S/DS: Development strategy

Grange Farm -- an exemplary new settlement of 4,000 to 5,000 homes -- is being promoted by The Grange Farm Partnership on land to the south-east of Cambridge close to several major employment hubs. Grange Farm was not on the agenda when the Regulation 18 plan was prepared, but now that it is, it is the hope of the developers that it will be taken as the seriously beneficial proposition that it is, and absorbed into the Regulation 19 Local Plan in due course. Grange Farm has also been submitted in response to the parallel Call for Sites exercise.

TMLC supports the proposed policy direction 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.

TMLC also supports the delivery of sites on the edge of Cambridge given they are sustainable locations to existing jobs, services, infrastructure, and transportation.

TMLC disagrees that Greater Cambridge housing need alone doesn’t provide the ‘exceptional circumstances’ required in national policy to justify removing land from the Green Belt on the edge of
Cambridge in this Local Plan (mentioned on page 39 and 45). Our position on why the release of Trumpington South from the Green Belt for housing is acceptable is discussed below and within the following sections: ‘Edge of Cambridge – General Comments’, S/CBC, S/EOC, BG/EO.

TMLC supports the need for the delivery of new strategic water supply infrastructure and will follow the development of the Water Resources East (Water Management Plan) for the region.

TMLC supports the delivery of Cambridge South Train Station and East West Rail. TMLC also supports Greater Cambridge strategy to plan new growth around the location of existing and committed transport schemes which will help provide sustainable transport options for residents and help the climate change aims of this emerging Local Plan (this is backed up by the majority of responses to the First Conversation consultation to releasing land from the Green Belt if it provides a more sustainable development option by reducing travel distances, helping us reduce our climate impacts)

We support the directing of growth towards locations that have the least climate impact, and where active and public transport are readily available. Development should be planned with good existing and proposed public transport, particularly in locations close to existing employment clusters. With the benefit of planned public transport improvements, the Campus is developing into an exemplary location at which to concentrate development.

Re: Policy S/DS: Development Strategy, in respect to ‘Housing Supply’ (and in particular in respect to ‘The Buffer’, and ‘The 5-Year Housing Land Supply’), and ‘Development Strategy / Spatial Distribution’.

The plans should incorporate even less focus on the Green Belt and villages than they currently do. Greater focus on new settlements / communities and expanded development of existing sites is the most appropriate way to deliver increased housing stock. We are not in favour of development on any kind of significant scale in any local villages. Above all though, villages within the Green Belt should be spared from any further development
The potential of existing projects within the Cambridge city limits should be maximised. However, growth in new settlements such as Cambourne, Waterbeach and Northstowe, which can be designed with excellent transport links (including East-West Rail) are by far the best approach to increased housing delivery. SCDC’s recognition in the First Proposals that the plan should include very limited (or ideally no) development in existing villages is fully supported.

The spatial strategy is urban focused, relying 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). At this stage there is no evidence to support 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 sites need to be allocated for housing to ensure the required annualised supply of housing of 2,326 homes can be achieved.

The strategy places little emphasis on existing villages to support the spatial strategy, particularly during the early years of the plan when these large sites are more likely to be prone to delays and slippage in the anticipated trajectory rates.

The plan should identify additional smaller sites that are capable of delivering homes over a 1-2 year period to help accelerate growth and provide greater certainty around housing supply over the plan period and beyond

This would also ensure that the plan allows choice and opportunities for smaller developers and housebuilders

Introducing further land supply at the most sustainable villages will not risk creating a dispersed strategy for growth, provided such sites are located in villages which already benefit form established supporting transport and social infrastructure and/or where other facilities outside but accessible to the village are readily available.

Great Shelford is one of those settlements where it is benefits from being one of the most sustainably located villages due to its relationship with Cambridge City. It has the clear advantage of having key infrastructure within the village but is also accessible to the wider facilities on offer in Cambridge.

Development at Great Shelford already forms part of the First Proposals Strategy. This principle is agreed and supported. It is appropriate to consider GB release in exceptional circumstances and the village is a strong candidate for accepting more growth. However, the choice of site is not substantiated by the evidence base. We comment on the proposed site allocation in the relevant section S/RRA.

Great Shelford is an appropriate location for growth and this should be maintained in the draft GCLP going forward. Should additional land be required, it remains a suitable place to accommodate more housing to 2041.

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. The evidence does not clearly show demonstrate that the trajectory assumptions are realistic. Some additional sites will be required to maintain flexibility and Great Shelford is better placed to accommodate additional growth without prejudicing the overall spatial objectives.

We do not consider the scope of Policy S/DS Development Strategy to be wide enough to allow for potential development at Dobbies Royston Garden Centre (which is allocated within the Rural Area). This is because the proposed Local Plan states only ‘a very limited amount of development’ is proposed in the rest of the rural area. As such the list of permitted categories should be amended to include ‘horticulture and garden centres.' The rational for doing so is included at 'Rest of the rural area - General Comments.'

We question the approach taken to the distribution of growth within Greater Cambridge, and whether it will meet the objectively assessed housing need. We do not consider this to be the case, predominantly due to the uncertainty surrounding delivery of several of the proposed site allocations. We question how 1,950 homes within the new settlement at Cambourne could be included within the supply, given no specific site has been identified for allocation, and that delivery within this region is wholly dependent upon the East West Rail route and proposed Station at Cambourne, the route and location of which are as yet unconfirmed, as is the anticipated delivery date.

Paragraph 4.26 of the Sustainability Appraisal (SA) quotes the commentary of the Housing Delivery Study (2021), which highlights a risk of relying on delivery from North East Cambridge and Cambridge Airport towards the end of the Plan period, given the uncertainties relating to the relocation of the wastewater treatment works and the relocation of Marshall’s operations respectively. Whilst the Plan provides confirmation as to the likelihood of the site being available from 2030, it is anticipated that the site will be capable of delivering 2,850 dwellings by 2041. We question what evidence exists to support such an ambitious assumption, particularly in light of the conclusions within the Housing Delivery Study (2021) that a traditional market-led approach would be unlikely to exceed an average of 300dpa over the duration of the build-out period. Furthermore, the Study also notes that delivery increases over time to a ‘peak’ in the middle before decelerating. As such, even with an optimistic assumption of completions within 2030, a minimum annual delivery rate of 259 dwellings would be required, including at year 1, which is not realistic.

Whilst we do not dispute the proposed allocation at Cambridge Airport, we do not consider there is sufficient evidence to support the delivery of 2,850 dwellings within the Plan period. As such, the Plan should identify additional sites for allocation to ensure the Plan is capable of meeting the objectively assessed housing need, and to ensure there is sufficient flexibility within the supply should any sites not deliver as expected.

The proposed strategy includes a heavy reliance upon large, strategic sites. The table on pages 77 and 78 of the Development Strategy Topic Paper calculates that the number of additional homes to be identified through the Plan, in addition to existing commitments, is 11,642. The additional sources of supply identified through the Plan include accelerated delivery rates at existing strategic sites, as well as a number of additional large sites. Of the total additional sources of supply identified, which we note is marginally below the identified requirement, 396 homes of the total 11,596 are on small-medium sites, equating to 3.4% of the total supply. Paragraph 68 of the NPPF requires planning policies to identify a sufficient supply and mix of sites, including specific, deliverable sites for years 1-5 of the Plan period and specific, developable sites or broad locations for growth for years 6-10 and where possible, years 11-15 of the Plan. We consider the strategy is focussed on delivery within the latter part of the Plan period, with insufficient small and medium sites allocated to ensure the housing need is met during the short-medium term. Paragraph 69 of the NPPF confirms the important contribution that small and medium sites can make to meeting the housing requirement of an area.

As set out in our comments on the Sustainability Appraisal (SA), Option 5 – dispersal – villages was subject to a number of broad assumptions which we consider resulted in an overly negative score and unduly influenced the limited distribution of growth to village locations. Our concerns are set out in full in our comments on the SA.

I strongly endorse what GCSP says in the section headed “ensuring a deliverable plan - water supply”. I would, however, go further because, as recognised in the 2020 Greater Cambridge Chalk Streams Project Report commissioned by Cambridge City Council and Cambridge Water Company, restoration of the chalk streams is needed. This seems to me to be potentially relevant to planning permission conditions and s106 agreements. Further, the issue of sewage outflows, for example in Haslingfield, needs to be addressed. In addition, it is not clear to me whether the assessments made for GCSP, which underlie its conclusions, take into account potential water usage during construction, including of large infrastructure projects, such as East West Rail and CSET. Finally, I agree with recommendation 13 of the Cambridgeshire and Peterborough Independent Commission on Climate’s October 2021 Final Report.

There are two other infrastructure areas in respect of which I would expect to see similar assessments and these are education and health infrastructure and, most especially hospitals. Whilst neither goes to the immediate deliverability of functional homes (unlike water) both, like transport, go to “everyday quality of life”. The former, and primary healthcare establishments, are mentioned in the infrastructure delivery plan-related November 2020 evidence base document, but hospitals are not mentioned in it at all. Why?

As the county council’s response to the Ox-Cam Arc consultation makes clear, the precise scope of educational establishments, funding of improvements or new establishments and timing are to a considerable extent, outside their control. This is also true of hospital infrastructure and there are very considerable issues - https://www.bbc.com/news/59372348. In addition, it is clear that every one of the three hospital projects currently proposed by CUHFT will require a very significant element of non-governmental funding and that the realistic scope and timing of each is most uncertain (despite the timing indicated on the websites for the cancer and children’s hospitals and in the Cambridge Biomedical Campus Vision 2050 (“Vision 2050”) - see its page 34, which includes one of the very few mentions of the hospitals in this document, despite their central importance to the community and to the current success of the biomedical campus). Indeed, it is unclear how many of them are realistic.

Please find attached the response to Policy S/DS on behalf of Axis Land Partnership who are promoting land at Boxworth End, Swavesey.

Full details are provided in the supporting main response document.

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


Significant transport investment is planned around Papworth, which will further support the
proposed sustainable expansion of the village. Transport connections to Papworth are set out in
more detail within the accompanying Transport Appraisals prepared by EAS. There are a number
of strategic schemes coming forward which will improve mobility in the area and better
connections with key service centres. Furthermore, bringing forward development in Papworth
would act as a catalyst and a source of additional investment to further improve local
infrastructure to connect Papworth to the south and increase the opportunities and likelihood for
Papworth residents and workers to travel, at least in part, by sustainable modes of travel:

● The completion of the A14 re-alignment and improvement works;
● The East-West rail preferred route has been announced which will link with Cambourne
which is just 4km south of Papworth (see figure 1 below);
● A428 Highways England improvement proposals which includes new footpath and cycleway
connections at the Caxton Gibbet junction and the re-alignment of the junction to reduce
congestion in the area and improve journey times along this key transport route;
● The Greater Cambridge Partnership’s Cambourne to Cambridge Transport project which will
improve transport connections. As part of these proposals, the proposed Scotland Farm Park
and Ride is currently the preferred option. Scheme completion is currently forecasted in 2024;
and
● The Combined Authority Mayor committing to enhanced bus provision to better connect
villages.

The Cambridgeshire Long Term Transport Strategy 2011-2031 supports this and identifies the
major infrastructure requirements that are needed to address existing problems and capacity
constraints on Cambridgeshire’s transport network, and the further infrastructure that is required
to cater for the transport demand associated with planned growth. It includes the following
schemes will improve the connectivity of Papworth Everard:
● Strategic and local cycle network improvement between Huntingdon-Papworth EverardCambourne;
● Area action plans for the A14 Trunk Road in Huntingdonshire and South Cambridgeshire
delivering;
- New A14 trunk road, local road capacity, cycle and pedestrian routes;
- Area action plan for the A428 Trunk Road in Huntingdonshire and South
Cambridgeshire. This includes:
- A428 Caxton Gibbet to Black Cat dualling by 2021, including a grade separated
junction at the A1 Black Cat roundabout;
- Bus priority measures Caxton Gibbet – West Cambourne, A428 to Bourne airfield;
A428 park and ride; and
- A428 and A1198 junction improvements.

Cambourne to Cambridge Public Transport Route and New Park and Ride Site: A number of
options are being considered by the Greater Cambridge Partnership (GCP) to improve journeys
from the west of Cambridge into the city. This follows a successful public consultation with
options soon to be presented for approval to the GCP Board for approval.

In its current form the village of Papworth is not providing a strong opportunity to reduce car trips
within the district; however, the provision of links to the south will improve this. New development
could be part of the solution to promote and help deliver more sustainable travel links for the
benefit of all.

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

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

Notwithstanding this clear direction in national policy, the emerging Local Plan makes very few
additional allocations in the rural area and VJF objects to this approach. This approach threatens
the vitality of villages within the rural area and stifles opportunities for further growth and
supporting local services. The allocation of additional sites in the rural area will also help to
ensure that the housing supply for the Local Plan is balanced and robust, reducing the reliance
on strategic sites and the limited allocations in villages. As such, the Development Strategy
should include for further allocations in the rural area to ensure that a sound spatial strategy is
developed and delivered.


It is important that any additional allocations accord with the principles of the proposed
development strategy. Land at Papworth accords with the proposed development strategy as
follows:
● Directing development to where active and public transport is the natural choice:
− Future transport links with the east-west transport corridor improvements will bolster
sustainable travel opportunities to Papworth.
● Where green infrastructure can be delivered alongside new development:
− The proposed development of the site would be landscape led with potential for benefits
to the green infrastructure that exceed policy requirements, including new swathes of
public open space
− The site is predominantly agricultural land and is low ecological value. Through
enhancements the proposals present an opportunity to deliver a biodiversity net gain of at
least 20%.

We support the role smaller sites can play for housing and employment, where they are well-integrated with existing neighbourhoods. This should relate to all types of housing and recognise the role mixed use housing and employment/education plays in achieving the Government’s aims of achieving sustainable development on previously developed sites, including the role those types of sites within the urban area play in reducing pressures for greenfield development.

We also support windfall development, especially where it assists in achieving the above aims, including the 11,640 homes to be identified. It is considered that the site (St Matthew’s Centre, Sturton Street, as identified in the Eastern Gate Supplement Planning Guidance as a potential development site {page 9}) should be included now as a mixed use education/student housing development capable of delivering 80 new purpose built student homes and enhanced and purpose built facilities for the Cambridge School of Visual and Performing Arts.

As set out in Policy H/SA, any student accommodation delivery on the site will assist in the delivery of overall housing as required by the Greater Cambridge Local Plan, as it potentially releases existing private housing stock used by students.

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.

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.

Within the Cambridge Urban Area, one new housing allocation is proposed, which has the capacity to deliver approximately 12 new homes. The remaining allocations are brought forward from the 2018 Local Plan and many of these were previously allocated in the 2006 Local Plan. As such, there is a view that if the sites have not been brought forward successfully in the last 15 years, given the increased demand for housing in the City, then it is questionable whether they will be in a position to deliver much needed housing during the next Plan period.

The remaining housing delivery is allocated to areas of major change and larger urban extensions on the edge of Cambridge at North East Cambridge, Cambridge East and North West Cambridge. Whilst the approach to these sites again is supported by Clare College, it is considered that these larger sites need to be complemented with a selection of sustainable small and medium scale sites which have the prospect of being delivered early within the Plan period, such as those within the ownership of Clare College and identified at the beginning of these representations.

Such housing delivery would help meet local housing needs over the Plan period, providing a greater variety in the type and location of development delivered. 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 Councils strategy focuses on the delivery of very large sites with few smaller allocations. Clare College would suggest that this approach may mean that particularly in the earlier years of the Plan period, the Council will struggle to deliver the required levels of housing, because it takes longer for larger sites to begin completing new homes. Therefore, Clare College would like to suggest that the Council consider an approach whereby these larger sites are complemented by a range of sustainable smaller and medium scale sites, both within the City Centre as well as in rural area of South Cambridgeshire such as their sites at Bentley Road and Great Chesterford.

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. Land at Bentley Road (HELAA Ref: 48066) is adjacent to the Guided Busway and associated pedestrian and cycle route, providing direct access to Cambridge Station, the City Centre and the Cambridge Biomedical Campus. As such, it is a highly sustainable location, close to services and facilities, a wide range of employment opportunities and public transport connections to London and other regional centres. Likewise, Land at Great Chesterford (HELAA Ref: 47934) is in very close proximity to the railway station at Great Chesterford, with direct connections to London, Cambridge and Bishop Stortford/Stansted Airport. The settlement of Great Chesterford itself benefits from a wide range of services and facilities as well as employment opportunities. Furthermore, it is well connected to the research and development institutes at Babraham, Great Abington and Hinxton. As such, Clare College would suggest that both of these sites are well placed to assist the Council in achieving their top priority to reduce carbon emissions. They should both be considered further in the next stage of the Local Plan and as smaller sustainable sites, which could be allocated to deliver much needed housing early in the Plan period.

OBJECT

Ely Diocesan Board of Finance (EDBF) has promoted a number of sites through the emerging GCLP process.

EDBF’s representations to the GCLP Preferred Options consultation refer to two of those sites, as follows:

• Land at Hinton Way in Stapleford (HELAA Site Ref. 40369) for residential development, and adjacent to the preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford); and
• Land off Butt Lane in Milton (Site Ref. 40365) for employment development on remainder of land adjacent to approved Cambridgeshire Constabulary Police Station.

The sites are currently located in the Green Belt. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster (for the Stapleford site) and the rest of the rural area (for the Milton site), and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Great Shelford, and the decision to not consider the relocation needs of existing businesses within the North East Cambridge area. It is requested that both sites are released from the Green Belt.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents. 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 Northstowe and Waterbeach.

The redevelopments at North East Cambridge and Cambridge East are complex and involve the relocation of the existing uses and are likely to take much longer to deliver than currently predicted; 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.

Most of the new settlements 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 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.

For these reasons, it is requested that additional small and medium allocations including land off Hinton Way in Stapleford should be identified in emerging GCLP, which can be delivered easily and provide policy compliant levels of affordable housing.

The Proposed Submission version of the North East Cambridge AAP is currently being reported through various committees of Cambridge City Council and South Cambridgeshire District Council, in advance of public consultation in early 2022.

It is noted that a number of amendments have been made to the AAP, including a 25% reduction in the amount of new commercial (office) floorspace to be provided across the North East Cambridge area and an associated reduction in the number of jobs to be provided from 20,000 to 15,000 jobs. It is intended that there would be no net loss in the quantum of existing industrial (Class B2 and B8) floorspace as a result of the regeneration of the North East Cambridge area. Although it is acknowledged in the AAP that some existing businesses within North East Cambridge would need to relocate as part of the redevelopment.

The Councils intend to support those existing businesses that will be displaced from North East Cambridge, including help to find alternative sites. However, finding alternative sites is likely to be difficult, partly because of the number of businesses that are likely to be displaced either permanently or for a temporary period, and partly because some business will want to remain close to the edge of Cambridge to be close to customers and employees. It is suggested that the remaining land off Butt Lane in Milton, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, could be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area, as well as for general employment purposes.

The promoted land by EDBF is currently located within the Green Belt, and in these representations it is requested that the Stapleford site is released to accommodate housing and affordable housing, and that the Milton site is released to accommodate employment uses including those business displaced from the North East Cambridge area.

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 at Stapleford and Milton, which are related to the significant identified need for housing and affordable housing in Greater Cambridge and the need to support economic growth (for Stapleford), and the specific need to provide land for existing businesses that will displaced by the redevelopment at North East Cambridge (for Milton).

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 identify 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 of the NPPF 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 the 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 EDBF land off Hinton Way in Stapleford 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. The EDBF land off Butt Lane in Milton is adjacent to Milton Park & Ride and is well connected to existing cycle routes, and there are proposed public transport and walking/cycling improvements proposed in the area including connections to Waterbeach, Milton and North East Cambridge. Therefore, the release of the land off Hinton Way and off Butt Lane from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

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

Great Shelford and Stapleford contain a good range of services and facilities, reflecting their status as a Rural Centre in the settlement hierarchy. For example, they contain a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants.

The promoted development by EDBF at land off Hinton Way in Stapleford would support the existing services and facilities. Shelford Station is located close to the site. There are bus routes on Hinton Way, Mingle Lane, Station Road and Cambridge Road, all of which are close to the site. There are cycle routes through Stapleford and Great Shelford into Cambridge. The route for the proposed Cambridge South East Transport project by the Greater Cambridge Partnership is located to the north west of the site, and there are proposed stops at Hinton Way and Haverhill Road that would be within close proximity of the site. Therefore, the promoted development by EDBF at land off Hinton Way in Stapleford 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 current need for 28 affordable dwellings in Stapleford for those with a local connection to the village, and an identified need in Great Shelford for 47 affordable dwellings – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. It should be noted that additional affordable housing needs will arise in Stapleford and Great Shelford in the future and during the plan period to 2041. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Great Shelford and Stapleford should only seek to meet locally derived affordable housing needs but also those district-wide needs of Greater Cambridge. The preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford) for 100 dwellings would meet the current identified needs for affordable housing of Stapleford, but not district-wide or future needs. The Stapleford and Great Shelford Neighbourhood Plan is at an early stage and a draft plan has not yet been published, so it is not clear whether this document will seek to address future and district-wide affordable housing needs through additional allocations; although it is noted that the emerging GCLP does not anticipate any future amendments to the Green Belt boundary to accommodate those affordable housing needs.

It is for these reasons that EDBF is requesting an additional allocation at land off Hinton Way in Stapleford.

It is requested that additional housing allocations should be made in the more sustainable villages in the Rural Southern Cluster and on the edge of Cambridge including at Stapleford, 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 a need for affordable housing in the villages which would only be partially met.

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 and the new communities on the edge of Cambridge are reviewed so that they are more realistic.

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 housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including at land off Hinton Way in Stapleford, 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 a current need for affordable housing both in the village and district-wide and there will be a need in the future too.

It is requested that the emerging GCLP should identify additional employment land allocations to meet the needs of businesses that will be displaced as a result of the redevelopment at North east Cambridge. The remaining land off Butt Lane in Milton, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, could be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area, as well as for general employment needs.

OBJECT

North BRLOG is promoting land at South West Cambridge for a landscape-led urban extension to Cambridge, and in representations it is requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy overall and the strategy for the edge of Cambridge, including the over reliance on the existing new settlements and new neighbourhoods to meet the housing requirements, and the decision to not release additional land from the Green Belt on the edge of Cambridge despite these being identified as sustainable locations.

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

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum. The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates for Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. 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.

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. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG and submitted with Issues & Options representations) highlighted the difficulty that the existing new settlements have in providing sufficient affordable housing, and also that there is sufficient residual value in strategic greenfield sites on the edge of Cambridge to support planning obligations and policy requirements including affordable housing in full. It is clear that the existing and planned new settlements and new communities on the edge of Cambridge are not and will not provide enough affordable housing, which should be a major 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 other strategic sites, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including the promoted development by North BRLOG at South West Cambridge.

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 around Cambridge, which are related to the significant need for housing and affordable housing in Greater Cambridge, and the need for additional housing to support the economic growth of Greater Cambridge. The cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high too. The Housing Needs of Specific
Groups Report (GL Hearn October 2021) provides further information on affordability and affordable housing needs. Table 42 of the GL Hearn Report identifies an affordable housing need of 199 dwellings per annum for Cambridge and 105 dwellings per annum for South Cambridgeshire, which equates to a combined total of 304 affordable dwellings per annum or a total of 6,384 dwellings during the plan period from 2020 to 2041. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely a large proportion of those journeys are undertaken by car this would add to traffic congestion and air pollution. The promoted development by North BRLOG at South West Cambridge would include affordable housing, and is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge and to other employment opportunities available in the City. The promoted development at South West Cambridge would be consistent with the exceptional circumstances to justify the release of land from the Green Belt, and would enable more employees and residents to live closer to where they work.

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

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities available in the City Centre. It is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge, and to other employment opportunities available in the City. Therefore, the release of the land at South West Cambridge from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

As set out in the North BRLOG representations to Section 2.3: Edge of Cambridge and to the HELAA Site Assessments for Site Ref. 52643 (Land north of Barton Road and at Grange Farm,
Cambridge), the Vision Document for South West Cambridge seeks to address landscape, heritage and Green Belt impacts by retaining substantial parts of the promoted development for green infrastructure that would remain within the Green Belt.

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

As set out above, the South West Cambridge site is accessible by walking, cycling and public transport, and will be well-related to planned bus and walking/cycling improvement projects being brought forward by the Greater Cambridge Partnership. The site is accessible to employment, education, retail and leisure opportunities. The promoted development would include a primary school and neighbourhood centre to meet the needs of residents and the surrounding area. There is a substantial and current identified need for affordable housing and a high housing affordability ratio in Cambridge and South Cambridgeshire, making it difficult for those that work in Greater Cambridge to access housing to buy and rent. The promoted development at South West Cambridge would provide market and affordable/social housing.

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 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 sites in the edge of Cambridge, in order to address the under-delivery of affordable housing from elsewhere.

It is requested that the promoted development at South West Cambridge is released from the Green Belt and allocated in emerging GCLP for a landscape-led urban extension.

Full details are provided in the supporting main response document.

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


Significant transport investment is planned around Papworth, which will further support the proposed sustainable expansion of the village. Transport connections to Papworth are set out in more detail within the accompanying Transport Appraisals prepared by EAS.
There are a number of strategic schemes coming forward which will improve mobility in the area and better connections with key service centres. Furthermore, bringing forward development in Papworth would act as a catalyst and a source of additional investment to further improve local infrastructure to connect Papworth to the south and increase the opportunities and likelihood for Papworth residents and workers to travel, at least in part, by sustainable modes of travel:

The completion of the A14 re-alignment and improvement works;
The East-West rail preferred route has been announced which will link with Cambourne which is just 4km south of Papworth (see figure 1 below);
Highways England improvement proposals which includes new footpath and cycleway connections at the Caxton Gibbet junction and the re-alignment of the junction to reduce congestion in the area and improve journey times along this key transport route;
The Greater Cambridge Partnership’s Cambourne to Cambridge Transport project which will improve transport connections. As part of these proposals, the proposed Scotland Farm Park and Ride is currently the preferred option. Scheme completion is currently forecasted in 2024; and
The Combined Authority Mayor committing to enhanced bus provision to better connect villages.

The Cambridgeshire Long Term Transport Strategy 2011-2031 supports this and identifies the major infrastructure requirements that are needed to address existing problems and capacity constraints on Cambridgeshire’s transport network, and the further infrastructure that is required to cater for the transport demand associated with planned growth. It includes the following schemes will improve the connectivity of Papworth Everard:

Strategic and local cycle network improvement between Huntingdon-Papworth EverardCambourne;
Area action plans for the A14 Trunk Road in Huntingdonshire and South Cambridgeshire delivering;
- New A14 trunk road, local road capacity, cycle and pedestrian routes;
- Area action plan for the A428 Trunk Road in Huntingdonshire and South Cambridgeshire. This includes:
- A428 Caxton Gibbet to Black Cat dualling by 2021, including a grade separated junction at the A1 Black Cat roundabout;
- Bus priority measures Caxton Gibbet – West Cambourne, A428 to Bourne airfield;
A428 park and ride; and
- A428 and A1198 junction improvements.

Cambourne to Cambridge Public Transport Route and New Park and Ride Site: A number of options are being considered by the Greater Cambridge Partnership (GCP) to improve journeys from the west of Cambridge into the city. This follows a successful public consultation with options soon to be presented for approval to the GCP Board for approval.

In its current form the village of Papworth is not providing a strong opportunity to reduce car trips within the district; however, the provision of links to the south will improve this. New development could be part of the solution to promote and help deliver more sustainable travel links for the benefit of all.

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

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

Notwithstanding this clear direction in national policy, the emerging Local Plan makes very few additional allocations in the rural area and VJF objects to this approach. This approach threatens the vitality of villages within the rural area and stifles opportunities for further growth and supporting local services. The allocation of additional sites in the rural area will also help to ensure that the housing supply for the Local Plan is balanced and robust, reducing the reliance on strategic sites and the limited allocations in villages. As such, the Development Strategy should include for further allocations in the rural area to ensure that a sound spatial strategy is developed and delivered.


It is important that any additional allocations accord with the principles of the proposed
development strategy. Land at Papworth accords with the proposed development strategy as
follows:
Directing development to where active and public transport is the natural choice:
Future transport links with the east-west transport corridor improvements will bolster
sustainable travel opportunities to Papworth.
Where green infrastructure can be delivered alongside new development:
The proposed development of the site would be landscape led with potential for benefits
to the green infrastructure that exceed policy requirements, including new swathes of
public open space
The site is predominantly agricultural land and is low ecological value. Through
enhancements the proposals present an opportunity to deliver a biodiversity net gain of at
least 20%.

Cambridge Biomedical Campus (HELAA site OS056)

We support the directing of groThe Campus is developing into an exemplary location in this regard wth towards locations that have the least climate impact, and where active and public transport are readily available. Development should be planned with good existing and proposed public transport, particularly in locations close to existing employment clusters. The Campus is developing into an exemplary location in this regard and planned expansion of the Campus onto land to the south will allow it to continue to do so.

The scale of the floorspace requirement at the Campus, across the range of land uses necessary for the Campus to develop as a sustainable Innovation district, embedded in a strong landscape framework justifies the full scale development of the district set out in Vision 2050, west as well as east of the West Anglia mainline.

The development strategy will not provide a wide range of homes and jobs and is heavily reliant on commuting to Cambridge and high-density living environments on sites with high infrastructure burdens.

The Local Plan should allocate the widest possible range of sites in order to provide choice, affordability and diversity in the market; not to mention resilience in supply across the plan period. Small-medium sized sites play an important role in providing a wide variety of house types, tenures, sizes and mix and also deliver quickly compared to larger sites.

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

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

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

Notwithstanding this clear direction in national policy, the emerging Local Plan makes very few
additional allocations in the rural area and Peterhouse objects to this approach. This approach
threatens the vitality of villages within the rural area and stifles opportunities for further growth
and supporting local services. The allocation of additional small to medium sized sites in the rural
area will also help to ensure that the housing supply for the Local Plan is balanced and robust,
reducing the reliance on strategic sites and the limited allocations in villages. As such, the
Development Strategy should include for further allocations in the rural area to ensure that a
sound spatial strategy is developed and delivered.

It is important that any additional allocations accord with the principles of the proposed
development strategy. Land south of Hattons Road, Longstanton accords with the proposed
development strategy as follows:

● Directing development to where active and public transport is the natural choice:
− Longstanton Park and Ride is located approximately 1.5km to the north of the site and
provides residents with access to a high frequency service between Cambridge and St.
Ives. The Park and Ride is within easy cycling distance of the site and would provide
residents with access to sustainable modes of transport.
− There is a footpath public right of way running along the eastern boundary of the site,
which connects Hattons Road with School Lane and a footpath on the opposite side of
Hattons Road. A tactile paving crossing point and footway could be created along the
northern boundary of the site on the south side of Hattons Road to improve connectivity.
A footpath link can also be created to the south to the existing footway on School Lane
and the Citi5/5A/5C bus stop around 100m from the south eastern boundary of the site.
This would provide the potential new residents with safe pedestrian access to services,
facilities and public transport from within the site.
Preferred Options Consultation 2021 – Land South of Hattons Road, Longstanton
● Where green infrastructure can be delivered alongside new development:
− The proposal includes multi-functional public open space including parklands, woodlands
and nature reserves which are connected by green corridors to enhance and build upon
existing corridors in the surrounding landscape. A total of 5.89 hectares (approximately
half of the site) is proposed for open space, including a continuation of the public open
space allocated in SC/1(b) to create a meaningful green spine through Longstanton.
− The site is predominantly agricultural land and can currently be considered to be of low
ecological value. Through enhancements the proposals present an opportunity to deliver
a biodiversity net gain of at least 10%.
● Where jobs services and facilities can be located near to where people live:
− Locating residential development in a sustainable location, within close proximity to
existing and proposed services, facilities, infrastructure and employment opportunities.
The site is located approximately 150m from the village High Street, located near to
Northstowe, which will provide a wide range of town centre uses, and is well within
cycling distance of the Longstanton Park and Ride. The site is therefore well placed for
future residents to be able to walk and cycle, rather than travel by private car, to meet
their daily needs.

Axis Land Partnerships wish to object to Policy S/DS Development Strategy. We have appended / emailed our response as follows:

Representation Report including response to:
Proposed Housing Trajectory outlined in Policy S/DS;
Sustainability Appraisal process for identifying the First Proposals Development Strategy outlines in Policy S/DS; and
Housing and Employment Land Availability Assessment (HELAA, September 2021) appraisal of Station Fields (site ref. 40084)

Supporting information:
Station Fields Green Infrastructure Strategy demonstrating how the proposals for Station Fields respond to key placemaking themes identified in the Plan;
GCP Foxton Travel Hub Response;
Access and Movement Strategy; and
Supporting Appendix

The College support including allocations within Cambridge City that can be well-located to bus routes, cycle paths, pedestrian paths, jobs, services and facilities, but objects to only one such modest new allocation. It results in a reliance on too few sites to deliver the significant majority of the Local Plan housing need. To re-risk a failure to deliver the housing requirement or a rolling five-year housing supply, it needs to allocate more smaller-sustainable sites; to add resilience to the housing supply by introducing more sites that can come forward at different stages in the housing market and economic cycles.

The emerging Policy S/DS: Development Strategy sets out the “proposed strategy for the pattern, scale and design quality of places created in Greater Cambridge for the plan period and beyond to 2050”. It identifies where the homes and jobs set out in Policy S/JH should be provided, in order to meet the vision and aims of the Local Plan.

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

We agree that it is fundamental that new developments are built in the most sustainable locations, for the environment, the economy and communities. However, there needs to be a recognition that this will mean different locations for different types of development, including greenfield locations for uses best located outside, but close to settlements such as employment hubs which have a servicing function for all other development sectors.

Locating logistics facilities close to urban centres enables the use of electric fleet and cargo bikes for last mile deliveries. In addition, this encourages workforce to travel to work via sustainable and more active transport modes, such as cycling, encouraging healthier lifestyles, decreasing congestion and improving the air quality.

At present, emerging Policy S/DS directs development to brownfield land and where it responds to opportunities created by proposed major new infrastructure. It then goes on to recognise that locations capable of providing sustainable development include the Cambridge urban area, edge of Cambridge, new settlements (namely Cambourne, Northstowe, Waterbeach and Bourn Airfield), the Rural Southern Cluster and limited development in the rest of the rural area.

We welcome that Policy S/DS recognises that appropriate development in the rest of the rural area including, “new employment sites in the countryside meeting specific business needs” and that Policy S/RRA identifies two manufacturing and warehousing allocations around the Swavesey junction of the A14. We agree that this quadrant of Greater Cambridge along the A14 is the most appropriate location to bring forward future economic opportunities and allow existing and new businesses to invest in the area. This location is served by the upgraded A14 and as such has high accessibility to the strategic network. In addition, this area is bounded by new residential developments including Northstowe (6,345 new homes across the Plan period), Cambourne West (2,590 homes), Cambourne (1,950 homes), Bourn Airfield (2,460 homes), Darwin Green (478 homes) and Eddington (3,142 homes). On this basis, significant additional labour supply will be available in this area over the plan period. Moreover, this location will encourage sustainable commuting to work and sustainable urban transport modes to deliver services in the City.

Given the clear sustainability benefits of locating such business along the strategic road network with minimal local highways trips and the recent major infrastructure improvements to the A14, we would encourage Policy S/DS to explicitly recognise that J25 Bar Hill, which is located outside of the Green Belt provides a valuable, sustainable, suitable and appropriate location for development, and support further development in this location.

The proposed Development Framework sets out a strategy for the pattern, scale and design quality of the homes and economic land provided in Greater Cambridge. To ensure that the distinctive character of towns and villages is protected, the council place emphasis on approving developments which are well-integrated with existing settlements (Policy S/DS, page 29-30 of the draft Local Plan).

The council have proposed to concentrate development in the City of Cambridge to accommodate for its growing number of jobs (as set out in Policy S/JH). Housing provisions for rural areas beyond the Green Belt (as outlined in Policy S/DS) are mainly in large rural towns. As a result, the plan does not provide development opportunities at numerous settlements within the Plan area, despite settlements like Meldreth, which offers an obvious development opportunity through the redevelopment of the Bury Farm site within/contiguous with the settlement, and has the potential to achieve highly sustainable patterns of development due to its infrastructure and connectivity to employment areas. The proposed Development Strategy cannot therefore be supported in its current form, as it does not promote sustainable development in highly sustainable locations at rural settlements beyond the green belt.

Areas where there is significant infrastructure to sustain rural communities and simultaneously a lack of new housing, such as Meldreth, represent an ideal opportunity for the new Plan to positively promote development opportunities on sites containing existing buildings at locations contiguous with existing settlements. It is therefore requested that the development strategy increases its provision of housing for rural areas where redundant farm buildings exist, contiguous with a settlement and where suitable infrastructure exists to support sustainable living and working patterns.

The development strategy does not provide a wide range of homes and jobs and is heavily reliant on commuting to Cambridge and high density living environments and risks not meeting the needs for all, for example for family housing.

In the case of NEC and Additional Cambourne, there is reliance on other consenting processes which in itself adds greater risk and uncertainty to deliverability. The strategy therefore needs to focus on strategic sites like Westley Green that are more deliverable and can facilitate more sustainable movements near to major employment locations to the east and southeast of Cambridge.

See submitted planning commentary for more information.

See my detailed comments on Policy S/RSC/HW and S/CBC.
I strongly endorse your section Ensuring a deliverable plan – water supply (pp 41 -42). Complete coordination with every organisation involved in water supply is absolutely essential.
Similarly, complete coordination with every organisation involved in transport strategy is absolutely essential.

The significant cumulative impacts of residential developments on healthcare infrastructure in the area should be recognised and, given their strategic importance, health facilities should be put on a level footing with affordable housing and other infrastructure providers when reviewing, securing and allocating S106 and CIL funds, in order to enable the delivery of vital NHS projects. It is imperative that planning policies are positively prepared, in recognition of their statutory duty to help finance improved healthcare services and facilities through effective estate management.

The proposed development strategy for Greater Cambridge directs the 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. Silverley Properties are of the view that the Council should deliver a greater number of smaller allocations to ensure that there is a supply of housing that can be built out sooner within the plan period, according with the NPPF. Land South of Newington, Willingham is a site that could be built-out quickly, with no undue physical constraints on development.

Cambourne Town Council is in support of development, but would make the following comment in relation to the Cambourne allocation:
- Object to any allocation of new homes for Cambourne until a final decision has been made on East West Rail and funding committed to the project. The prospect of a railway station is the only reason that Cambourne is considered a sustainable location for growth and until this is secured, no allocation should be progressed.
- Given the inherent uncertainty of delivery largescale infrastructure, any allocation of new homes in Cambourne should specifically state that planning permission will not be granted until work commences on a Cambourne Station and no new homes will be allowed to be occupied until the station and East West Rail services are operational.

Policy S/DS – Development Strategy (P29)
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 necessary dictate that a ‘very limited amount of development’ come forward in rural areas. 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.
Whilst the plan allows for the development of sites of up to 8 and possible 15 in exceptional circumstances it is anticipated that these will come forward on a windfall basis. It is considered that the plan should be more proactive spatially in terms of ensuring that a proportion of housing need generally is used to underpin and safeguard the vitality of village locations going forward.
Indeed, on this the strategy goes onto state that ‘we have identified a limited number of new sites for housing at our more sustainable villages’. This appears to demonstrate that proactively planning for growth in village locations is beneficially however it is not then clear why these villages have been deemed appropriate for allocated development whilst villages such as Fowlmere are not.
Fowlmere continues to be classified as a Group Village within the emerging Local Plan, and whilst this is not necessarily considered the focus for strategic growth, modest growth is important in supporting, sustaining and enhancing local amenities and services.
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 larger settlements presents risks with regards to disproportionate settlements that could leave smaller villages, such as Fowlmere, with stagnated growth and poor support for local facilities.
Much of south Cambridgeshire is protected by Green Belt. Fowlmere falls outside of the Green Belt and the accommodation of development there offers the added benefit of not needing to remove further parcels of land from Green Belt designation.
It is considered that the development of Land off Long Lane, Folwmere can valuably contribute to the Greater Cambridge housing requirement whilst supporting and contributing to the Fowlmere local community. In this respect a site that is immediately developable, with minimal site-specific constraints, presents a positive opportunity for residential development that should be fully considered.
The site was submitted in response to Greater Cambridge’s call for sites (ref: 40012). In response Greater Cambridge concluded that that whilst the site was available and achievable it was not suitable. Much technical assessment of the site has subsequently taken place. As shown on the concept plan, submitted alongside these representations, it is considered that all technical issues relating to development of the site can be overcome and in this respect the site is considered suitable for development. This is expanded on below in the context of some of the key obstacles identified by the Council:
• Adopted Development Plan Policies: Assessed Amber on the basis that the site sits outside the development framework for Fowlmere as currently defined. The purpose of the emerging Greater Cambridge Plan however is to identify what sites are needed to meet housing supply have regard to the need to proactively identify sites and remove policy constraints as necessary. Within an emerging Local Plan therefore a settlement boundary need not be a barrier to suitability;
• Flood Risk: Again this has previously been assessed amber. It is acknowledged that part of the site is in flood risk zone 2 and 3. However, as shown on the attached concept plan technical analysis has confirmed that the site can come forward for development outside of these areas. In short flood risk does not prejudice the sites suitability for development;
• Landscape and Townscape. This was assessed to be Red given the potential impact on the village form and townscape of Fowlmere. Much design work has been undertaken to consider how residential development could come forward on the site in a manner that is sensitive to both the built form of Fowlmere and the streetscene itself. The Council’s assessment appears to pre-judge the site solely on the principle of its location outside of the existing settlement framework. In design terms it is considered that the site could come forward without significant impact in both landscape and townscape terms. This is not considered an issue that should cut to the principle of development on the site and not an issue therefore that can at this initial stage i.e. without consideration of detailed proposals, deem the site to be unsuitable;
• Bio-diversity and Geo-diversity: Again this has been assessed Amber but it is not clear on what basis. As the concept plan submitted alongside these representations shows the site allows for ample provision of green space. The delivery of new and enhanced open space within the site will include areas of native planting, wildflowers and trees and will assist in strengthening biodiversity in this location. The site is currently arable and as such offers only limited ecological value. Development of the site will delivery a net bio-diversity gain, in line with policy aspirations;
• Historic Environment. This has been assessed Amber on the basis that the site is within 100m of a listed building. The Concept Plan attached to these representations however shows that this relationship can be treated sensitively, in this instance a buffer is shown between and development and the sited asset. Again this is not considered an issue that need cut to the principle of development but rather one that can be handled sufficiently sensitively through the consideration of detailed proposals;
• Accessibility to Services and Facilities: This has been assessed as Red and as such a major issue in terms of the suitability of the site. All of the Local Amenities within Fowlmere are within a 10 minute walk and as such are accessible. Furthermore, development of the site offers the opportunity to provide important economic support to safeguard these facilities and the potential, in this respect, to provide support for further services.
• Site Access: It is not clear why this has been assessed as orange when the assessment concludes that access to the site is ‘ acceptable in principle’. Technical work has further confirmed this. Development of the site can be appropriately accessed;
• Transport and Roads: Fowlmere, as a village, is sustainably located and benefits from a number of facilities and amenities within a 10-minute walk of the site. With regards to transport connections Fowlmere is served by two bus services with the 915 bus service passing directly in front of the site connecting Fowlmere with Cambridge and Royston. In terms of village locations the site is fully accessible. This is not a barrier to development and indeed it is considered that the ability to use the development of this site to help contribute towards and safeguard these transport services should be reviewed further.
Overall, given the village’s sustainable location, combined with the district’s growth targets and housing delivery requirements set out within the new Local Plan, it is considered that land off Long Lane, Fowlmere, presents an appropriate location for additional housing. The site is bounded by logical and permanent boundaries and lacks substantial constraints. Further, the site is capable of delivering enhancements to open space and biodiversity. We strongly urge the Council to review the opportunity presented by the site.

Recommendation: Village locations can provide sustainable locations for growth coupled with an ability to support existing communities, services and facilities. This should be acknowledged within policy. The need for growth in these places to sustain and help these existing settlements thrive should also be acknowledged.
The Spatial Strategy should seek to proactively plan for growth in village locations and should make clear that growth will be encouraged in village locations where it is shown appropriate to support and enhance the village moving forward.
Land at Long Lane Fowlmere be identified as a site suitable for the development of up to 130 new homes.