S/DS: Development strategy

Full text:

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60148

Received: 13/12/2021

Respondent: U&I PLC and TOWN

Agent: Carter Jonas

Representation Summary:

North East Cambridge, SS/5 (HELAA site OS062)

SUPPORT
We broadly support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land, noting that it has already been identified for homes and jobs growth.

However, we are extremely concerned by the ‘Homes’ target for NEC that is stated in the table on page 32, which refers to 3,900 homes between 2020 and 2041. Fundamentally, this is at odds to the trajectory that has been agreed with Homes England as a pre-requisite for the substantial public funding that has been agreed in principle to relocate the WWTW.

We would therefore instead support a policy that recognises 5,600 homes will be provided on the Core
Site by 2041. Consideration will also then need to be given to other housing that is expected to come
forward within the NEC AAP

Full text:

NORTH-EAST CAMBRIDGE ‘CORE SITE’, COWLEY ROAD,
CAMBRIDGE

GREATER CAMBRIDGE LOCAL PLAN 'FIRST PROPOSALS' (REG 18)

Written Response on behalf of U&I PLC / TOWN

Monday, 13 December 2021

Classification L2 - Business Data

CONTENTS

0.0 INTRODUCTION 1
1.0 POLICY RESPONSE 2

0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I / TOWN, to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).
0.2 U+I and TOWN have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (to be referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document). For the avoidance of doubt, these representations are submitted on behalf of U+I and TOWN as master developers rather than the landowners themselves.

0.3 Regeneration of the Core Site will be facilitated by the relocation of the WWTW, which will be funded from the Homes England’s Housing Infrastructure Fund, and which is currently going through a Development Consent Order approval process. Anglian Water will be submitting separate representations to the First Proposals, on this specific element.

0.4 U+I/TOWN have been actively involved in the policy formation process of the NEC AAP and are therefore looking to ensure there is policy consistency between the NEC AAP Proposed Submission and First Proposals documents.

0.5 Consideration will need to be given to the prospect of policy inconsistencies between the Greater Cambridge Local Plan (‘GCLP’) and NEC AAP.

0.6 As a point of broad principle, we would request that relevant GCLP policy (particularly where performance standards are stated) provides appropriate wording that defers to more area/site-specific policy, where it is being formed in other Development Plan Documents, such as NEC AAP. In the event of any inconsistency, this will ensure that there is a clear understanding over which policy takes preference. For instance, if a 20% biodiversity net gain (‘BNG’) target is ultimately adopted in GCLP policy, and a minimum 10% BNG is sought in NEC AAP, then there would be a clear signal in the GCLP policy that the NEC AAP policy is the correct standard to apply.

1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing
OBJECT
1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.
1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.
1.3 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.
1.4 It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

Policy S/DS: Development Strategy

SUPPORT

1.5 We broadly support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land, noting that it has already been identified for homes and jobs growth.
1.6 However, we are extremely concerned by the ‘Homes’ target for NEC that is stated in the table on page 32, which refers to 3,900 homes between 2020 and 2041. Fundamentally, this is at odds to the trajectory that has been agreed with Homes England as a pre-requisite for the substantial public funding that has been agreed in principle to relocate the WWTW.
1.7 We would therefore instead support a policy that recognises 5,600 homes will be provided on the Core Site by 2041. Consideration will also then need to be given to other housing that is expected to come forward within the NEC AAP.

Policy S/NEC: North-East Cambridge

SUPPORT

1.8 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process.
1.9 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC.
1.10 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP.

Policy BG/BG: Biodiversity and Geodiversity

OBJECT

1.11 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).
The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so:

- Post-development biodiversity value of the onsite habitat;

- the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development;

- the biodiversity value of any biodiversity credits purchased for the development;

1.12 Whilst U+I/TOWN recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).
1.13 In terms of implications for the Core Site in North-East Cambridge, the NEC Ecology Study (2020) recommended that a target for a net gain of 10% is applied for all developments within NEC. Where this is not achievable within the site boundary then offsite measures should be provisioned.
1.14 By way illustration, a 20% gain to the 36.76 biodiversity units that have been identified in the Ecology Study would result in the need to achieve 44.112 biodiversity credits, in order to satisfy policy requirements. This seems highly ambitious, given the level of density that will need to be achieved across the Core Site to meet NEC strategy objectives. We will continue to make representations on this point as the NEC AAP progresses. GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.

1.15 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/HD: Creating Healthy New Developments

SUPPORT

1.16 We broadly support the 10 principles for creating healthy places. The vision for North-East Cambridge is of a healthy, inclusive, walkable, low-carbon new city district with a vibrant mix of high quality homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods.
1.17 One of the five strategic objectives of the NEC AAP is for a healthy and safe neighbourhood and notes the principles of the Health New Towns programme.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments

SUPPORT

1.18 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy GP/LC: Protection and Enhancement of Landscape Character

COMMENT

1.19 The policy notes that ‘the edges of Cambridge and the villages are an important area of transition which require sensitive landscaping to protect the setting of the settlements and to provide a well- defined edge which respects townscape and the countryside beyond’.
1.20 The Core Site at North-East Cambridge will need to be planned to a high density in order to fully achieve the the strategic objectives of the NEC AAP, as well as to hit the quantum of development required under Homes England’s Housing & Infrastructure Fund. This will require a number of buildings that are taller than may otherwise be commonly found in the north of Cambridge (including surrounding villages, such as Milton). The masterplan for the Core Site will take great care in how its development edges interface with the landscape and setting of nearby settlements, as well as adjoining ‘bad neighbour’ uses currently in existence. The policy will need to recognise the strategic objectives of NEC AAP and avoid imposing conditions that could unreasonably restrict development.

Policy GP/QD: Achieving High Quality Development

SUPPORT

Policy GP/QP: Establishing High Quality Landscape and Public Realm

SUPPORT

Policy J/NE: New Employment Development Proposals

SUPPORT

1.21 We broadly support the intent of the policy but consider it essential that GCSP takes a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area. There is a need to provide sufficient supply in order to meet the balanced homes/jobs requirements and to reflect the high employment density and employment skills these uses engender.
1.22 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It
noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries

SUPPORT

Policy H/HD: Housing Density

SUPPORT

Policy H/CB: Self and Custom-build Homes

OBJECT

1.23 The concern we have with this policy is the ability for the Core Site scheme to comply with the amount of Self-build/custom build being sought, given the high-density development that is envisaged. We would seek reference in the policy to wording that reflects the relevant policy in the NEC AAP i.e. to support ‘custom-finish’ as well.

Policy I/ST: Sustainable Transport and Connectivity
SUPPORT

Attachments:

Representation Document (201.50 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60171

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Water Supply
The Councils’ Integrated Water Management Plan indicates that current levels of abstraction from the chalk aquifer used to supply the Greater Cambridge area are unsustainable. Water companies have a statutory duty to develop and maintain an efficient and economical system of water supply in their areas and the Councils and relevant water companies need to ensure that the necessary resources and infrastructure are in place to secure the necessary supply required to meet the demands of not only Greater Cambridge, but all those areas affected.

If the necessary infrastructure is not in place a stepped requirement may be necessary but should be seen as a last resort. It will also be necessary, as set out in paragraph 68-021 of PPG, that the Councils will need to ensure that planned housing requirements can still be met within the plan period and does not become continually delayed.

Full text:

Water Supply
The Councils’ Integrated Water Management Plan indicates that current levels of abstraction from the chalk aquifer used to supply the Greater Cambridge area are unsustainable. As such the study outlines that there is a need for new strategic water supply infrastructure in order to provide for the longer term needs of the area if development is to be delivered beyond those levels already agreed as part of current Water Resource Management Plans (WRMP). The Councils highlight that a new WRMP is being prepared to cove the period to 2050 and it will be important that the proposed level of growth set pout in this plan can be accommodated moving forward. Water companies have a statutory duty to develop and maintain an efficient and economical system of water supply in their areas and the Councils and relevant water companies need to ensure that the necessary resources and infrastructure are in place to secure the necessary supply required to meet the demands of not only Greater Cambridge, but all those areas affected.
If the necessary infrastructure is not in place a stepped requirement may be necessary but should be seen as a last resort. It will also be necessary, as set out in paragraph 68-021 of PPG, that the Councils will need to ensure that planned housing requirements can still be met within the plan period and does not become continually delayed.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60180

Diagrams referenced in Representation (68.26 KB)
Covering email (124.05 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60210

Received: 11/12/2021

Respondent: Dr J. Valerie Neal

Representation Summary:

On water issues, I fully endorse the Consultation Response of the Friends of the Cam on the Draft Local Plan.

Full text:

Policy S/DS: Development strategy
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.
The proposed development strategy for Greater Cambridge 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.
The development strategy is broadly supported

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60263

Received: 13/12/2021

Respondent: Gonville & Caius College

Agent: Strutt & Parker

Representation Summary:

Rectory Farm, west of Milton (HELAA site 60263)

In principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

It is clear from both the adopted and emerging Local Plan, that the A10 corridor from north- east Cambridge to Waterbeach is a key focus for growth. We fully support this approach. Consistent with this objective, it is considered that further growth should be provided on land to the west of Milton, at Rectory Farm. Rectory Farm is a particularly sustainable option for growth, given that it immediately adjoins the existing park & ride to the south of the site.

Full text:

INTRODUCTION
1.1 This representation has been prepared by Strutt & Parker on behalf of Gonville & Caius College to support the promotion of land at Rectory Farm, Milton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Consultations and covers the following topic. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.

1.4 The HELAA excludes the Rectory Farm site from allocation primarily on the basis of landscape issues and highways issues.

1.5 The site was originally submitted as part of the Call for Sites for up to 1,500 dwellings and 30,000 m2 of employment. For reasons explained at Call for Sites stage and set out within this representation it is considered that the site is suitable and deliverable in the medium term for a development of that scale.

1.6 It is considered that several of the assessments criteria, particularly regarding the landscape impact and the transport impact on the A14 should be re-categorised. This is particularly the case given that HELAA assessment appears to have been undertaken in isolation and has not given due consideration to the major transport projects being promoted along the A10 corridor. Further analysis of this is set out within section 7 of this report.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up with demand for increased jobs within the area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 As acknowledged within the Development Strategy Topic Paper, that accompanies this consultation it is acknowledged that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox- Cam Arc as a centre for housing and employment growth.

3. QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?

3.1 Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

3.2 The site at Rectory Farm is located in a very sustainable location, with the development not overly reliant on car travel, with many public transport options easily accessible. It is located centrally along a key growth corridor within the emerging Local Plan. To the north, is Waterbeach New Town, which has planning consent and an allocation for the delivery of over 5,000 dwellings within the plan period and the delivery of a further 4,000 dwellings after the end of the plan period. To the south is the North- East Cambridge Major area of change, which has a draft allocation for the delivery of 3,900 dwellings within the Local Plan period and 8,350 dwellings in total, along with the delivery of 15,000 new jobs.

3.3 It is clear from both the adopted and emerging Local Plan, that the A10 corridor from north- east Cambridge to Waterbeach is a key focus for growth. We fully support this approach. Consistent with this objective, it is considered that further growth should be provided on land to the west of Milton, at Rectory Farm. Rectory Farm is a particularly sustainable option for growth, given that it immediately adjoins the existing park & ride to the south of the site. In addition, the proposed ‘central option’ of the Cambridge to Waterbeach Rapid Transit Route immediately dissects Rectory Farm and has the ability to provide a bus stop within Rectory Farm, which could serve both the existing village of Milton and new job and housing growth at Rectory Farm. There is also the ability to provide ease of cycle access into the City from the site, via Waterbeach Greenway.

4. QUESTION: We think that the area of Milton Road in North-East Cambridge (including the current waste water treatment plant) can be developed into a lively and dense city district, after the water treatment plant relocated. What housing, jobs, facilitates or open spaces do you think this site should provide?

4.1 We support the proposed allocation and redevelopment of north- east Cambridge in principle and as set out in section 3 above, we consider that the corridor between north- east Cambridge and Waterbeach provides a sustainable transport corridor and should provide a focus for growth. However, we do consider that the GCSPS have taken an inconsistent approach in terms of the scoring of North- East Cambridge site within the HELAA than they have for land adjacent to Rectory Farm. Land within North- East Cambridge has a draft allocation for development, despite the fact that it is to a large extent reliant on the relocation of the Waste Water Treatment Works, which is subject to a complicated Development Consent Order approval process.

4.2 The Local Plan also references that the sustainability of North- East Cambridge will improve as a result of planned infrastructure projects such as the Chisholm Trail, Waterbeach to Cambridge Public Transport Corridor and Waterbeach Greenway. We fully support and agree that the delivery of these three important projects will improve the sustainability not only of North- East Cambridge, but also the settlements of Milton and Waterbeach. Within the HELAA Land at Rectory Farm has been deemed unsuitable on the basis of additional traffic pressure on the A14, however Cambridge North- East, which is both a significantly larger development and closer to the A14 has been deemed suitable on transport grounds. It is therefore unclear, why a different approach appears to have been taken between Cambridge North- East and land at Rectory Farm in this regard, which is not justified or sound in planning terms

4.3 Further analysis of this point is set out within our response to the HELAA, within section 7 of this report.

5. QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?

5.1 The proposed strategy focuses on locating new development in and around Cambridge City, growing existing new settlements, with a small degree of growth in the rural southern clusters.

5.2 It is considered that additional growth should be provided within the most sustainable and largest villages within South Cambridgeshire, such as Milton. As set out in detail within our Call for Sites submission (which has been appended to this representation), Milton is arguably the most sustainable of the Minor Rural Service centres, given its very close proximity to Cambridge, its range of services and the ability to travel from Milton to Cambridge by sustainable transport means. Rectory Farm, is particularly sustainable given that it abuts Milton Park & Ride, which provides for direct and convenient bus access to the City.

5.3 The delivery of major transport schemes along the Waterbeach to Cambridge corridor will further improve the sustainability of Milton, particularly on its western side. The sustainability of Milton will be further enhanced by the additional of 15,000 jobs in north- east Cambridge, which will be very easily accessible by both bike and bus from land at Rectory Farm.

5.4 It is therefore considered that appropriate growth should be provided within the more sustainable, larger villages such as Milton.

6. QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?

6.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. Gonville and Caius College are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Milton Parish Council regarding the mix and type of housing to be delivered land at Rectory Farm.

6.2 The size of the site also means that there is capacity for up to 30,000 m2 of employment floor space included within the site. The College are flexible regarding the type of employment space to be delivered as part of the allocation, in order to meet the extensive demand for job growth along this corridor.

7. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far? Yes, the site at Rectory Farm should be allocated for mixed use development and would be a sound allocation as part of the emerging Local Plan.

7.1 The site was promoted originally at Call for Sites stage for a residential-led mixed use development for 1,500 dwellings and up to 30,000m2 of employment space. This section of the report re-assesses the sites suitability, and demonstrates that it is a suitable location for mixed use development. The site has scored red in the HELAA Assessment in respect of Landscape and Townscape Impact and Strategic Transport Matters. For reasons set out within this section, it is considered that these sections need to be re- scored within the HELAA.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60271

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, aka Cambridge South East (HELAA site 40058)

Build-out rates
As per the October 2021 Housing Delivery Study (HDS), Waterbeach is assumed to deliver at 250dpa, but Bourn Airfield and Cambourne West are set to only deliver at 150dpa with the odd year of delivery rising to 200dpa. The clear evidence to justify this disparity in sites of a similar scale is unclear.
Northstowe is consistently assumed to deliver 250 dpa but within the next 4 years is to deliver in excess of 300dpa. This approach would not appear to have been taken with regard to Table 18 of the HDS, which sets out that average build out rate of urban extensions delivering 2,000+ homes are 225-275. We would consider that setting out an expected delivery of over 300dpa for multiple years is highly optimistic and it is not clear from the evidence base how this is justified, to ensure no optimism bias this should be lowered to a more realistic average build out rate of 250dpa, which fits within the identified range above, with a peak of 300dpa in 1 or 2 years if it can be evidenced.

Full text:

Context
Housing underpins every objective of sustainable development in the NPPF; economic (building a strong economy and ensuring sufficient land of the right types is available in the right place), social (supporting strong communities by ensuring a sufficient number and range of homes can be provided and by fostering well-designed, safe places) and environmental (making effective use of land, improving biodiversity and moving to a low carbon economy). The NPPF goes on to set out that (para 61): “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”
Housing also underpins the themes of the emerging GCLP, for example:
1 Climate Change – it is a recurring theme in the GCLP that one of the biggest contributors to climate change is in commuting to Cambridge. This is exacerbated by the current lack of affordable housing relative to quantum of jobs in Cambridge. Building enough new homes just to keep pace with job growth may simply maintain the current situation but planning for more jobs without the corresponding homes would exacerbate the issue further.
2 Biodiversity – new housing development can provide access to new formal and informal open spaces, taking pressures of existing habitats, whilst also delivering biodiversity net gain.
3 Jobs – at its most simple level job growth must be supported by housing growth to ensure a sufficient labour force is available. It is also key that these homes are in the right places, because businesses rely upon (and gain a competitive advantage from) having a workforce which can move readily to new employment opportunities. Jobs also need to be supported by a range of housing types and tenures to ensure that workers on all incomes can access employment, and the provision of new housing allows for delivery of affordable housing as well as specific types, such as key worker accommodation.
4 Infrastructure – development of housing is key to ensuring existing infrastructure can be retained (for example, ensuring public transport networks remain viable) and is also key to unlocking new infrastructure.
The intersection of housing with other themes is also noted within the GCLP itself, stating that: “Delivering new net zero carbon homes, across a variety of tenures, with sufficient indoor and outdoor space, designed to be adaptable throughout the lifetime of their occupants, and located close to jobs will provide many varied benefits for people and the planet. This theme therefore connects with most of the other themes. For example: net zero carbon homes (Climate Change) will help control energy costs making living costs more affordable, the creation of healthy new high quality developments with green spaces and other appropriate infrastructure (Biodiversity and Green Spaces, Wellbeing and Social Inclusion, Great Places, and Infrastructure) will improve the health and wellbeing of residents, and providing new homes will help businesses to meet their staffing needs (Jobs).” (GCLP First Proposals p.259)
The GCLP proposes a number of policies including for affordable housing, housing mix, density, specialist housing, self-build homes, build-to-rent homes, student accommodation and community-led housing.
Housing in the GCLP
On the basis of Section 5.0 (which set out that the GCLP should be more ambitious in its planned level of employment growth) we consider that commensurate increases would also be needed in housing growth to support this. As with employment, we consider that the housing requirement in the GCLP should be expressed as a minimum to ensure that there is flexibility to allow for higher housing growth in order to ensure Greater Cambridge’s potential is maximised.
In addition, we also make some observations below about identified housing delivery in the GCLP.
Build-out rates
As per para 10.19 of the October 2021 Housing Delivery Study (HDS), Waterbeach is assumed to deliver at 250dpa, but Bourn Airfield and Cambourne West are set to only deliver at 150dpa with the odd year of delivery rising to 200dpa. The clear evidence to justify this disparity in sites of a similar scale is unclear.
Northstowe is consistently assumed to deliver 250 dpa but within the next 4 years is to deliver in excess of 300dpa. This approach would not appear to have been taken with regard to Table 18 of the HDS, which sets out that average build out rate of urban extensions delivering 2,000+ homes are 225-275. We would consider that setting out an expected delivery of over 300dpa for multiple years is highly optimistic and it is not clear from the evidence base how this is justified, to ensure no optimism bias this should be lowered to a more realistic average build out rate of 250dpa, which fits within the identified range above, with a peak of 300dpa in 1 or 2 years if it can be evidenced.
Windfalls
We further note the high windfall figure of 450 dwellings per annum that is expected to be delivered across Greater Cambridge, see HDS (October 2021). It is noted that the historic windfall allowance has traditionally been 350dpa, however a recent review of the data suggests that c.500dpa has been delivered across the area over the longer term. The 450dpa is made up of the top end of the range for 240-255 for South Cambridgeshire and 185-195 for Cambridge City.
However, the evidence appears to show that the windfall figures are elevated between the years of 2013 to 2018, i.e. the years in which the adopted Cambridge Local Plan was at Examination in Public. It is not surprising that windfalls would be higher in this period as non-allocated sites came forward without the benefit of an up to date adopted local plan, in effect the majority of housing supply would have been a windfall. Comparing this data with windfalls delivered in the period either side is less. Furthermore, the windfall ranges concluded on for Cambridge and South Cambridgeshire above seem to align very closely with the historic windfall figures for sites ‘including gardens’. This would run contrary to the NPPF paragraph 71 which states that plans should consider the case for setting out policies to resist inappropriate development of residential gardens, including these in a long-term windfall allowance could perpetuate this trend.
Housing requirement buffer
The HDS confirms that it is a recommendation that ‘at least a 10%’ buffer is applied to ensure an ‘over-allocation’ of land against the eventual housing requirement. However, as we have demonstrated above in the case of South East Cambridge and as we detail regarding Greater Cambridge as a whole in respect to Theme 5 – Jobs, the economy in this location is particularly robust and has seen strong levels of growth, despite the downward pressures placed on economic growth due to Covid 19. It is therefore a realistic expectation that job growth could be considerably higher than projected by the currently adopted scenario, which is demonstrated clearly by the spatial strategy suggested within the Cambridgeshire and Peterborough Independent Economic Review (CPIER) have referred to within their report that employment growth rates are far higher than have been indicated by official figures and that growth can be expected to keep increasing. Noting the overall thread of sustainability running through the Local Plan, it would seem appropriate to provide a higher buffer of dwelling to facilitate houses close to local sources of employment which have seen higher growth rates over the past few years, notably biomedical and technology industries which are prevalent in South East Cambridge.

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60272

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

Windfalls
We further note the high windfall figure of 450 dwellings per annum that is expected to be delivered across Greater Cambridge. It is noted that the historic windfall allowance has traditionally been 350dpa, however a recent review of the data suggests that c.500dpa has been delivered across the area over the longer term. The 450dpa is made up of the top end of the range for South Cambridgeshire and Cambridge City.
However, the evidence appears to show that the windfall figures are elevated between the years of 2013 to 2018. Comparing this data with windfalls delivered in the period either side is less. Furthermore, the windfall ranges concluded on seem to align very closely with the historic windfall figures for sites ‘including gardens’. This would run contrary to the NPPF paragraph 71 which states that plans should resist inappropriate development of residential gardens, including these in a long-term windfall allowance could perpetuate this trend.

Full text:

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60273

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

Housing requirement buffer
The HDS confirms that it is a recommendation that ‘at least a 10%’ buffer is applied to ensure an ‘over-allocation’ of land against the eventual housing requirement. However, the economy in this location is particularly robust and has seen strong levels of growth, despite the downward pressures placed on economic growth due to Covid 19. It is therefore a realistic expectation that job growth could be considerably higher than projected, which is demonstrated clearly by the spatial strategy suggested within the CPIER. Noting the overall thread of sustainability, it would seem appropriate to provide a higher buffer of dwellings to facilitate houses close to local sources of employment which have seen higher growth rates over the past few years.

Full text:

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60275

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

It is notable that there is a lack of new housing or employment allocations located on the south eastern edge of Cambridge. There are a number of strong employment and housing sites which are being retained, but no further allocations to help strengthen and build those new communities.
This is particularly surprising given the locational advantages that this particular area on the edge of Cambridge benefits from, notably the upcoming delivery of the Cambridge South train station. It would therefore seem unnecessarily restrictive of Greater Cambridge to limit the allocations for employment growth in this area solely to the Biomedical Campus.
The Councils should not arbitrarily limit themselves at this stage by not countenancing Green Belt release, particularly in those locations such as South East Cambridge where there is already an established employment cluster that could suitably accommodate further development.

Full text:

Context
The NPPF places great importance on building a strong, competitive economy, and states that: “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.” (Paragraph 81).
Planning policies and decisions should also “recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries.” (NPPF Paragraph 83).
The national and international significance of the Cambridge economy and its high technology clusters is recognised as a key component throughout the Reg 18 consultation. Cambridge has a leading presence in specialist sectors – including knowledge intensive businesses such as hightech manufacturing, life sciences and healthcare – and the retention and ongoing growth of these dominating sectors needs to be fully supported by the GCLP. The strength of Cambridge’s economy is typically attributed to the spatial concentration of local business networks within and on the edge of the city itself, which encourages sharing of knowledge and labour through economies of agglomeration, as well as the presence of a local, highly-skilled workforce which is driven by the esteemed Cambridge University and other research organisations. This was exemplified by the recent re-location of AstraZeneca’s global headquarters to the city in order to build on its relationship with leading research, academic and healthcare organisations based in and around Cambridge, which make it ‘one of the most exciting bioscience hotspots in the world’.
Future scale of employment growth in Cambridge
In this context, the Reg 18 consultation sets out the level of needs in Greater Cambridge that development will meet over the plan period of 2020 – 2041. For jobs, Policy S/JH proposes that the GCLP will meet the objectively assessed need for 58,500 new jobs, around 20,000 of which would be office and industrial jobs and the rest for jobs in services and support uses such as shops, schools and healthcare. This identified need is based on, albeit 100 jobs greater, the ‘Central Scenario’ (referred to as KS3) in the Greater Cambridge Employment Land and Economic Development Evidence Study (‘the employment evidence’). The Higher Scenario (KS2) forecast a need for 78,700 jobs over the plan period, compared to the central growth scenario of 58,400 jobs. Importantly, this is concluded to be the preferred – and recommended – range, and as such the two figures represent an upper and lower employment forecast to 2041. As it stands, the emerging GCLP only provides for the lowest identified need in this range (being just 100 jobs over the lower figure).
The authors of this study, GL Hearn, considered that the Central Scenario was appropriate over the Higher Scenario as per the below: “The reduction in growth rates is important to consider as it allows for the rate of growth in percentage terms to slow as the sectors expand, avoiding unrealistic absolute year-on-year changes in the sectors as they get larger.”
The highest growth projection scenario (KS1) was rejected because it “exceeds historic rates due to high long-term annual growth rates for growing individual sectors leading to disproportionate absolute change. This rate or level of growth should not be considered realistic given the population, development and environmental implications.”
Whilst it is noted that there is a possibility of individual sectors slowing in growth as they expand, those particular sectors which have primarily driven growth in Greater Cambridge such as tech and biomedical have not seen such a slowdown in growth. The assessment of the scenarios in the Greater Cambridge Employment Land and Economic Development Evidence Study looks at trends between 2001-2017 and 1991-2017, i.e. not taking into account growth in the past four years. Indeed, sectors such as tech and biomedical have accelerated over the Covid19 period and certainly since 2017. It is therefore considered that the evidence to support the adoption of the Central Scenario is lacking, and that the prevalence of these high growth sectors and their unfettered growth in challenging economic conditions would point to continued long term growth with associated higher long term job growth for Greater Cambridge. On this basis, planning for the ‘Central Scenario’ is not a sound, or realistic approach to planning for job growth in Greater Cambridge.
Further, the Reg 18 consultation acknowledges that the employment evidence suggested providing flexibility in employment land in case the market delivers more jobs than anticipated. This reflects the Cambridgeshire and Peterborough Independent Economic Review (CPIER), which considered employment projections that were even greater than the ‘Higher Scenario’ set out by the Councils. In their final report published in September 2018, the Independent Review judged that the most reasonable level of employment growth is that which assumes a continuation of recent higher employment growth rates, which have come in the context of nationally high employment growth, before gradually returning to longer-term levels. This would be in line with the much higher rates of growth that have been occurring in the Greater Cambridge area.
Importantly, the Independent Review also notes that there has been an under-projection of employment growth in the area; in other words, high employment growth has been unanticipated and therefore not built into targets. The East of England Forecasting Model (EEFM) is the primary model used to inform local plans in this region, and the report states that EEFM’s projections for employment growth in recent years fell below the actual output by a significant margin. In the aforementioned employment and economic evidence study, the Councils confirm that their preferred approach to employment forecasting involved using the EEFM; if employment growth continues to be significantly above that forecast by this model, then the GCLP will not provide for enough development (jobs and homes, which must be planned for in parallel to ensure unsustainable commuting patterns and worsening of affordability to not go unchecked). This is particularly significant given that the Reg 18 consultation is currently planning for the lower end of the recommended employment forecast.
The under-estimation of employment growth in Cambridge has been evident in recent years; since 2011 (the start of the current plan periods) Greater Cambridge has seen between 56% and 91% (depending on which source is used) of all jobs planned for in the 2011-31 period (41,400), despite only being around one-third of the way into the plan period. Given there is clear historic evidence of employment growth running higher than anticipated, it is vital that the GCLP recognises the likelihood of this continuing and allows for flexibility, particularly by expressing any employment figure in the plan as a clear ‘minimum’. The Council should also consider an early review mechanism if employment growth continues to run substantially above anticipated levels, in order that sufficient sites can be brought forward more quickly to accommodate this growth.
Taking the above points together, there is clearly justification for including higher employment related figures in the GCLP. The national importance of the Greater Cambridge economy, combined with world-renowned clusters and the strong performance of knowledge intensive sectors, has the potential to drive growth beyond the relatively modest figure in the emerging GCLP. The persistently higher growth rates in the Cambridge city region are also emphasised by other relevant stakeholders, including Cambridge Ahead. The need for flexibility to respond to economic opportunities is central to the NPPF (as cited above) but also the PPG (ID: 2a-027) with its requirement for plans to “consider and plan for the implications of alternative economic scenarios.”
Spatial options for employment
When considering the Spatial Strategy that the Greater Cambridge Local Plan is pursuing, it is notable from a review of the First Proposals map that there is a lack of new housing or employment allocations located on the south eastern edge of Cambridge. As can be identified through the existing allocations from the Cambridge City Local Plan within Policy S/EOC: (Other site allocations on the edge of Cambridge), there are a number of strong employment and housing sites which are being retained, but no further allocations to help strengthen and build those new communities which were started under the existing Local Plan, and provide no further options for growth for those important business locations. Notably within South East Cambridge, these include Peterhouse Technology Park and the allocations GB1 -4 which provide for both housing and employment uses.
This is particularly surprising given the locational advantages that this particular area on the edge of Cambridge benefits from, notably the upcoming delivery of the Cambridge South train station that is proposed at the Biomedical Campus. As is confirmed by the Transport and Works Act Order (TWAO) application made by Network Rail on the 18th June 2021 the proposed station will be supported by significant infrastructure upgrades, including the provision for 1,000 cycle parking spaces and improved roads/crossings to provide access to the station. As such, the station will be highly accessible by cycle, and sites with existing allocations such as the land south of Peterhouse will be easily accessible by cycle. It would therefore seem unnecessarily restrictive of Greater Cambridge to limit the allocations for employment growth in this area solely to the Biomedical Campus, and not to other strong employment locations such as those existing allocation sites GB3-4 which are within short public access of the new train station.
In addition to the overall need for new jobs, Table 3 in the Councils’ employment evidence also confirms that there is a demonstrable need for B1a/b uses, with projections showing that there will be a significant undersupply across the GCLP period even after the potential contribution of B1 mixed sites is taken into account. The evidence suggests that this reflects that most of the projected demand in B1b is assumed to be for research and development (R&D) employment, and that if the ‘higher growth scenario’ was achieved over the plan period then the current pipeline of supply is likely to be insufficient.
Businesses evidently want to tap into the location of Cambridge, and our site’s location to the south eastern edge of the city has existing connections to the rest of the Cambridge economy. Further Green Belt release would be justified in this area to facilitate further economic growth extensions at the PTP site in the context of Cambridge’s local need. This leads us on to the consideration of the identified locations for employment growth in the Reg 18 consultation.
The GCLP consultation sets out the proposed strategy for development in Greater Cambridge and Policy S/DS provides detail on where the homes and jobs identified in Policy S/JH should be provided in order to meet the vision and aims of the local plan. The growth strategy appears to be separated into five distinct locations – namely the Cambridge urban area, the edge of Cambridge, new settlements, the rural southern cluster, and the rest of the rural area – with the amount of proposed development differing in these areas according to their scale, characteristics and sustainability.
While the development strategy is not overtly clear on which sites will specifically include employment uses to accommodate the need for new jobs, Policy S/DS suggests that the overall focus for employment growth – some of which relates to mixed-use sites – will be at North East Cambridge, Cambridge East, Cambridge Biomedical Campus, Babraham Research Campus and other new or continued sites, primarily within the Cambridge urban area and existing business parks at the Rural Southern Cluster. The policy clearly lists the specific sites that will contribute to meeting the housing need requirement, setting out the quantum of homes to be delivered at those sites over the plan period, however it does not provide the same transparent approach with regards to the supply of jobs (i.e. sites for employment).
The GCLP provides further detail on new employment development proposals in Policy J/NE. This policy supports employment development in Cambridge at the sites set out in the development strategy and within appropriate mixed use areas of major change and opportunity areas, and states that other employment proposals in Cambridge will be considered on their merits where they are of an appropriate scale, character and accessible location. The policy goes on to specify a range of sites which are particularly suited to supporting the need of clusters, which include significant opportunities at:
• North East Cambridge
• West Cambridge
• North West Cambridge
• Cambridge Biomedical Campus
• Welcome Trust Genome Campus
• Granta Park
• Babraham Research Campus
• New Towns at Northstowe and Waterbeach.
While the policy recognises that cluster related employment is not restricted to these areas, the GCLP is not currently proposing to direct growth towards South East Cambridge – and neither is it identified as a proposed location for further employment development. It is considered that, given the need to plan for higher employment growth, the spatial approach and proposed allocations are somewhat limited and do not fully explore the potential of South East Cambridge to support other existing clusters. The site provides an opportunity to deliver additional employment land in a sustainable location; fundamentally, it can facilitate growth despite its current location within the Green Belt.
As such, the Councils should not arbitrarily limit themselves at this key stage in the local plan process by not countenancing Green Belt release, particularly in those locations such as South East Cambridge where there is already an established employment cluster that could suitably accommodate further development. The expansion of the PTP cluster should be specifically supported by the GCLP, and the Green Belt release of such sites could in fact lead to more sustainable outcomes, for example by facilitating a nature network as discussed in the previous section, and by delivering jobs in close proximity to homes.
The needs of specific sectors
Moreover, the specific need for further employment provision in specialist sectors – as identified throughout the GCLP and supporting employment evidence – means that there will be demand for further expansion of clusters that currently support these types of businesses and/or technologies. Arm Holdings (‘ARM’) is the anchor tenant at PTP and is a driving force in the global semiconductor (computer chip) industry. Its primary business is in the design of ARM processors (CPUs), for which it is considered to be market dominant, and it is one of the best-known ‘Silicon Fen’ companies (also known as the Cambridge Cluster).
There is currently a worldwide shortage in semiconductor production, which is not expected to end in the short-term, and ARM is therefore one of the companies that is well positioned to help address increasing industry demand. Millions of everyday products, such as cars, smartphones and fridges, rely on semiconductors and demand for new products that use semiconductors will only continue to grow. Further investment in semiconductor manufacturing capacity to boost supply is anticipated, and ARM is a leading global company set within the context of Cambridge’s economy which has an international reach. The demand for further expansion of ARM at PTP, which has emerged as a significant high-tech employment cluster, beyond 2041 can therefore be expected.
Considering the strength of and continued need for specialist sectors in Cambridge, it is also of importance that jobs in these sectors are unlikely to have been – or will continue to be – negatively impacted by COVID-19. The Reg 18 consultation document states that the employment evidence is based upon pre-COVID-19 data. However, the strength of Cambridge’s knowledge-intensive sectors, particularly its globally renowned life sciences cluster, has only been underscored by the recent COVID-19 pandemic and as a result, job growth has and will continue to trend upwards. A report by New London Architecture (NLA) highlights the contribution of the life sciences sector to the national economy and states that it is one of the most resilient sectors. While one of the most significant impacts of COVID-19 is the rise of homeworking, the nature of most jobs in life sciences requires employees to be physically present. As the economy adjusts to the ‘new normal’ it therefore seems apparent that both the global reach of Cambridge’s life sciences cluster and demand for space in this sector will only continue to grow.
How do other options compare?
New settlements
As previously noted, areas beyond Cambridge City are unproven employment markets; demand for employment space remains primarily in and on the edge of Cambridge City.
The emerging GCLP identifies Cambourne as a broad location for longer term strategic scale growth, with part of the settlement’s role to be a growing employment centre to provide local opportunities for its residents and nearby communities. However, Policy S/CB states that future development at Cambourne will need to consider: The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy. This suggests that there is no latent demand from existing occupiers or a particular need arising in this location for specific forms of employment space. As is confirmed below through a planning history review, existing provision on site includes predominantly general office space rather than research and technology companies which tend to gravitate to specialist clusters on the edge of Cambridge such as that at PTP. Policy S/NS sets out the direction for the three new settlements of Northstowe, the new town north of Waterbeach, and Bourn Airfield new village, which are proposed to continue to grow during the period of the new Local Plan and beyond, including elements of employment development.
Neither policy is clear on the amount or type of employment development that is to be allocated or supported in these new settlements. Historically, Cambourne and Northstowe have been delivering housing at relatively strong rates and are better associated with residential orientated development. A review of the relevant evidence and recent planning applications relating to potential employment development at the new towns indicates the following:
1 Waterbeach – Arguably the strongest potential new settlement for employment development due to the proximity of the existing Cambridge Innovation Park and Cambridge Research Park, which lie adjacent to the new town. Waterbeach is likely to build on the ICT/professional services and biotech sectors located at the existing parks and the site is coming forward through two large applications under two land ownerships.
Planning applications comprise: an outline application for 6,500 homes and 15,000m² of business (B1) floorspace, including small to medium sized offices, light industrial workshops, studios and maker spaces (reference S/0559/17/OL, approved 2019); an outline application for 5,500 homes and up to 22,400m² B1a office and 2,400m² B1c/B8 light industrial, storage and distribution space (reference S/2075/18/OL, awaiting decision); and a further application for the expansion of the Innovation Park, including new office buildings and floorspace (reference 20/05253/FUL, awaiting decision).
2 Cambourne – The extension of Cambourne (Cambourne West) is located immediately adjacent to the existing Cambourne Business Park, which contains larger scale office accommodation occupied by a mix of businesses in professional services, IT, telecommunications and research and development. The employment evidence confirms that the Business Park itself ‘has taken some time to work towards being an established employment location’, raising questions on the potential for the extension to deliver further employment space.
Outline planning permission was granted in 2017 for the Cambourne West extension (reference S/2903/14/OL), which included land for the provision of up to c.6ha of B1 employment space, anticipated to be small offices, R&D and clean technology businesses – however to date there does not appear to be further activity on this provision. Significantly, the land directly south of the Business Park is being promoted for residential development only; a screening opinion was recently submitted for 300 new homes (21/03771/SCRE).
3 Bourn Airfield – Located to the east of Cambourne, planning applications at Bourn Airfield suggest that the site is expected to deliver a mixed-use village comprising of 3,500 dwellings and supporting uses including 1,500m² of employment floorspace comprising offices, R&D and light industry (Class B1a, b and c uses) (reference S/3440/18/OL, awaiting decision). A further application, granted in January 2021, includes provision for an additional 24,620m² of employment space consisting of a mix of B1b (research and development), B1c (light industrial) and B8 (storage and distribution) (reference 20/02568/FUL).
4 Northstowe – The employment evidence makes clear that ‘Northstowe has a challenge in bringing forward employment under the current strategy’. The new town will eventually include up to 10,000 new homes and a range of other uses. Planning applications to date suggest that there will be a series of employment area parcels across the phases of development in association with the town centre and local centres, primarily for mixed B1 uses, however no employment floorspace has yet been completed within the new settlement which is in early phases of development. There are a number of other identified employment locations that are either established or seeking market position – including Cambourne and Waterbeach.
While this review provides an insight into potential employment development in the new town designated areas, it is not clear how much, and what type, of employment space is already permitted against that still being proposed in the emerging GCLP. As noted previously, the Reg 18 consultation does not set this out in a transparent way, and it is difficult to ascertain whether or not the importance (and delivery) of employment growth that is being proposed at these new towns is likely to materialise or be successful. If Cambridge wants to fully capitalise on its economic success then it must maximise the development potential of employment sites located close to established employment clusters which attract the best businesses and workers; this is an opportunity available to Greater Cambridge at Land South of Cambridge.

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60276

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, aka Cambridge South East (HELAA site 40058)

The development strategy is not overtly clear on which sites will specifically include employment uses to accommodate the need for new jobs. The policy clearly lists the specific sites that will contribute to meeting the housing need requirement, setting out the quantum of homes to be delivered at those sites over the plan period, however it does not provide the same transparent approach with regards to the supply of jobs (i.e. sites for employment).
It is difficult to ascertain whether or not the importance (and delivery) of employment growth that is being proposed at these new towns is likely to materialise or be successful. If Cambridge wants to fully capitalise on its economic success then it must maximise the development potential of employment sites located close to established employment clusters which attract the best businesses and workers.

Full text:

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60281

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, aka Cambridge South East (HELAA site 40058)

Growth at Waterbeach, Northstowe, Bourn Airfield and Cambourne are an important part of the strategy for development. Such areas are unproven employment markets. This is illustrated by the ongoing challenge that Cambourne and Northstowe face in delivering employment growth. Demand for employment space (including lab and office space) therefore remains in and on the edge of Cambridge City.
Locating employment development beyond the urban area of Cambridge will only serve to drive unsustainable travel patterns as local residents increasingly need to use the car to commute. The combination of unproven employment markets and unsustainable travel patterns associated with the new towns therefore raises questions around the proposed strategy towards employment growth in these areas, and it is considered that this is contrary to the aims of the central climate change theme.

Full text:

Context
Climate change is fundamental to the NPPF’s environmental objective of sustainable development, stating that: “The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.”
The emerging GCLP is strongly influenced by reducing climate impacts, through compact development located to connect homes with jobs and where active and sustainable travel can be maximised. The proposed development strategy for the Greater Cambridge area is subsequently focused on directing development 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 (as set out in Policy S/DS).
CEG agrees with the emphasis placed on the need to decrease climate impacts and support the aim to help Greater Cambridge transition to net zero carbon by 2050. To achieve this, the Reg 18 consultation recognises that development should be sited in places that help to limit private car use and, in turn, carbon emissions. In the context of South East Cambridge, the Plan states that: ‘Our evidence shows that the edge of Cambridge could be a sustainable location for homes and jobs, being accessible to existing jobs and services.’
How do other options compare?
New settlements
Within the overarching climate change context, it is important to consider the proposed development at new settlements, as well as the associated impacts. Section 2.4 of the Reg 18 consultation document suggests that growth at Waterbeach, Northstowe, Bourn Airfield and Cambourne is an important part of the strategy for development – all of which lie beyond the Cambridge Green Belt to the north and west of the city (within the previous South Cambridgeshire plan area).
Such areas beyond Cambridge City and the edge of Cambridge are unproven employment markets. While Waterbeach does benefit from an existing agglomeration of employment uses, it is evident that businesses want to be sited where they can tap into the presence of other local business and research networks, a local highly skilled labour force and Cambridge University, and this means being located in or near the city. This is illustrated by the ongoing challenge that Cambourne and Northstowe face in delivering employment growth; while they may be effective in housing delivery terms, these new settlements do not contain established clusters of knowledge-intensive sectors and they struggle to recreate the economic magnetism of the city itself. Demand for employment space (including lab and office space) therefore remains in and on the edge of Cambridge City.
This is an important point within the climate change theme. As to be expected, locating employment development beyond the urban area of Cambridge will only serve to drive unsustainable travel patterns as local residents increasingly need to use the car to commute. This was highlighted throughout the transport evidence, in which new settlement strategic spatial options tended to score lower than those focused around the city or on the edge of the city, including in the Green Belt, because travel to work patterns are not characterised by active modes of travel. The combination of unproven employment markets and unsustainable travel patterns associated with the new towns therefore raises questions around the proposed strategy towards employment growth in these areas, and it is considered that this is contrary to the aims of the central climate change theme.

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60284

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

Land West of Elizabeth Way, Gamlingay (HELAA site 40300)

There are no proposed allocations in Gamlingay, and very little residential development proposed for the rural areas - questions whether the Council will meet the NPPF target for small and medium sized sites (paragraph 69). The GCLP needs to provide for a range of different housing needs which allows smaller settlements and rural areas to continue to thrive (paragraph 79 of the NPPF).

There is also a need for sites to be allocated which can deliver the required level of affordable housing which is a needed both in the urban and rural areas. Dependence on the allocation of strategic sites with already high infrastructure burdens is unlikely to offer sustainable, long-term solutions to the chronic and worsening affordability issues. Strategic sites alone do not deliver policy-compliant levels of affordable housing, so, more smaller sites need to be allocated.

Full text:

There are no proposed allocations in Gamlingay as part of the emerging GCLP, and very little residential development proposed for the rural areas as a whole which questions whether the Council will meet the NPPF target of delivering at least 10% of their housing requirement on small and medium sized sites (as set out within paragraph 69 of the NPPF). Land to the West of Elizabeth Way, Gamlingay would provide a sustainable medium sized site providing much needed affordable housing. The GCLP needs to provide for a range of different housing needs which allows smaller settlements and rural areas to continue to thrive. This is in accordance with Paragraph 79 of the NPPF which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

There is also a need for sites to be allocated which can deliver the required level of affordable housing which is a need both in the urban and rural areas. According to recent housing needs projections, an annual net need of 435 affordable rental units and 105 affordable units for homeownership will be needed across South Cambridgeshire to satisfy housing demands. Dependence on the allocation of strategic sites with already high infrastructure burdens is unlikely to offer sustainable, long-term solutions to the chronic and worsening affordability issues manifesting across the Greater Cambridge area. Strategic sites alone do not deliver policy-compliant levels of affordable housing, so, if this is the target, more smaller sites that are far more likely to deliver a policy-compliant level of affordable homes at a faster rate need to be allocated.

The First Proposals plan is heavily reliant on the delivery of a handful of strategic developments, particularly large and complex sites which, on average, would take 5-8 years for the first home to be delivered. To ensure that housing delivery does not stall, and the affordability crisis worsened as a result, a pipeline of smaller developments which can deliver homes quickly will be needed in the short-to-medium term. Site 40300, Land West of Elizabeth Way, Gamlingay is suitable, available, and deliverable within 0-5 years.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60295

Received: 13/12/2021

Respondent: Miller Homes - Fulbourn site

Agent: Turley

Representation Summary:

Land of Shelford Road, Fulbourn (HELAA site 51610)

South Cambridgeshire is a rural district with no large towns, and a number of rural and minor rural centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing centres. The spatial strategy however fails to do this.
Plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlements as part of the development strategy. However, due to the significant infrastructure requirements and lead in times associated with these sites, it is critical that a range of smaller and medium sized sites are also included. Such sites deliver more homes earlier in the Plan period and thus complement the longer-term delivery at the larger strategic sites and new settlements. The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge.
We do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities (paragraph 79 of the NPPF).

Full text:

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the 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.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land off Shelford Road, Fulbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and dedicated cycle routes into the City Centre and Cambridge Biomedical Campus, including Addenbrooke’s Hospital, the Councils have not proposed any new site allocations around Fulbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

Attachments:

Representations to the GCLP First Proposals - Miller Homes (13.56 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60302

Received: 13/12/2021

Respondent: Miller Homes - Melbourn site

Agent: Turley

Representation Summary:

Land south of Cambridge Road, Melbourn (HELAA site 47903)

South Cambridgeshire is a rural district with no large towns, and a number of rural and minor rural centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing centres. The spatial strategy however fails to do this.
Plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, due to the significant infrastructure requirements and lead in times associated with these sites, it is critical that a range of smaller and medium sized sites are also included. Such sites deliver more homes earlier in the Plan period and thus complement the longer-term delivery at the larger strategic sites and new settlements. The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge.
We do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities (paragraph 79 of the NPPF).

Full text:

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the 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.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land south of Cambridge Road, Melbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and a good range of services, the development strategy as currently drafted proposes relatively limited growth around Melbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

Attachments:

Representations to the GCLP First Proposals - Miller Homes (5.93 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60310

Received: 13/12/2021

Respondent: Gladman Developments

Representation Summary:

The Councils should seek to allocate a range of sites, by size, type and market locations to ensure that the Local Plan delivers identified housing need for the region. Growth should be dispersed across the settlement hierarchy and the region to ensure future sustainability and vitality.
Recognise that some Green Belt land may need to be released to meet needs, but not in excess of meeting the needs. The methodology used to assess Green Belt land needs to be suitably robust and clearly demonstrate that exceptional circumstances exist. There may be no alternative to Green Belt release to meet some of the needs of Cambridge, however its unlikely to justify Green Belt release in the villages and towns.
Many settlements are sustainable and capable of accommodating growth, and residential development performs a key role in maintaining and enhancing their sustainability and vitality. Growth should be directed to those settlements which have not experienced development in the current plan period.
It is vital that the Councils are not overly optimistic in the projected delivery rates of new strategic sites or overly reliant on these sites to deliver need as often subject to significant infrastructure costs and provision.

Full text:

The proposed direction of this policy focuses development in and around the City of Cambridge and through new settlements. Some development is proposed in the Rural Southern Cluster area of South Cambridge, including Green Belt land, and minimal development is proposed in the rest of the rural area.
The Councils should seek to allocate a range of sites, by size, type and market locations to ensure that the Local Plan delivers identified housing need for the region. Growth should be dispersed across the settlement hierarchy and the region to ensure future sustainability and vitality. Growth should also be focused along sustainable transport corridors, such as the Melbourn to Cambridge corridor in the southwest of the area. This corridor is a sustainable location for growth, offering sustainable transport options in to Cambridge whilst allowing housing needs to be met without releasing Green Belt land in the rural southern cluster.
While Gladman recognise that some Green Belt land may need to be released to meet the needs of Cambridge City, the release of Green Belt land in excess to meeting the City’s needs is unnecessary. As outlined at paragraph 140 of the NPPF (2021);
‘Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.’
The Councils must ensure that the methodology used to assess Green Belt land is suitably robust and can clearly demonstrate that exceptional circumstances exist to justify the release of Green Belt land.
Furthermore, the release of Green Belt should not be the primary source of developable land when other suitable and sustainable sites are available outside of the Green Belt. This is clearly outlined at paragraph 141 of the NPPF (2021) which states;
‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.’
It is recognised that there may be no alternative to Green Belt release to meet some of the needs of Cambridge on the edge of Cambridge, however that is unlikely to justify Green Belt release on in the villages and towns. It is imperative that the Councils have considered, assessed, and rejected all other reasonable options to get to that point.
The site submissions at Section 10 and the accompanying appendices demonstrate several available sites that would not require the loss of Green Belt and supports the NPPF’s (2021) assertion later within paragraph 141 that sites in ‘other locations well served by public transport’ should be optimised. Currently, the proposed spatial strategy disproportionately directs growth towards Cambridge City and fails to account for and direct growth towards the sustainable villages on key transport corridors in South Cambridge.
Many settlements, including rural service centres, are sustainable and capable of accommodating growth which ensures their continued vitality. The accompanying Linton StoryMap and Meldreth StoryMap explore this in greater detail. While Gladman support growth in Cambridge, there should be sufficient growth directed towards the rural areas, particularly in South Cambridge in line with the housing needs of the area. The Council must recognise that residential development performs a key role in maintaining and enhancing the sustainability and vitality of settlements. Growth should be directed to those settlements which have not experienced development in the current plan period to ensure the future prosperity of the area and ensure the vitality and continued use of services and facilities within the villages remain over the plan period.
In addition, while strategic sites in close proximity to economic hubs and Cambridge City will form an important aspect of the Plan’s strategy, it is vital that the Councils are not overly optimistic in the projected delivery rates of such sites. Additionally, the Councils should not be overly reliant on strategic developments to deliver identified need as such sites are often subject to significant infrastructure costs and provision. The Councils should also be mindful that new settlements may not be delivered within the plan period up to 2041 and are often subject to lengthy delays. To ensure that this does not impact overall housing delivery, the Councils should seek to allocate small to medium sized sites in sustainable locations that can be delivered by smaller housebuilders and are less likely to incur significant delays.
Fundamentally, the distribution of development should not be a politically driven decision, but one based on robust evidence and consideration of a number of factors such as local housing needs and settlement sustainability. Green Belt land should not be released unless exceptional circumstance can be demonstrated and all other reasonable, suitable alternative sites have been considered.
Overall, the Local Plan will need a balanced strategy, including a variety of different elements to ensure delivery over the course of the plan period and to meet the needs across the plan area. It is important that the Councils do not place an over reliance on just one type of approach, in this case, large scale urban extensions and new settlements, as this could hinder delivery of much needed housing.

Attachments:

Representations to the GCLP First Proposals - Gladman (1.26 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60323

Received: 13/12/2021

Respondent: Daniels Bros (Shefford) Ltd

Agent: DLP Planning Ltd

Representation Summary:

Land north of Craft Way, Steeple Morden (HELAA sites 40440 & 40442)

The Plan does not provide for an appropriate strategy which will meet the housing requirement and provide for the necessary flexibility sought. Soundness concerns are raised relating to the delivery of large-scale development proposals; the failure to recognise the role of growth in the rural areas in sustaining levels of housing delivery and the overreliance on assumptions regarding windfall, contrary to paragraphs 71 (regarding expected future trends) and 66 of the Framework (regarding the identifying housing requirements for the rural area).

Full text:

(i) Introduction
The Plan seeks to identify land to deliver additional homes beyond the 37,200 dwellings currently in the supply. The Plan therefore has identified land that the Councils’ consider capable of delivering 11,460 dwellings. This includes a 10% buffer in addition to the proposed housing requirement of 2,111 dwellings per annum set out in Policy S/JH so as to ensure flexibility to deal with unforeseen circumstances.
A ‘whole plan buffer’ is both supported and considered necessary to enable the housing requirement to be met, with any failure to meet the requirement likely to mean that the Plan area’s needs are not met contrary to the objectives of national policy. A whole plan buffer future-proofs the plan and makes it more robust.
Sitting behind the ‘First Proposals’ is the November 2020 Development Strategy Options Report, which sets out 8 strategic options for growth. These options are as follows;
• Densification of existing urban areas;
• Edge of Cambridge – Outside Green Belt;
• Edge of Cambridge – Green Belt;
• Dispersal – New Settlements;
• Dispersal – Villages;
• Public Transport Corridors;
• Integrating jobs and homes – southern cluster;
• Growth focussed on Public Transport Nodes – Cambourne/A428
As set out in the Committee version of the ‘First Proposals’, the proposed development strategy for Greater Cambridge 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”.
Development is expected to be focussed on the edge of Cambridge and by expanding the ‘new settlements’ at Cambourne, Northstowe, Waterbeach and Bourn Airfield. Some minor development is proposed in the rural area to the south of Cambridge (the Rural Southern Cluster), with very limited development across the rest of the Greater Cambridge Plan area.
As set out in these representations it is considered that the higher growth scenarios provide a true reflection of the actual demand for housing linked to reasonable forecasts for employment growth. However, even using the Councils’ ‘medium’ scenario, without prejudice to the reservations in these representations, the Councils’ Preferred Approach represents a significant increase in the requirements for development.
To address this, the Councils are only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites within the confines of the existing strategy. In practice, the risks to delivery mean that the Councils’ stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period with very limited additional sources of flexibility.
This concentration of development in the Cambridge and the ‘new settlements’ will only further exacerbate the affordability problems in the remainder of the rural settlements. Paragraph 79 of the Framework seeks to promote sustainable development in rural areas to maintain and enhance rural vitality and viability. It is essential, therefore, that the needs of the sustainable rural settlements across the Plan area are assessed and a meaningful level of growth apportioned to them to ensure their ongoing vitality and viability. This will help to preserve and enhance rural services and facilities and allow local rural communities to meet their own needs for housing whilst providing much needed affordable housing in the parts of the borough that suffer with the greatest affordable housing need.
In addition to the need to support a wider spectrum of settlements, a reliance on strategic scale growth should be carefully considered. With the potential for multiple factors to cause delay in the delivery of the large strategic sites including, for example, infrastructure which often takes longer to come forward than envisaged. Arguably the low contingency and over reliance on strategic sites, exposes the Plan to a greater degree of uncertainty and risk. To remedy this, arguably the Plan should propose the allocation of further, non-strategic sites that could be delivered quicker and would ensure a rolling provision of housing.
Within this context an increase in the overall buffer to at least 20% should be considered. This would better address the need to recognise risks to the planned strategy and would also be a more appropriate measure to reflect the Council’s reliance on windfall supply. To ensure that the Plan is effective a significant proportion of any buffer should be accommodated specifically through support for the allocation of sites in the rural area.
In distributing the growth, the Plan could also act to maximize housing supply across the widest possible range of sites, by size and market location, so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products. The key to increased housing supply is the number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increases housing delivery and the success of the Plan.
(ii) Summary of Housing Delivery Concerns within the First Proposals Strategy Options
There is significant research that considers the lead-in and rate of delivery of development on the scale of that proposed at North-East Cambridge, Northstowe, Cambourne and Waterbeach. The level of infrastructure required and the ability to have multiple builders on one site often results in slower delivery than anticipated by Councils. It should be noted that as is set out in Policy S/DS, in addition to the expected delivery in line with the adopted Local Plans, additional delivery, or the faster delivery of homes, is expected to contribute to the additional 11,640 homes planned for. Whilst it is not necessary to revisit the allocations that have already been subject to Examination and subsequently adopted, it is reasonable to consider, on the basis of new evidence, the contribution that they can make to meeting the overall housing need of 2,111 dwellings per annum plus 10% buffer over the 2020-2041 plan period.
Lichfields’ “Start to finish” (Second Edition) states that the average annual build-out rate for a schemes of 2,000+ dwellings is 160 dpa with a median of 137dpa. It should be acknowledged that not all sites will deliver at this rate. Further, the Lichfields research shows that if a scheme of more than 500 dwellings has an outline permission, then on average it delivers its first home in approximately 3 years. However, from the date at which an outline application is validated, the average figures can be between 5.0 and 8.4 years for the first home to be delivered; such sites would make no contribution to completions in the first five years.
The largest proposed allocation in respect of contribution to meeting the additional housing requirement of 11,640, is that at North-East Cambridge (S/NEC) The Councils are proposing mixed use development including residential uses, with an Area Action Plan currently being prepared. The Councils have assumed that North-East Cambridge will have some early delivery on the Chesterton Sidings parcel, but to date only pre-application discussions have occurred. The build out rates, of 350 dpa are based on the recommendations set out in the Housing Delivery Study. It is unclear how the Councils have determined that the proposed allocation will deliver 3,900 dwellings over the plan period given that the Housing Delivery Study suggests, against an unjustified build-out rate, only 2,200 dwellings will be delivered to 2041.
In respect of Cambridge Airport (S/CE), the main landowner, Marshall of Cambridge, announced in April 2010 that the relocation of Cambridge Airport would not happen before 2031 at least, as there were currently no suitable relocation options. Despite this under Policy S/DS, the site is expected to contribute 2,850 dwellings by 2041. Once again, this figure differs from the yield set out in the Housing Delivery Study, which sets out a maximum contribution of 2,200 dwellings over the plan period.
The Councils have assumed that the site will contribute 50 dwellings in 2033, just two years after the 2031 date for the relocation of the airport. In reality, it is likely that this 2031 deadline for identifying suitable sites and relocating the airport will be missed and even if it were to be hit, given the work that would be required to bring the site into a suitable condition to accommodate residential development, there is very little reasonable chance of anything being delivered in 2033. Realistically, it is unlikely that the site will contribute more than 400 dwellings over the plan period.
In respect of Northstowe, it is noted that in addition to the expected delivery set out in the adopted Development Plan, an additional 750 dwellings (faster delivery of homes already planned) are expected to contribute to the 11,640 additional dwellings being planned for.
As is set out in the latest Annual Monitoring Report, even with 5-housebuilders on-site, the average number of dwellings completed between 2016 and 2020 on the Northstowe site thus far, is just 169 per year. The Councils’ trajectory, set out in the Housing Delivery Study, requires 300 dwellings per annum to be delivered on-site. If the historic rate of delivery were to be carried through over the 2020-2041 plan period only 3,549 dwellings would be delivered against the Councils’ assumption of 6,304 and clearly the additional 750 dwellings being planned for under Policy S/DS would simply contribute to the currently adopted requirement only.
It is noted that significant weight is being placed on the modern methods of construction proposed for Phase II of the Northstowe development and the rate of delivery indicated by Homes England on the other Phases. There appears little by way of clear evidence to suggest that this will result in increased delivery beyond the average already demonstrated.
In line with the standard assumptions being made in respect of delivery, the Housing Delivery Study expects the Waterbeach New Town to deliver between 250 and 300 dwellings per year from 2023/2024, or 5,700 over the plan period to 2041. If the average of 160 dwellings per annum, as is set out in the Lichfield’s research, were to be applied, the contribution that the site could make to meeting the plan period housing requirement would be just 3,120 dwellings. Further, it is accepted, as confirmed in the South Cambridgeshire Local Plan Inspector’s Report, that the site requires significant investment in infrastructure and, realistically, may not start to deliver new housing until the mid or later years of the plan period.
Given the above, there are serious concerns in respect of the ability of a number of strategic allocations to deliver development at the scale that is required to meet the identified housing proposed housing requirement of 2,111 dwellings plus a buffer, let alone the requirement of 2,549 dwellings plus a buffer that is justified on the basis of economic growth and funding.
(iii) Levels of Growth in the Rural Area and Contribution to Overall Supply
Accordingly, the Greater Cambridge Plan fails to identify sufficient land for housing to meet the housing requirement. The identification of additional land should recognise that allocating a range of sites, both in terms of size and location, will provide the best reasonable prospect of meeting and maintaining the supply of housing as is required by national policy.
Page 40 (Figure 10) of the ‘First Proposals’ consultation indicates that the Greater Cambridge Local Plan strategy (including windfalls) would achieve only 18% of growth in rural areas over the 2020 to 2041 period. This is a substantial reduction on the distribution of growth in previous development plans. The Councils’ evidence base demonstrates that this approach is unsound: not effective and not consistent with national policy including providing for flexibility in accordance with Paragraph 82 of the NPPF2021.
The Councils fail to recognise the role of growth in the rural areas in sustaining the benefits associated with recent increases in delivery.
The most recent April 2021 Housing Trajectory suggests that allocations in rural areas of South Cambridgeshire will comprise around 15% of delivery between 2021/22 and 2025/26. This increases to over 40% (around 930dpa in total) when Unallocated Sites with Planning Permission or Resolution to Grant Planning Permission in South Cambridgeshire are included, which predominantly comprise land within the rural areas and a number of schemes granted when the Council was previously unable to demonstrate a robust five year supply. The Councils’ latest Authority Monitoring Report reflects that this will sustain recent levels of completions being disproportionately concentrated in South Cambridgeshire and not principally related to the delivery of Urban Fringe/New Settlement sites.
Adopting these broad assumptions this total (4650 dwellings) would comprise around 50% of the 18% total growth allowed for in rural areas but forecast for delivery ahead of adoption of the Greater Cambridge Local Plan. This would broadly tally with the Councils’ assumptions that windfall in South Cambridgeshire (2,570) plus small allocations in the southern cluster and rural area villages (384 dwellings) and remaining commitments on allocated rural sites (1,903) and unallocated sites (1,539) (6,396 dwellings total) would comprise the remaining potential sources of supply in rural areas. A small proportion of these categories would nonetheless relate to other components of the spatial distribution.
The practical implication is that average growth in the rural areas for the remaining 15 years of the plan period is likely to amount to only 310 dwellings per annum. This reinforces that the evidence in the Housing Delivery Study does not support the conclusion that rates of completions exceeding 2,000 homes can be achieved without a significantly greater proportion of supply from rural areas.
(iv) Windfall and Small Sites Delivery Assumptions
The Councils’ assumptions for windfall supply over the 2020 to 2041 plan period (5,345 dwellings) exceed the total allowance for flexibility within the trajectory (4,400 dwellings). Within these circumstances the Councils plainly cannot claim that the windfall allowance is not central to achieving the planned requirement. The ‘First Proposals’ consultation also accepts that windfall supply is relied upon to ensure at least 10% of homes are delivered on sites of less than 1 hectare, in accordance with Paragraph 69(a) of the NPPF2021.
The Councils’ approach in relation to windfall supply and managing the delivery of small sites as a component of the planned strategy is unsound: not effective and not consistent with national policy. Increases to the assumed level of windfall supply are not supported by robust evidence. Notwithstanding some evidence that rates of supply from unidentified sites have exceeded past estimates Paragraph 71 of the NPPF2021 also requires consideration of expected future trends and the reliability of sources of supply.
The Councils’ Housing Delivery Study does not undertake any analysis of the impact of the Councils’ proposed development strategy and arbitrary limits to levels of growth across the settlement hierarchy in terms of the effect on windfall supply. This is despite paragraph 3.9 suggesting that the potential for additional large windfall development should be assessed where it would be consistent with the Councils’ policies. The arbitrary limits to scheme size are likely to reduce the scale of potential ‘large’ windfall sites relative to past examples and provide an additional incentive to ensure total potential capacity for development is taken up more slowly (across multiple applications) below the threshold for affordable housing contributions).
The Councils’ suggested reasons to depart from the requirements of national policy in NPPF2021 Paragraph 69(a) – stating that if it were to allocate specific sites it would need us to develop large numbers of sites in the rural area in what it claims are potentially unsustainable locations – is not justified or effective.
Allocating suitable sites such as our client’s land at Steeple Morden would overcome the risks identified with the Councils’ reliance on a high level of windfall supply. This would provide overall flexibility and could secure benefits under the policies of the development plan including contributions towards affordable housing and necessary community infrastructure. This is consistent with the Government’s objectives for housing in rural areas, whereas the Councils’ suggested approach does not seek to risks deliberately failing to meet the needs of these communities.
For the avoidance of doubt, updated details of our client’s land submitted with these representations (including a revised Site Boundary at Appendix 1) confirm that the site could suitably be identified for allocation comprising an area no greater than 1 hectare in accordance with national policy.
(v) Neighbourhood Planning (S/JH)
Paragraph 66 of the NPPF2021 strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations.
Page 24 of the ‘First Proposals’ consultation suggests that the approach to providing targets for designated neighbourhood areas will be upon the basis of apportioning a share of the area’s windfall figures and will not form part of the target for new homes to be allocated. This approach is unsound: not positively prepared and not consistent with national policy.
It is clear that the Councils are reliant on assumptions for windfall supply in order to deliver the planned strategy and housing requirement. In these circumstances the approach to apportion levels of windfall development as the basis for neighbourhood plan housing requirements is likely to compound risks to relying to a large extent upon supply from unidentified sites and the Councils’ arbitrary limits to acceptable scales of development at individual settlements based on the proposed policies of the Greater Cambridge Local Plan.
In these circumstances it is unclear how Neighbourhood Plans would, for example, facilitate opportunities to increase levels of housing delivery of secure benefits such as sites contributing towards affordable housing. This reinforces how the overall strategy is likely to fail to address needs within the rural area. By extension, the approach presents additional risks to ensuring housing needs are met in full.
In the context of our client’s site at Steeple Morden it is suggested that the identification of an appropriate housing requirement should reflect the relative sustainability of the Group Village and the ability of the settlement to support an appropriate level of growth. In suitable locations such as Steeple Morden it would be appropriate for the approach to provide a housing requirement for the neighbourhood area and also to facilitate the allocation of sites that would also assist in the wider Plan area’s ability to secure at least 10% of new homes on sites no larger than one hectare.

Attachments:

Representations to the GCLP First Proposals - Daniels Bros (957.59 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60329

Received: 10/12/2021

Respondent: Steeplefield

Number of people: 2

Representation Summary:

Land between 12 & 14 Station Road, Steeple Morden (HELAA site 40054)

Our area of concern is the stance taken in the plan to ignore the need for small scale opportunities for development in established settlements. It is considered that the Council's strategy focuses on very large sites to deliver their housing requirement with virtually no small or medium allocations. By delivering more housing in settlements such as Steeple Morden, development will continue to support local services and facilities, supporting their retention and growth.

Full text:

Land between 12 and 14 Station Road, Steeple Morden SG8 0NW
Site reference 40054

On 22nd April our planning consultant wrote to you alerting you to the fact that the call for sites database incorrectly represented our site in terms of its planning history. The site now benefits from an extant planning consent. Our submission to the local plan matches (does not exceed) the scale of development and land extent of the approved outline planning application S/1887/18/OL. The consent notice was dated 24th June, 2020.

The implication of this is that the District Council’s own assessment concluded that there were no factors in terms of Landscape and Townscape effects which outweigh the need for development. Indeed, the application was recommended for approval without objections from professional technical consultees for landscape and conservation area matters working on behalf of the District Council.

In the light of the foregoing we note that the Local Plan team’s site assessment (Map 596 site 40054) categorises our site a “Red” in the summary and “Red" against Landscape and Townscape. The assessment states that, “A key concern here is the woodland that comprises the site, development in this location would adversely impact the immediate and adjacent setting”. This conclusion is clearly based merely on a desktop appraisal and in ignorance of the various detailed professional submissions that led to recommendations for approval by the Council’s own professional officers in these areas of expertise. By this message we submit that the Local Plan's site assessment is demonstrably technically flawed. A substantial volume of technical submissions are held on the planning portal for the outline consent sufficient to outweigh the Local Plan’s conclusion and obviate the necessity to provide detailed argument here.

Our second area of concern is the stance taken in the plan to ignore the need for small scale opportunities for development in established settlements.

We submit that it is clear in paragraph 69 of the NPPF 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 's strategy focuses on very large sites to deliver their housing requirement with virtually no small or 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 in settlements such as Steeple Morden, development will continue to support local services and facilities, supporting their retention and growth. The need for additional housing in Steeple Morden was demonstrated by a formal 'Housing Need Survey' undertaken for the project by Cambridgeshire Acre in September and October 2020.

Taking these two points together we submit that there is a strong case to be made for the site to be allocated to deliver homes which meet a local need and for the settlement boundary for Steeple Morden to be amended to include our site 40054 within the development framework. As was concluded in the District Council's assessment of our planning application, development of our site represents gains in terms of housing, landscape, ecology and arboriculture. We hope that the Local Plan team will reconsider the status and the record of assessment of our site.