windfalls-led), there are restricted opportunities for a genuinely plan-led approach to the development of these villages.

We believe that the proposed strategy is in conflict with the policy set out in NPPF (paragraph 79), which sets out the following approach in relation to rural housing:
“To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”

In the context of the NPPF, we urge the Councils to review their development strategy in relation to the rural area.

As shown by Figure 10 of the consultation document (page 40), the proposed spatial strategy represents a decrease in the proportion of growth within rural areas: from 30% in the Structure Plan; to 23% in the currently adopted Local Plans; down to a proposed 18% (for the emerging Greater Cambridge Local Plan). Supporting text states that “the less sustainable rural area would have a lower share of development in the new plan, whilst still providing some limited development to help support our rural communities” (page 40, emphasis added). This represents a gross generalisation: there are many settlements within the rural area that are very sustainable, and there are many that could be made more sustainable if evidence suggests (via a more informative audit of facilities/services) that growth could address a local shortfall of services. We consider that the spatial strategy should include an enhanced and more informative audit of services and local needs for each settlement and support more allocations within the rural area, particularly where it could address local needs that would make a settlement more sustainable, or where there are existing sustainable settlements on public transport corridors such as Hardwick Village.

We are strongly of the opinion that the development strategy should include a range of site allocations within the rural area villages. In addition to harnessing the existing potential of sustainable locations – where there is good access to public transport, etc – the careful planning of village site allocations can deliver benefits and enhancements for the existing population of the settlement (in addition to new residents). Where well-located and well-planned, a new development or settlement extension within a village context can be a catalyst to deliver wider and more holistic improvements, in the best interests of local communities – the Local Plan evidence base should re-assess this and identify where development in or adjacent to settlements could be made to address/support local needs.

Another risk to the proposed strategy is that unplanned, piecemeal development is likely to come forward in and around the villages in the event that housing completions stall on the strategic / new settlement sites. There is a genuine risk that major infrastructure requirements, S.106 triggers and other constraints could delay the delivery of housing completions on several of the major sites. The impact on housing land supply – as experienced within South Cambs District in recent times – is that the tilted balance of NPPF will become engaged and windfall sites will be granted planning permission through an appeals-led approach. This is less likely to deliver the well-planned and sustainable development that could be provided through an allocations-led approach.

The ongoing sustainable development and rejuvenation of existing village settlements should form part of the vision and development strategy of the Greater Cambridge Local Plan. The strategy set out in D/DS includes an over-emphasis on the City and new settlements; it is imbalanced and demonstrates a lack of consideration for the significant proportion of the area which is made up of village settlements. These communities require new housing to meet local needs, and opportunities for sustainable growth and development. We believe that the strategy should be revisited with this in mind.

On a related note, alongside the lack of medium and large-scale site allocations within the rural area villages, the Settlement Hierarchy (Policy S/SH) proposes significant restrictions on the typical scale of development within the villages (depending upon their ranking in the hierarchy). By limiting the size of housing development that can come forward via windfalls, there is a reduced prospect of significant community benefits and affordable housing being delivered through these sites.

With regard to the sources of supply, a blended strategy is proposed which draws on multiple approaches including; densification of Cambridge urban area, edge of Cambridge (outside the Green Belt), new settlement expansion, focus on public transport corridors and some dispersal to the villages. We feel the potential for further new settlements should form part of the strategy considerations.

The potential for further new settlements has been dismissed in the assessment of options and the Strategy places unsubstantiated reliance on intensification of existing allocations (North West Cambridge) and accelerated delivery at the new settlements of Northstowe and Waterbeach. In total, this accelerated delivery and intensification is expected to deliver 2,500 new homes over the Plan period. It is unclear how this approach can significantly boost the supply of homes (as sought in Government policy) in comparison with an approach which identifies additional strategic sites for new housing.

The Plan identifies that there is the opportunity for additional homes within the built area of the existing site in North West Cambridge at Eddington (1000 additional homes). Simply making an existing allocation larger does not necessarily mean it will deliver housing at an increased rate. We note that in the draft housing trajectory (Development Strategic Topic Paper) completions at Eddington are shown to increase from 109 to 291 dwellings per annum in the monitoring year 2024/2025. Beyond this, the delivery rate is set at around 250 homes per annum. This is an unrealistic expectation and whilst it would not be disputed that larger sites can contribute more units over the longer term (i.e. beyond the plan period), it is not necessarily the case that larger sites deliver more units per year. Output is dictated by market demand in a particular area, the number of sales outlets (per developer) on site and the capacity of homebuilding for each company on site. Given that a housebuilder would typically build 35-50 homes per sales outlet, the expectation for Eddington would require 5-7 housebuilders on this single site. This is extremely unlikely and does not reflect the historic disposal strategy of the landowner for this site. There appears to be no certainty contained in the evidence base that this additional housing at Eddington can come forward in the period to 2041.

The accelerated delivery at Waterbeach equates to an additional 50 units per annum over the period 2026/27 to 2041/41. A total of 750 additional homes are identified above the planned growth. No evidence is presented in the current consultation as to how this accelerated delivery is to be achieved. Housing delivery at Waterbeach has not yet started (anticipated to commence in 2022). In a similar approach to Northstowe, the draft housing trajectory assumes 250 units from each site per annum. At this stage there is no evidence to support the view that delivery rates can be sustained in these locations at this level.

As advised at para 73 (d) NPPF 2021, strategic policy-making authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites. Without further justification for the densification and acceleration of key schemes within the development strategy the housing delivery element of the Plan would be unsound.

The conclusion must be that further strategic sites need to be allocated for housing to ensure the required annualised supply of housing of 2,326 homes can be achieved. Vistry Group and RH Topham & Sons Ltd do not feel that sufficient evidence has been put forward to show that this can be achieved by a strategy that relies upon increasing the density of existing allocations and accelerating delivery. The identification of a further new settlement or strategic expansion of a sustainably located settlement would provide greater certainty around housing supply over the Plan period and beyond. We feel there is more potential for integrating new development (in the form of new allocations) with planned new infrastructure to the west of Cambridge such as the A428 Improvement Scheme.

The Landowner, RH Topham & Sons Ltd submitted a proposal for a new settlement option at Croxton during the 2019 Call for Sites stage (HELAA reference 40288). This site offers the opportunity to co-ordinate the delivery of new homes and jobs with key elements of committed transport infrastructure. NPPF 2021, para 73 directs strategic-policy makers to consider the opportunities presented by existing or planned investment in infrastructure when considering suitable locations for new development. This must therefore consider potential site opportunities which arise as a result of changes to key infrastructure. In terms of suitability, the Site falls outside of the Cambridge Green Belt, lies wholly in Flood Zone 1 (lowest probability of flooding), outside of any protected landscape/open space designation and is not part of a County Wildlife Site. In addition, there are no abnormal physical constraints to the development of the land.

The Concept Plan included with the earlier submission and provided with these representations shows how a Croxton Garden Village concept within the Greater Cambridge Local Plan administrative boundary could be achieved. The land contained between the new A428 carriageway and the existing road can accommodate circa 1,750 homes and associated supporting infrastructure within the South Cambridgeshire administrative boundary.

The land is in single ownership and can be phased over future Plan periods to continue delivering to 2050. A proposed Garden Village at Croxton would be a unique, practical and exciting opportunity to deliver housing and growth needs using Garden Settlement principles. The proposed location, being bounded by the existing and new A428 road could provide a solution towards meeting the identified social and economic needs and addressing the housing and development delivery during the Plan period and beyond.

The land is controlled by Vistry Group which was formed in January 2020 following the successful acquisition of Linden Homes and the Galliford Try Partnerships & Regeneration businesses by Bovis Homes Group PLC. With developments from Northumberland to Cornwall and Cheshire to Norfolk, Vistry is one of the top five housebuilders in the UK by volume. As one of the country’s leading housebuilders, Vistry has an established reputation for quality that runs through their homes’ design, build, specification and customer service.

Vistry Group has an established track record of taking large strategic sites through Local Plans to planning permission and importantly then delivering the new communities (infrastructure and homes) on the ground in a timely manner.

Introducing further land supply through alternative locations where they are not affected by large-scale upfront infrastructure requirements with long lead-in periods can enable new communities to be established quickly. For example, utilising planned infrastructure projects to direct growth to areas that have the necessary infrastructure capacity and options to influence delivery rates is key. Taking advantage of this immediate opportunity that new transport connections will offer during the Plan period will help create new markets to offer choice and avoid market saturation. The committed A428 dualling scheme should be a key focus for locating new housing in a location with improved connectivity and accessibility.

A Croxton growth option should be considered in the context of extending the C2C corridor scheme to link through to the St Neots rail infrastructure.

When the A428 Black Cat to Caxton Gibbet improvements scheme opens in 2025/2026, the new dual carriageway will become an extension of the existing A421. The certainty created through the committed funding stream and the current Development Consent Order application can be relied upon during the early part of the Plan period which allows major decisions to be made on locating development along this road corridor.

The First Proposals acknowledge that Cambourne could be a broad location for growth where the exact quantity, locations and design will be defined through future plan reviews. It correctly acknowledges that it is too early to identify a specific development area and amount of development.

There is potentially a case for a longer plan period to 2050 to be advanced to allow time to plan the necessary infrastructure but this would not change the need for sufficient land to be identified for the phase to 2041 on deliverable sites.

There is already significant committed growth around Cambourne and at Bourne Airfield which can continue through the Plan period regardless.

Whilst the future EWR route and new station locations are uncertain, all of the published work to date demonstrates that the land at Croxton will not be affected by any of the route options. The site is the only contained land parcel between the Black Cat Roundabout and west Cambridge that does not require any land to be safeguarded to deliver EWR. Should the current or preferred Route Options 1, 2 or 9 be realised, the recent Value Management Scenario testing has shown that all works would occur beyond the site boundaries. This is in stark contrast to any Cambourne-related works.

In summary, the draft development strategy does not currently reflect a robust spatial strategy that is capable of delivering the stated growth levels during the plan period. Some additional sites will be required.

Our Clients acknowledge this is a ‘First Proposals’ stage but it is imperative that progress on the plan preparation is not unnecessarily delayed pending decisions on the EWR route. There is the opportunity to include safeguarded land/corridors within the 2041 plan with a view to locating additional growth in a future plan review to 2050 once the route is fixed/delivered.

For the current Plan, additional land will be required to be identified now that will be compatible with, and complement future growth at Cambourne.

OBJECT

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

The overall development strategy is overly reliant on the delivery of extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing. There can be no certainty at all regarding East West Rail which is many years away and the abandonment of the East-West expressway and parts of HS2 must cast serious doubts over the prospect of it being funded.

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. 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 or at both at the same 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 is allocated in both Local Plans as a strategic site. It is acknowledged that this site involves 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. It is considered that the delivery of development at the site 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.

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 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 is 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 and North East Cambridge the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The promoted development by Hill Residential at land east of Balsham Road in Fulbourn is located within the Green Belt, and in these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation and not just the Rural Southern Cluster as indicated in emerging GCLP. There are other villages in the Green Belt that are also well related to employment and are accessible by sustainable modes of transport, and the identified exceptional circumstances apply to these villages too. For example, Fulbourn is very well related to the employment opportunities within and on the edge of Cambridge including Peterhouse Technology Park and Capital Park and to the Southern cluster. In addition, it contains a very good range of services and facilities and is accessible by sustainable modes of transport, and there is an identified need for affordable housing which is not being addressed through the emerging neighbourhood plan or by the emerging GCLP.

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

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. Fulbourn is well served by public transport and is well connected with existing cycle routes, and there are plans to improve the walking and cycling connections to Cambridge. Therefore, the release of suitable land from the Green Belt on the edge of Fulbourn would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport. As set out above, exceptional circumstances to release land from the Green Belt applies to other locations on the edge of Cambridge, and not just the Rural Southern Cluster. All of the larger villages on the edge of Cambridge are well related to employment and are accessible by non-car modes of transport, and are sustainable locations for additional development. It is requested that land on the edge of Fulbourn, including land east of Balsham Road promoted by Hill Residential, should be released from the Green Belt on the grounds that it is a sustainable location for development.

As set out in representations to Section 2.6: Rest of Rural Area and the HELAA Site Assessments (for Site Ref. 40271), the land east of Balsham Road in Fulbourn makes a limited contribution to openness and the purposes for including land within the Green Belt and should be released from the Green Belt in emerging GCLP.

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

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

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

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 65 affordable dwellings in Fulbourn for those with a local connection to the village, and affordable housing needs in the neighbouring villages of Teversham (21 dwellings) and Great Wilbraham/Little Wilbraham (6 dwellings) – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without additional allocations in Fulbourn. It is noted that the emerging Fulbourn Neighbourhood Plan makes no new housing allocations despite the need for affordable housing being identified as an issue for the local community. There is no community land trust in Fulbourn. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Hill Residential at land east of Balsham Road in Fulbourn would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including at Fulbourn, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is an identified need for affordable housing in the villages which would only partially be met by other developments.

Requested Change

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

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

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

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

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.

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

As requested in Hill Residential’s representations to Section 2.6: Rest of Rural Area, the land east of Balsham Road in Fulbourn should be released from the Green Belt and allocated in emerging GCLP for residential development.

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

As noted in our previous comments we consider that the strategy is incorrect and the delivery of housing within rural areas should be proposed. This will ensure that the villages within South Cambridgeshire do not stagnate and assist with affordability factors.
The restrictions placed upon the rural villages therefore should be reduced and development on the edges of these settlements should be permitted.
We are also not convinced that faster housing delivery rates will be achieved within Northstowe, Waterbeach and Bourn Airfield given the historic delivery of these sites as reported in the Council’s housing land supply and delivery reports.

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

Please see attached document

See additional supporting planning commentary.

It is supported that sites should be developed that can be well-integrated with existing communities to reinforce the distinctive character of the city, towns and villages. It is acknowledged that in the urban areas, sites should be developed at densities making effective use of land (NPPF 2021; Paragraph 11(a). However, a focus on higher development density should not restrict development in sustainable locations in smaller settlements, where high density development may not be appropriate. We do not agree with the statement on page 30 of the First Proposals document “Using less land for development reduces our carbon emissions, and allows more space for nature and wildlife”. High quality development can also, at suitable lower densities, achieve carbon neutrality and provide enhancements for nature and wildlife, along with a wealth of other benefits.

Over-reliance on Existing Allocations
The proposed development strategy in the First Proposals document relies predominantly on existing allocations carried forward from the Adopted 2018 Local Plans and outstanding planning permissions, alongside a limited number of new sites.

The First Proposals document identifies 13 ‘new’ sites, totalling 11,640 homes. Of these, ‘new’ sites, three sites (Eddington - North West Cambridge, Waterbeach New Town and Northstowe), are all existing allocations. An additional 1,000 homes are proposed to be provided at Eddington, and Waterbeach New Town and Northstowe are assumed to achieve faster delivery rates of an additional 750 homes each over the plan period. The growth strategy also includes a site for 2,850 homes at Cambridge Airport comprising safeguarded land from the previous plan, which was also identified as an area for growth part of the Cambridge Local Plan (2003). As set out in greater detail below, noting the significant amount of time that this allocation has been identified within previous Local Plans, we raise significant concerns over the delivery of this site within the timescales anticipated, particularly noting larger sites by their very nature can take longer to be delivered. To encourage a more reliable delivery rate across the plan area we propose that additional sites are allocated to ensure the consistent delivery of dwellings to significantly boost the supply of homes as required by Paragraph 60 of the NPPF (2021).

It should be noted, therefore, that only 9 of these 13 sites are strictly ‘new’. In total the 9 sites will provide 6,246 dwellings (equating to approximately 12.8% of the total 48,840 homes to provide for).

The First Proposals document makes provision for a very limited number of new sites. It is clear that there is a heavy reliance on existing and previously identified sites rolled forward from the adopted Local Plans and many of these sites are on a large scale which also means they typically take longer to be brought forward.

Whilst we recognise that the inclusion of the 10% buffer seeks to provide the flexibility to deal with unforeseen circumstances, should any sites not be brought forward as planned, the heavy reliance on existing allocations and commitments is overly optimistic and along with the very limited number of new proposed site allocations, the 10% buffer is not considered sufficient. The buffer should be increased to a minimum of 20% and further sites allocated to ensure a robust strategy to account for both the current heavy reliance on existing allocations and planning permissions, as well as to accommodate any additional jobs growth as stated above. Such an approach has been adopted in other local authority areas, including most recently across Babergh and Mid Suffolk Local Authorities.
With regards to the deliverability of each of the proposed site allocations in the First Proposals document, we also have significant concerns with the deliverability of Cambridge Airport. The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan, allocated in the 2006 Local Plan and safeguarded in the 2018 Local Plans for development should the site become available.

As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030. The Topic Paper states at Page 116:

“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”. [Own Emphasis]

There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, particularly noting that Cranfield Airfield is only expected to become available from 2030 at the earliest.

Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF (2021).

It is also unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.

Relative to this and the delivery of North-East Cambridge is the requirement for relocating the existing Waste Water Treatment works at North-East Cambridge, the relocation and delivery of which could implicate the larger allocations’ housing rates/timing. Whilst it is understood that a site for the replacement facility has been identified and recent public consultation undertaken (with an intention for a DCO application to be made in 2022/23), it is acknowledged that the larger allocations will be dependent on the delivery of this new facility.

Over-reliance on Windfall Sites
In addition, we also have significant concerns regarding the heavy reliance on windfall within the development strategy, which comprises 5,300 dwellings and equates to almost 11% of the total number of homes to be provided. The NPPF (2021) definition of ‘Windfall sites’ is “Sites not specifically identified for development” whilst the First Proposal document defines ‘Windfall development’ as “Sites which have not been specifically identified as available for development in the Local Plan. They normally comprise previously developed sites that have unexpectedly become available”.

The Housing Delivery Study for Greater Cambridge (AECOM, October 2021) reports that Greater Cambridge has historically achieved a high rate of windfall development. Despite this, Greater Cambridge’s windfall reliance is considered overly high, particularly in light of the Councils’ apparent anticipation that these will mostly comprise previously developed sites. It is also noted that the settlement boundaries have been tightly drawn to the existing urban edges, which is unlikely to provide sufficient flexibility for (greenfield) windfall sites to come forward. It should also be noted that the Green Belt around Cambridge City will also represent a further constraining factor to the delivery of speculative development.

A more appropriate strategy is for the windfall requirement to be reduced and a greater range of sites explicitly allocated, including for the lower order settlements where the current development strategy is for very limited development.

Through the positive allocation of additional sustainable sites at the lower order settlements, this will ensure that the Greater Cambridge growth strategy is genuinely plan-led, as required by Paragraph 15 of the NPPF (2021) and ensure that such growth is supported by the appropriate infrastructure. In addition, by re-allocating a proportion of the anticipated windfall growth to specific sustainable sites, this will provide a greater level of certainty of the anticipated location of growth to the Councils’, developers and the local community compared with the current proposed strategy that will inevitably see a range of speculative development within the rural areas.

Lack of Development within the Villages
At page 75 of The Development Strategy Topic Paper (2021), it is stated:

“Our evidence, Sustainability Appraisal and consultation responses show that a strategy focussed on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure. As such we consider that villages should not be the primary focus for growth within the development strategy.”

Whilst it is not disputed that villages should not be the primary focus for growth, the current strategy is too restrictive and cannot be supported. Appropriate village development can be sustainable in terms of transport and carbon emissions and provide the necessary infrastructure requirements, as would be the case for Land West of London Road, Fowlmere.

The current development strategy, specifically the high percentage of growth to be delivered through windfall sites, is much more likely to lead to unsustainable village development than a strategy whereby the Council has control over ensuring village development is located where there is good access to a high quality public transport network and provides the required infrastructure.

Overall we have concerns regarding the robustness of the development strategy and its ability to bring sufficient land forward for development at a sufficient rate to address the OAN over the plan period as required by NPPF (2021) Paragraph 23.

The Draft Local Plan should increase the distribution of development across the plan area ensuring that a wide range of sites are proposed for development by including a greater number of site allocations in sustainable rural areas with good access to public transport and facilities, such as Land West of London Road, Fowlmere.

As identified by Paragraph 69 of the NPPF (2021), small and medium sized sites (such as Land West of London Road, Fowlmere) can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.

A growth strategy which solely focuses on growth within large scale settlements will also prevent the organic growth of more rural areas, which is needed in order to maintain the vitality of rural communities and support local services (NPPF 2021; Paragraph 79).

The Policy Direction:
As identified at page 29 of the First Proposals, Policy S/DS sets out the proposed strategy for the pattern, scale and design quality of places created in Greater Cambridge, “not only for the plan period but beyond to 2050”. With regards to this, we reiterate the comments made in response to Policy S/JH and the recommended requirement to extend the Plan period to 2050.

The preferred option for the proposed policy direction is a “blended strategy” (page 38 of the First Proposals) that is strongly focused on growth that directs 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 proposed development strategy seeks to take up “opportunities to use brownfield land” and “responds to opportunities created by proposed new infrastructure”. Firstly, the Commissioners wish to highlight that within the document, there is no clarity as to what is meant by development having “the least climate impact”, the term is not defined, leading to ambiguity for developers as to what proposals should be seeking to achieve. This is contrary to the requirements of paragraph 16(d) of the NPPF. Secondly, it is highlighted that the redevelopment of brownfield land can bring its own challenges with regards to sustainability; such sites are usually associated with higher abnormal costs which can sometimes put pressure on viability and the ability to deliver higher standard, sustainable developments.

With regards to the policy direction, the First Proposals document goes onto identify that the Councils propose to meet their housing and jobs needs by taking account of existing planning permissions, “alongside a limited number of new sites in the most sustainable locations”. Page 31 of the First Proposals identifies that in terms of the Councils’ new settlements, it is proposed that Cambourne will be evolved and expanded 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”.

Strategically Cambourne is ideally located, being approximately 15 kilometres to the west of Cambridge city centre and to the south of the A428, the highway that connects Cambridge with the A1 to the east.

In terms of proposed infrastructure works, there are two significant strategic transport schemes within proximity to Cambourne that are being developed by National Highways and East West Rail, to support future growth within the area. These relate to improvements to the A428 Black Cat to Caxton Gibbet and East West Rail between Oxford and Cambridge.

In terms of the A428 improvement works, National Highways has identified the upgrade of the A428 as a strategically important scheme to enable delivery of the Oxford-Cambridge growth corridor, the delivery of which is identified in National Highway’s ‘RISE2 5-year Delivery Plan’. The delivery of the scheme will have a significant beneficial impact on the potential for development within the locality and importantly for the Site. This is discussed further within the Transport Written Representation prepared by Pell Frischmann on behalf of the Commissioners, which accompanies this representation.

With regards to the East West Rail proposals, of relevance is the central section of the proposed East West railway line which is planned to link Bedford to Cambridge. This will form the final stage of the larger project to link Oxford and Cambridge. This scheme would include the construction of a new station at Cambourne. The route alignment and location of the station, which would either sit to the north-east or south-east of the Site, is yet to be announced. However, as detailed at page 23 within the East West Rail Company’s ‘Making Meaningful Connects Consultation Document’ (2021), it is anticipated that the scheme at Cambourne will support the potential for “new housing and communities within the area” and “bring economic growth to the community, creating more jobs and prosperity” through the new station.

Subsequently, the Commissioners strongly support the identification of growth at Cambourne.

The Source of Housing Supply:
Emerging Policy S/DS goes on to identify the total additional homes that need to be identified within the Plan; 11,640. This figure takes account of the identified housing need for the period 2020-2041 (44,400 homes), application of a 10% buffer (4,400 homes) to provide “flexibility to deal with unforeseen circumstances” and the current committed housing supply (37,200 homes).

As discussed in response to Policy S/JH, the Commissioners consider that the identified housing need of 44,400 should be reviewed and increased to reflect the higher growth scenario. We do not propose to repeat the reasoning for this in response to Policy S/DS (please refer to the Commissioners response to Policy S/JH for completeness) however, based on this scenario, the Commissioners consider that the total additional homes to be identified in the emerging Local Plan between 2020 and 2041 should be at least 21,650, as calculated below:

Plan Period (2020-2041): Housing need based on ‘higher’ growth (53,500 homes) + 10% buffer for flexibility (5,350 homes) – Current housing supply (37,200 homes) = 21,650 homes

If the Plan period were to be extended until 2050, as recommended in the Commissioners’ response to Policy S/JH, based on the high growth scenario, the total additional homes to be identified in the emerging Local Plan should be at least 46,917, as calculated below:

Recommended Plan Period (2020-2050): Housing need based on ‘higher’ growth (76,470 homes) + 10% buffer for flexibility (7,647 homes) – Current housing supply (37,200 homes) = 46,917 homes

Even if the Plan period were to remain as currently proposed (2020-2041), this results in the Council needing to identify a further 10,010 homes. This is a significant increase (approximately 46%) from the current requirement, which the Commissioners consider the Councils need to identify in order for the Plan to accord with national policy, specifically paragraph 20, which requires strategic policies to “make sufficient provision” for (inter alia) housing. Clearly, if the Plan period were to be increased to 2050, the requirement would further drastically increase, with the Council needing to identify 35,277 new homes in addition to the 11,640 identified within the First Proposals.

The sources to meet the housing requirement as set out within the First Proposals are included within the table that follows the ‘Homes to provide for’ table within the document. Upon review of the sources of supply table, the identified supply results in only 11,596 homes being identified between 2020 and 2041, 44 homes less than the requirement as it currently stands. Therefore, and notwithstanding the Commissioners comments regarding the need to significantly increase the housing requirement, the Councils should be at least identifying sufficient supply to meet the identified requirement.

The Commissioners support the identification of new development at Cambourne within the sources of supply table. Page 38 of the First Proposals relates to the Councils’ justification for Policy S/JH and it states, “the most sustainable location for strategic scale development away from Cambridge is to expand on existing development in the Cambourne area, taking advantage of the significant benefits that will be provided by the proposed East West Rail station as well as the improvements already anticipated from the Greater Cambridge Partnership’s Cambourne to Cambridge scheme. This significant improvement in public transport provides an opportunity to grow an existing town, enhancing the critical mass of population, employment and services available locally to those communities”. The evidence that has underpinned this justification is detailed at page 73 of the Councils’ Development Strategy Topic Paper. As discussed in response to Policy S/SD and explored further in the upcoming response to Policy S/CB, the Commissioners concur with this assessment.

The policy goes onto identify that 1,950 homes of the 11,640 additional homes to be identified within the Local Plan, as required by the Councils, should be directed to Cambourne. This equates to approximately 17% of the overall additional homes to be identified supply. However, what is not clear within the First Proposals document is which sites have been included within the current housing supply figure. Therefore, when reviewing the First Proposals document alone, it lacks transparency as to how the overall figure for future development at Cambourne during the Plan period accords with the Councils’ development strategy.

Based on the current 17% distribution figure as discussed above, if the housing need were to be based on the high growth figure resulting in the Councils needing to identify 21,650 additional homes in the currently proposed Plan period, then this would equate to approximately 3,600 new homes to be planned for at Cambourne. This would further increase if the Plan period were to be extended to 2050. Subsequently, the Commissioners’ consider that the Councils should be planning for a significant extension or new settlement within the area. The Commissioners’ Site, The Kingsfields, has the ability to accommodate such growth. As set out within the Vision Document that accompanies these representations, it is considered that the Site could accommodate circa. 4,500 new homes.

Whilst the First Proposals document includes an infographic showing the proposed housing trajectory for the different types of supply (page 35), it does not include a trajectory setting out the anticipated rate of development for specific sites, nor does it consider the reasons as to why this exclusion is considered appropriate. This is a requirement of national policy (as detailed at paragraph 74 of the NPPF) and as such, the Commissioners recommend that the Councils address this within the emerging Local Plan’s next iteration.

It is supported that sites should be developed that can be well-integrated with existing communities to reinforce the distinctive character of the city, towns and villages. It is supported that in the urban areas, sites should be developed at densities making effective use of land (NPPF Paragraph 11(a). However, a focus on higher development density should not restrict development in sustainable locations in smaller settlements, where high density development may not be appropriate. We do not agree with the statement on page 30 of the First Proposals document “Using less land for development reduces our carbon emissions, and allows more space for nature and wildlife”. High quality development can also achieve carbon neutrality and provide enhancements for nature and wildlife, along with a wealth of other benefits.

Over-reliance on Existing Allocations
The proposed development strategy in the First Proposal document relies predominantly on existing allocations carried forward from the Adopted 2018 Local Plans and outstanding planning permissions, alongside a limited number of new sites.
The First Proposals document identifies 13 ‘new’ sites, totalling 11,640 homes. Of these, ‘new’ sites, three sites (Eddington - North West Cambridge, Waterbeach New Town and Northstowe), are all existing allocations. An additional 1,000 homes are proposed to be provided at Eddington and Waterbeach New Town and Northstowe are assumed to achieve faster delivery rates of an additional 750 homes each over the plan period. A site for 2,850 homes at Cambridge Airport comprising safeguarded land from the previous plan, which was also identified as a growth area as part of the Cambridge Local Plan (2003). As set out in greater detail below, noting the significant amount of time that this allocation has been identified within previous Local Plans, we raise significant concerns over the delivery of this site within the timescales anticipated, particularly noting larger sites by their very nature can take longer to be delivered. To encourage a more reliable delivery rate across the plan area we propose that additional sites are allocated to ensure the consistent delivery of dwellings to significantly boost the supply of homes as required by Paragraph 60 of the NPPF (2021).
It should be noted, therefore, only 9 of these 13 sites are strictly ‘new’. In total the 9 sites will provide 6,246 dwellings (equating to approximately 12.8% of the total 48,840 homes to provide for).
It is clear that the First Proposals document makes provision for a very limited number of new sites. There is a heavy reliance on existing and previously identified sites rolled forward from the adopted Local Plans and many of these sites are on a large scale which also means they typically take longer to be brought forward.
Whilst we recognise that the inclusion of the 10% buffer seeks to provide the flexibility to deal with unforeseen circumstances should any sites not be brought forward as planned, the heavy reliance on existing allocations and commitments is overly optimistic and along with the very limited number of new proposed site allocations, the 10% buffer is not considered sufficient. The buffer should be increased to a minimum of 20% and further sites allocated to ensure a robust strategy to account for both the current heavy reliance on existing allocations and planning permissions, as well as to accommodate any additional jobs growth as stated above. Such an approach has been adopted in other local authority areas, including most recently across Babergh and Mid Suffolk Local Authorities.
We have concerns with the deliverability of Cambridge Airport. The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan and safeguarded in the 2018 Local Plans for development should the site become available. As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030. The Topic Paper states at Page 116:
“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”.
There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, when it is only expected to become available from 2030 at the earliest.
Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF.
It is also unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.
Relative to this and the delivery of North-East Cambridge is the requirement for relocating the existing Waste Water Treatment works at North-East Cambridge, the relocation and delivery of which could implicate the larger allocations’ housing rates/timing. Whilst it is understood that a site for the replacement facility has been identified and recent public consultation undertaken (with an intention for a DCO application to be made in 2022/23), it is acknowledged that the larger allocations will be dependent on the delivery and relocation of this new facility.

Over-reliance on Windfall Sites
In addition, there are concerns regarding the heavy reliance on windfall within the development strategy, which comprises 5,300 dwellings and equates to almost 11% of the total number of homes to be provided. The NPPF definition of ‘Windfall sites’ is “Sites not specifically identified for development” whilst the First Proposal document defines ‘Windfall development’ as “Sites which have not been specifically identified as available for development in the Local Plan. They normally comprise previously developed sites that have unexpectedly become available”.
The Housing Delivery Study for Greater Cambridge (AECOM, October 2021) reports that Greater Cambridge has historically achieved a high rate of windfall development and we have not sought to interrogate this evidence at this stage to confirm whether this conforms with NPPF Paragraph 71. Nonetheless, this windfall reliance is considered high, particularly in light of the Councils’ apparent anticipation that these will mostly comprise previously developed sites. It is also noted that the settlement boundaries have been tightly drawn to the existing urban edges, which is unlikely to provide sufficient flexibility for (greenfield) windfall sites to come forward.
A more appropriate strategy is for the windfall requirement to be reduced and a greater range of sites explicitly allocated, including for the lower order settlements where the current development strategy is for very limited development.
Through the positive allocation of sustainable sites at the lower order settlements, including Minor Rural Centres, this will ensure that the Greater Cambridge growth strategy is genuinely plan-led, as required by Paragraph 15 of the NPPF (2021) and ensure that such growth is supported by the appropriate infrastructure. In addition, by re-allocating a proportion of the anticipated windfall growth to specific sustainable sites, this will provide a greater level of certainty of the anticipated location of growth to the Councils, developers and the local community compared with the current proposed strategy that will inevitably see a range of speculative development within the rural areas.
Land to the East Side of Cambridge Road, Melbourn offers a logical and sustainable location for residential growth. The Site’s position on the edge of Melbourn provides a sustainable location for new development with local public transport connections and pedestrian and cycle links, as well as proximity to nearby local amenities including jobs, services and facilities within the village centre. The Site also lies in close proximity to Melbourn Science Park, which has recently achieved approval for a further extension, providing employment for a number of companies engaged in pharmaceuticals, biochemistry and mechanical engineering.

Lack of Development within the Villages
At page 75 of The Development Strategy Topic Paper (2021), it is stated:
“Our evidence, Sustainability Appraisal and consultation responses show that a strategy focussed on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure. As such we consider that villages should not be the primary focus for growth within the development strategy.”
Whilst it is not disputed that villages should not be the primary focus for growth, the current strategy is too restrictive and cannot be supported. Appropriate village development can be sustainable in terms of transport and carbon emissions and provide the necessary infrastructure requirements, as would be the case for land to the east side of Cambridge Road, Melbourn.
In fact, the current development strategy with the high reliance on windfall sites is much more likely to lead to unsustainable village development than a strategy where the Council has control over ensuring village development is located where there is good access to a high quality public transport network and provides the required infrastructure.
Overall we have concerns regarding the robustness of the development strategy and its ability to bring sufficient land forward for development at a sufficient rate to address the OAN over the plan period as required by NPPF (2021) Paragraph 23.
It is considered that there should be a greater focus on a wide range of sites being brought forward for development, by including a greater number of site allocations in sustainable rural areas with good access to public transport and facilities, such as land to the east side of Cambridge Road, Melbourn.
Smaller sites can often be brought forward quicker and provide greater certainty of delivery, particularly in the early part of the plan period. As acknowledged by Paragraph 79 of the NPPF (2021), housing in rural areas can maintain the vitality of rural communities and provide opportunities for villages to grow and thrive, especially where this will support local services.
As discussed later in this Section, it is clear that Melbourn is a sustainable location and able to support additional housing growth, which is evidenced through the two allocations proposed for the settlement. Melbourn should, however, be allocated a greater proportion of growth that is comparable to its identification as the largest village in the south west of the district (Development Strategic Topic Paper 2021; 262).

LVA are of the view that the Local Plan should allocate enough deliverable small to medium sized sites for development so Cambridge City Council and South Cambridgeshire District Council are not heavily reliant on the delivery of large strategic sites. There appears to be a disproportionate reliance on such sites to meet the 11,640 additional homes that are required in the period 2020-2041. 11,200 of these are quoted as coming from just six sites (3,900 at North East Cambridge, 2,850 at Cambridge Airport, 1,000 at North West Cambridge, 750 at Northstowe,750 at Waterbeach New Town, and 1,950 at Cambourne).

Small to medium sized sites can make an important contribution to meeting the housing requirement of an area as they are generally built out quicker than larger sites (as per Paragraph 68 of the NPPF). In this regard, they are an important element of improving the supply of sites. This is particularly the case for Cambridgeshire which contains an area in which there are sustainable settlements and villages where smaller greenfield sites tend to be more readily available than brownfield sites and large strategic sites.

LVA believe there should be a more detailed focus on villages within the Local Plan and a mechanism introduced to allow for larger levels of development in these locations. The key point in LVA’s view is that it is accepted that interrelationship with surrounding areas is material and that it is accepted that residents in village locations must rely upon services and facilities outside of their particular settlement to meet all of their needs. This is not uncommon and is generally how most residents in villages within Cambridgeshire meet their daily needs. In such villages, a reliance on the private car is to be expected and that development in these locations should not be prohibited on this basis. More distinction needs to be given as between rural settlement as opposed to rural areas.

LVA consider it important to permit all villages to grow proportionately and enhance the quality of life for all generations. Not to plan and allow housing in these areas will lead to ever reducing demands for schooling, employment, and shops services as the aging population grows in such settlements. Further, we will see a continuing trend of aging dependent populations in villages lacking the care support of having families nearby as they will be forced to move to larger settlements due to a lack of new housing options especially those of an affordable nature that are typically found within open market led schemes.

Housing Need - The Councils Homes topic paper states that as of April 2021 there were 1,603 applicants on the Housing Register for South Cambridgeshire and 1,919 applicants for Cambridge (Source: Home-Link Choice Based Lettings Scheme Register). There is a need for affordable housing from within the local community in almost every village in South Cambridgeshire. The Housing Statistical Information Leaflet (South Cambridgeshire District Council, December 2019) shows that there are no Housing Register applicants in only five out of the 102 villages in the district and the Housing Register only captures part of the overall need. Market housing is also often needed to support the delivery of affordable housing, and this would bring a significant benefit.

Working from Home needs to be catered for - One of the impacts of the COVID-19 pandemic over the past 21 months has been the introduction of an era of home working and it naturally follows that this flexibility will give rise to workers feeling less inclined to live close to their workplace, which are commonly in urban areas. They will instead seek to retreat to life in more rural areas that provide better quality living and amenity spaces, with more value for their money after a year spent at home. Furthermore, after a year of isolation from friends and family, it is inevitable that people will want to live nearer to their loved ones, namely who are elderly or vulnerable and residing in villages. The Local Plan therefore must acknowledge and cater for number of city and town residents moving to more villages due to the effects of COVID-19.