S/DS: Development strategy

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.

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.

The First Proposals plan is heavily reliant on the delivery of a handful of strategic developments, particularly large and complex sites. To ensure that the delivery of industrial space does not stall, and the supply-demand gap for employment space widens as a result, a pipeline of smaller developments which can deliver commercial sites quickly will be needed in the short-to-medium term.

The First Proposals plan is heavily reliant on the delivery of a handful of strategic developments - particularly large and complex sites which on average take 5-8 years for the first home to be delivered. To ensure that housing delivery doesn't 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.

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.

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.

LATE REPRESENTATION
On behalf of Westley Waterless Parish, I would like to put on record the following comments about the SCLP.

Strategy
Figure 4 - support the locations of proposed new housing development 2020-2041
Policy S/JH - agree that the Plan should formulate proposals based upon the forecast of the most likely level of new jobs
Policy S/DS agree with the proposed policy direction and consider that Figure 6 showing proposed sites to be included in the Plan represents a sustainable spatial response to the proposed development strategy. Support the fact that no new settlement is proposed around Six Mile Bottom and agree with the comment at page 39 that further new settlements should not be allocated
Policy S/RRA - endorse Figure 43 showing site allocations in the rest of the rural area which does not include SMB

Greater Cambridge HELAA Appendix 4 (Part C)
Refer to Site 40078 at pages 1419-1425
Agree with the red assessment of impact upon the local landscape. But it must be noted that the overall evaluation has been based upon a development of 2,000 dwellings whilst the Concept Vision produced by L&Q Estates / Hill Residential Ltd. in February 2020 describes Westley Green as having the potential to deliver up to 8,500 dwellings. The Westley Green Concept Framework shows a very large site extending into East Cambridgeshire and the impact of such a development form will have a significant deleterious impact upon a much wider landscape and existing communities. That scale of development will have a much greater impact upon local infrastructure such as water supply than the more limited assessment contained in the HELAA.

Have ECDC formally requested that the Plan should accommodate some of its future housing provision around SMB?

Kind regards
Jim Paltridge
Chair
Westley Waterless Parish

LATE REPRESENTATION
On behalf of Westley Waterless Parish, I would like to put on record the following comments about the SCLP.

Strategy
Figure 4 - support the locations of proposed new housing development 2020-2041
Policy S/JH - agree that the Plan should formulate proposals based upon the forecast of the most likely level of new jobs
Policy S/DS agree with the proposed policy direction and consider that Figure 6 showing proposed sites to be included in the Plan represents a sustainable spatial response to the proposed development strategy. Support the fact that no new settlement is proposed around Six Mile Bottom and agree with the comment at page 39 that further new settlements should not be allocated
Policy S/RRA - endorse Figure 43 showing site allocations in the rest of the rural area which does not include SMB

Greater Cambridge HELAA Appendix 4 (Part C)
Refer to Site 40078 at pages 1419-1425
Agree with the red assessment of impact upon the local landscape. But it must be noted that the overall evaluation has been based upon a development of 2,000 dwellings whilst the Concept Vision produced by L&Q Estates / Hill Residential Ltd. in February 2020 describes Westley Green as having the potential to deliver up to 8,500 dwellings. The Westley Green Concept Framework shows a very large site extending into East Cambridgeshire and the impact of such a development form will have a significant deleterious impact upon a much wider landscape and existing communities. That scale of development will have a much greater impact upon local infrastructure such as water supply than the more limited assessment contained in the HELAA.

Have ECDC formally requested that the Plan should accommodate some of its future housing provision around SMB?

Kind regards
Jim Paltridge
Chair
Westley Waterless Parish

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.

The proposed development strategy for Greater Cambridge directs the vast majority of growth to the Cambridge Urban Area, the edge of Cambridge and new settlements. Only a very small level of growth is directed to the Rural Southern Cluster and the Rest of the Rural Area. Of the allocations proposed, the vast majority of these are existing commitments (adopted allocations, sites with planning permission etc.). The Council are only proposing a need for an additional 11,640 homes to be allocated through the emerging Local Plan.
As part of their strategy, the Council have stated that their top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes. Whilst Taylor Wimpey do understand this approach by the Council, they do have some concerns in relation to how this strategy has been applied.
Firstly, many of the settlements within South Cambridgeshire are highly sustainable in their own right and benefit from excellent public transport links to Cambridge, and other destinations. Linton is one such settlement, and further commentary on its position within the hierarchy is set out in the comments for Policy S/SH. Taylor Wimpey therefore consider that the Council should explore the option to deliver more housing in other sustainable settlements, including Linton, in order to provide a greater spread of housing distribution in the District and provide a portfolio of types of sites to meet needs in a range of locations. In doing so such housing distribution would still accord with the strategy presented by the Council, by providing housing in highly sustainable Linton.
Such housing delivery would help meet the needs of smaller settlements over the plan period, providing greater variety in the types and location of development delivered. It is important to highlight that the National Planning Policy Framework (NPPF) is clear in paragraph 69 that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly’ and that local planning authorities should ‘promote the development of a good mix of sites’. It is considered that the Council strategy focuses on the delivery of very large sites with a much lesser number of smaller allocations. Taylor Wimpey are therefore of the view that the Council should look to deliver a greater number of smaller allocations to ensure that there is a supply of housing that can be built out sooner within the plan period. The site in Linton is one such site that could be built-out relatively quickly.
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 Linton, development will continue to support local services and facilities, supporting their retention and growth. This point is also recognised in the appraisal of spatial options set out within the Greater Cambridge Local Plan: First Proposals Sustainability Appraisal (October 2021).

Housing Supply (Policy S/DS: Development Strategy) The Buffer Many of the problems with the delivery of housing stem from the fixing of a housing requirement at plan-making stage that is too low and does not allow sufficient flexibility. Doing so means that:
a) there is insufficient flexibility should allocated sites in the plan do not come forward as anticipated;
b) the sites allocated in the plan have a monopoly position and the LPA is under great pressure to grant planning permission even where concerns exist around one or more aspects of the proposal; and
c) if housing delivery does not keep pace with needs, the immediately available recourse is to increase housing land supply through speculative planning applications predicated upon the presumption in favour of sustainable development – the plan-making system being too slow to respond quickly enough when a shortfall is identified.

The NPPF states (para. 74): “The supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of: a) 5% to ensure choice and competition in the market for land; or b) 10% where the local planning authority wishes to demonstrate a five year supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year; or c) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply41.”

PPG states (ID: 68-022-20190722): “To ensure that there is a realistic prospect of achieving the planned level of housing supply, the local planning authority should always add an appropriate buffer, applied to the requirement in the first 5 years (including any shortfall), bringing forward additional sites from later in the plan period. This will result in a requirement over and above the level indicated by the strategic policy requirement or the local housing need figure. Buffers are not cumulative, meaning that an authority should add one of the following, depending on circumstances:
• 5% - the minimum buffer for all authorities, necessary to ensure choice and competition in the market, where they are not seeking to demonstrate a 5 year housing land supply;
• 10% - the buffer for authorities seeking to ‘confirm’ 5 year housing land supply for a year, through a recently adopted plan or subsequent annual position statement (as set out in paragraph 74 of the Framework), unless they have to apply a 20% buffer (as below); and
• 20% - the buffer for authorities where delivery of housing taken as a whole over the previous 3 years, has fallen below 85% of the requirement, as set out in the last published Housing Delivery Test results.”

Under proposed Policy S/DS: Development Strategy (commencing page 27), and the sub-heading of ‘Proposed Policy Direction’ (commencing page 29) the draft Plan states (page 31) (our emphasis): “In order to provide greater confidence that the identified housing needs in Policy S/JH New Jobs and Homes can be met, and that a continuing supply of housing can be demonstrated, we are proposing to allocate enough sites to provide approximately a 10% buffer so we have the flexibility to deal with unforeseen circumstances. …” A 10% buffer is generally considered the minimum possible if an authority is seeking to be able to demonstrate, on a rolling basis, a 10% buffer within its 5YHLS.

However, the ‘Greater Cambridge Housing Trajectory and Five Year Housing Land Supply’, published 1 st April 2021, explains that the Councils consider it appropriate to apply ‘lapse rates’, of between 6% and 10% to some projected delivery to take into account that some sites never come forward. So far as we can tell the Councils have not included reference to lapse rates, or made any provision for sites not coming forward, within the draft Plan.

Many Local Plans have been adopted with a 10% buffer built into the projected housing supply, which has proven to be insufficient, resulting in the consequences outlined above. The solution is relatively straightforward – include a larger buffer in the form of additional allocations. The former of these is generally preferable as, again as noted above, the plan-making system being too slow to respond quickly enough when a shortfall is identified. Inclusion of a larger buffer would have a number of benefits for all parties and provide greater certainty over the delivery of housing.
It would:
1) provide greater democratic oversight of housing supply, putting LPAs in control and able to respond proactively to housing delivery should a shortfall occur;
2) reduce uncertainty for local communities and the propensity for ‘speculative’ planning applications where a shortfall in housing is encountered;
3) remove the monopoly of land supply caused by the current plan-making system and increase the likelihood of the Councils being in a position to secure a policy compliant proposals;
4) provide a source of housing land which the Councils can draw upon to maintain deliver if the plan-making process takes longer than anticipated; and
5) reduce the number of planning appeals, thereby making cost savings for both the Councils and the Planning Inspectorate.

Summary It is thus evident that:
• The 10% buffer proposed is not sufficient and additional sites should be allocated across the Greater Cambridge area to provide sufficient flexibility. Further work will be required to identify the size of an increased buffer but we would suggest that this be at least 15% (equivalent to 6,660 homes on a housing requirement of 44,400 homes, or 7,245 homes on a housing requirement of 48,300 homes – see above).

The 5-Year Housing Land Supply

The NPPF states (para. 74): “… Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing …”

It is usual practice for assessments of housing need and supply to be calculated over periods commencing on 1st April. PPG states (ID: 68-003-20190722): “The purpose of the 5 year housing land supply is to provide an indication of whether there are sufficient sites available to meet the housing requirement set out in adopted strategic policies for the next 5 years. …”
The draft Plan does not explicitly address this need to demonstrate a 5YHLS. The ‘Greater Cambridge Housing Trajectory and Five Year Housing Land Supply’, published 1st April 2021, concludes that, applying a 5% buffer to the calculation, across the Greater Cambridge area, the Councils can, as of 1st April 2021, demonstrate a 5YHLS of 6.1 years. The ‘Housing Delivery Study for Greater Cambridge’, October 2021 projects the 5YHLS for an assumed adoption date of the emerging Local Plan of 1st April 2025.

However, in doing so it makes a numbers of errors and a number of assumptions are adopted that are flawed. We discuss just two of these below Firstly, it calculates the baseline requirement as being 2,111 dws x 5 years = 10,555 dws. Based on the emerging Local Plan including an overall housing requirement of 44,400 homes, the correct baseline requirement would be 2,114.3 dws x 5 years = 10,571 dws.

Secondly, the revised trajectory promulgated in the Delivery Study adds 516 dws to the delivery projected identified in the April 2021 Trajectory for the period 2020/21 to 2025/26, and a further 1,641 dws to the delivery projected for the period 2025/26 to 2029/30. This additional delivery has not been properly tested against the requirements for inclusion in a 5YHLS with a base date of 1st April 2021 and the Study ‘assumes’ that it will be able to be included.

If this 516 and 1,641 dws were removed from the supply and the figures in the April 2021 Trajectory relied upon, there would be a shortfall over this period of 414 dws. Taking into account just these two corrections results in the following:
TABLE PROVIDED IN ATTACHED DOCUMENT

Summary It is thus evident that:
• Whilst the Councils have been nominally able to show that they will be able to demonstrate a 5YHLS on adoption of the Plan, this projection is prone to challenge and is not robust, such that there is a high potential that the Councils will fail the 5YHLS test soon after adoption of the new Plan.

The Role of Small Sites
Under proposed Policy S/DS: Development Strategy (commencing page 29), and the sub-heading of ‘Spatial Strategy’ (commencing page 36) the draft Plan states (page 40) (our emphasis): “National planning policy says at least 10% of our housing requirement should be accommodated on sites no larger than 1 hectare, unless it can be shown that there are strong reasons why this cannot be achieved. …”

This is not completely correct. The NPPF states (para. 69): “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. To promote the development of a good mix of sites local planning authorities should: a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved …”

There is a subtle but important difference between 10% of a housing requirement being accommodated on sites no larger than 1 hectare and 10% of a housing requirement being accommodated on identified sites of no larger than 1 hectare. The need to identify this land is critical to ensuring that sufficient small and medium sized sites do make an important contribution towards the meeting of the housing requirement, as required by national policy. Failure to identify sufficient sites jeopardises this objective.

The need to ‘identify’ sites is noted in the ‘PAS Local Plan Route Mapper Toolkit Part 2: Local Plan Form & Content Checklist’, last published in October 2021. On this point, the draft Plan simply states (page 40): “… The site commitments we have and new proposals suggested in this consultation, together with windfall sites expected to come forward would mean we exceed this requirement by some margin. …”

This statement falls far short of the explicitly clear requirement in national policy to identify sufficient sites to deliver 10% of the housing requirement. Section 6.6 of the Development Strategy Topic Paper discuss the requirement set out in paragraph 69 of the NPPF. It states (page 44): “The housing supply anticipated to deliver the First Proposals housing requirement includes existing housing commitments (adopted allocations and sites with planning permission), existing commitments for communal accommodation for students and older people (adopted allocations and sites with planning permission, converted to dwelling equivalents as set out in Appendix 2B), proposed new allocations, and a windfall allowance. All of these elements of housing supply include sites no larger than one hectare.”

The Topic Paper highlights on page 45 that only small sites sufficient to provide 2,077 homes are ‘identified’ (we do not concur with the inclusion in this allowance of C2 communal accommodation as including such runs counter to the intent of paragraph 69). This figures equates to less than half the 4,400 dwelling requirement that would result from paragraph 69 were the proposed housing requirement of 44,400 to be adopted. In addition, most of these ‘identified’ sites are within Cambridge, with very few within South Cambridgeshire. The remainder of the provision to meet the small sites requirement comprises the ‘windfall allowance’. Windfall sites are defined in the NPPF as: “Sites not specifically identified in the development plan.” and in the draft Plan as: “Sites which have not been specifically identified as available for development in the Local Plan. They normally comprise previously developed sites that have unexpectedly become available.” As such, windfall sites cannot, by definition, be ‘identified’.

The Council’s proposal to utilise the windfall allowance to meet the requirements of paragraph 69 runs counter to the intent of paragraph 69 – to ensure that Local Plans ‘identified’ small sites that could then be brought forward by small and medium-sized housebuilders to assist with housing delivery. The draft Plan continues (page 40): “… However, if we were to allocate specific sites it would need us to develop large numbers of sites in the rural area. …”

Here the draft Plan is almost accepting that it is not doing what national policy requires; by use of ‘however’ it is almost as though the draft Plan recognises the requirements of national policy but it has decided that this requirement should be set aside.

The draft Plan continues (page 40): “… This would compromise our development strategy, by directing a significant portion of growth to less sustainable locations, impacting on our response to the challenges of net zero carbon, and likely requiring large numbers of Green Belt releases.”

By this statement, the draft Plan explicitly sets out that it is contrary to national policy – the requirement set out in paragraph 69 of the NPPF has been set aside in favour of the proposed ‘development strategy’. Paragraph 69 of the NPPF is explicit: the 10% requirement applies (our emphasis): “… unless it can be shown that there are strong reasons why this cannot be achieved …”.

Neither the draft Plan, nor any of the supporting evidence base sets out a reason why the requirement ‘cannot be achieved’. Instead, the draft Plan simply concludes that it cannot as it would ‘compromise the development strategy’ – a strategy that was seemingly arrived at first. Indeed, the number of potential development sites submitted through the call-for-sites process makes it very evident the requirement can be met; it is simply that a decision has been taken that the draft Plan should not do so.

The case for allocating sufficient sites to accommodate 10% of the housing requirement on sites no larger than 1 hectare is very strong and widely recognised. As stated in Appendix 9 to the ‘Housing Delivery Study for Greater Cambridge’, dated October 2021, with regard to ‘meeting the small sites requirement’ (our emphasis): “Concentrating development at sites within Cambridge urban area and also allocating sites at villages is likely to yield a number of sites that would meet the NPPF Paragraph [69] definition of “small sites”, assisting with meeting the small sites requirement.”

Summary It is thus evident that:
• The draft Plan, knowingly, does not accord with national policy in paragraph 69 of the NPPF.
• The draft Plan does not provide any reason as to why it ‘cannot’ comply with the requirements of paragraph 69 of the NPPF.
• The draft Plan should be made compliant with the requirements of paragraph 69 of the NPPF by adapting it to include additional small sites no larger than 1 hectare, predominantly within South Cambridgeshire.

Development Strategy / Spatial Distribution (Policy S/DS: Development Strategy)
(NB See also our discussion above in relation to: ‘Development Strategy / Spatial Distribution’. This is repeated (in part) here due to the manner in which we will need to submit the representations / the way in which they will be considered separately to each other.)

Under proposed Policy S/DS: Development Strategy (commencing page 29), and the sub-heading of ‘Proposed Policy Direction’ (commencing page 29) the draft Plan states (page 31) (our emphasis): “In the rest of the rural area, we propose a very limited amount of development:
• Small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive;
• New employment sites in the countryside meeting specific business needs; and
• Windfall development - an allowance for homes on unallocated land, which would need to be consistent with policy requirements in the Plan, including Policy SS/SH: Settlement Hierarchy, which sets out scales of development in different categories of village.”

It is considered that this is akin to the abandoning of the rest of the rural area; whilst those villages identified as having ‘very good public transport access’ will be allowed to ‘thrive’, essentially no provision is being made, over the course of the next generation, to enable any other communities to grow. In short, other than a limited number of villages the Development Strategy will lead to the stagnation and decay of the rural area.

As we discuss below in relation to the ‘rest of the rural area’, the rural area accommodates 5 Rural Centres, 13 Minor Rural Centres and 33 Group Villages, not to mention 55 Infill Villages. The draft Plan proposes the allocation of only 6 new sites / 384 new homes, to this area – a ‘paltry attempt to meet local needs. As evidenced by the table on page 32 of the draft plan, this figure equates to just 3.3% of the new housing allocations proposed.

This is directly contrary to national policy in the NPPF, which includes (para. 79): “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”

In addition (para. 84): “Planning policies … should enable: … d) the retention and development of accessible local services and community facilities, such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship.”

The draft Plan completely fails to recognise that by not allowing rural communities to grow, irrespective of whether they have a full range of services and facilities and ‘very good’ public transport links, it will run counter to the guidance in paragraphs 79 and 84 and almost certainly lead to the loss of services and facilities and a reduction in rural sustainability.

This national policy is a far more nuanced and sustainable approach than the blunt tool being proposed in the draft Plan. Two easy options for a solution to this are to either:
i) increase the housing requirement as discussed above and accommodate the addition 1,900 (48,300 – 44,400 = 1,900) to 4,700 (1,900 (as above) plus increased buffer: 7,245 – 4,400 = 2,845; total = 4,745) homes on sustainable sites in sustainable locations (the HELAA process makes it clear that these do exist) within the rural area; and/or
ii) not include the ‘additional’ / ‘faster’ delivery of between 1,500 and 2,500 new homes on the edge of Cambridge / at new settlements, thereby providing increased flexibility and relieving the pressure to continue the high rate of delivery experienced in recent year, and to instead accommodate these homes on sustainable sites in sustainable locations within the rural area.

With regard to the latter option, the Development Strategy Topic Paper notes (page 74) (our emphasis): “… Our Housing Delivery Evidence suggests that our assumptions on housing delivery at Northstowe and Waterbeach can be faster than we previously estimated, such that they could contribute additional homes towards our housing need to 2041. …”

The ‘evidence’ included in the ‘Housing Delivery Study for Greater Cambridge’, dated October 2021, is scant and apparently based solely, and entirely, on the expectation that Modern Methods of Construction (MMC) will facilitate faster delivery than previously expected. However, virtually no evidence to support this contention, which also fails to take into account whether the higher rate of delivery can be sustained in all other respects (e.g. highway and other infrastructure improvements not capable of adopting MMC), or whether the demand will persist for the higher rate.

The suggestion in the draft Plan is notable for it’s use of ‘can’ and ‘could’ – in particular the expected delivery of an additional 1,500 new homes at Northstowe and Waterbeach is readily accepted as being something that ‘could’ happen – whether it is ‘likely’ to happen is not addressed.

This conflicts with the approach taken to the expected level of employment growth as discussed above in relation to ‘Housing Needs’ / ‘The Housing Requirement’, where the Councils have entirely set aside the higher level of employment growth that their own evidence identifies ‘could’ happen in favour of what they consider is ‘most likely’ to happen. Noting this, in regard to the Development Strategy and distribution of development, it would appear that the draft Plan is seeking to have it’s cake and eat it, or to put it another way, adopting one approach in one regard, and a contrasting one in another. At best this suggests a lack on consistency in the Plan.

Summary
It is thus evident that:
• The quantum of housing allocated to the rural area is ‘paltry’ and insufficient to enable existing communities to ‘thrive’ and/or ‘grow’.
• The approach taken to the distribution of development, especially the ‘additional’ / ‘extra’ on the edge of Cambridge / at Northstowe and Waterbeach, is not supported by robust evidence, and is an approach that conflicts with that taken to employment growth.
• Two options for a solution would be to either:
increase the housing requirement by 1,900 to 4,700 homes as discussed; and/or
not include the ‘additional’ / ‘faster’ delivery of between 1,500 and 2,500 new homes on the edge of Cambridge / at new settlements, and to instead accommodate these homes on sustainable sites in sustainable locations within the rural area.

SUMMARY

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

With regard to Housing Supply (Section 2.1 of the draft Plan):
The 10% buffer proposed is not sufficient and additional sites should be allocated across the Greater Cambridge area to provide sufficient flexibility. Further work will be required to identify the size of an increased buffer but we would suggest that this be at least 15% (equivalent to 6,660 homes on a housing requirement of 44,400 homes, or 7,245 homes on a housing requirement of 48,300 homes – see above).

Whilst the Councils have been nominally able to show that they will be able to demonstrate a 5YHLS on adoption of the Plan, this projection is prone to challenge and is not robust, such that there is a high potential that the Councils will fail the 5YHLS test soon after adoption of the new Plan. o With regard to the role of ‘small sites’, the draft Plan, knowingly, does not accord with national policy in paragraph 69 of the NPPF, does not provide any reason as to why it ‘cannot’ comply with the requirements of paragraph 69 of the NPPF, and should be made compliant with the requirements of paragraph 69 of the NPPF by adaptation to include additional small sites no larger than 1 hectare, predominantly within South Cambridgeshire.

With regard to the Development Strategy / Spatial Distribution (Section 2.1 of the draft Plan): The quantum of housing allocated to the rural area is ‘paltry’ and insufficient to enable existing communities to ‘thrive’ and/or ‘grow’.

The approach taken to the distribution of development, especially the ‘additional’ / ‘extra’ on the edge of Cambridge / at Northstowe and Waterbeach, is not supported by robust evidence, and is an approach that conflicts with that taken to employment growth. Two options for a solution would be to either: - increase the housing requirement by 1,900 to 4,700 homes as discussed; and/or - not include the ‘additional’ / ‘faster’ delivery of between 1,500 and 2,500 new homes on the edge of Cambridge / at new settlements, and to instead accommodate these homes on sustainable sites in sustainable locations within the rural area.

Greater Cambridge Local Plan – The First Proposals Consultation
Land east of Long Road, Comberton

Thakeham Homes Ltd (Thakeham) is writing in respect of the Greater Cambridge Local Plan – The First Proposals Consultation (1st November to 13th December 2021), specifically in relation to Land east of Long Road, Comberton located to the east of Comberton (‘The Site’)

Introduction Thakeham is pleased to be participating in this consultation and has outlined its position below in response to the Greater Cambridge Local Plan (GCLP) – The First Proposals Consultation.

Thakeham is promoting a site: Land east of Long Road, Comberton which is located on the eastern edge of Comberton. This site is available, within single ownership and is achievable and deliverable to contribute towards the development needs of Greater Cambridge in the first five years of the plan period.

An Evolution Document accompanies these representations, which further sets out Thakeham’s vision for the site, incorporating 400 new homes (inclusive of policy compliant affordable housing provision) alongside key community benefits including a new flexible co-working space, a new Multi Use Games Area and community allotments alongside play space and open space provision.

About Thakeham
Thakeham prides itself in being an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.

Thakeham build for the future, for communities and individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.

Each development is different and tailored to its locality with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other local community, cultural and environmental stakeholders from the start of each project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.

As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable, zero carbon communities. Out approach sets us apart from our competitors. We deliver our schemes with a focus on infrastructure-led sustainable development.

Sustainability
There is an evident theme in Greater Cambridge in respect of environmental impact and the importance of ensuring any development, whether that be residential or infrastructure, seeks to minimise its impact. Thakeham would like to take this opportunity to outline the measures implemented on its developments to minimise environmental impacts as a direct and indirect result of development: • From 2025, all Thakeham homes will be net-zero carbon in lifetime use. • From 2025, all Thakeham homes will be carbon neutral in production. Our off-site panellised system will make construction more efficient, faster, enhancing quality and reducing construction traffic. • Thakeham is committed to offsetting the embodied impact from the production of new houses, as well as development houses that are zero carbon in lifetime operation. • Thakeham support the Wildlife Trust’s guidance on Homes for People and Wildlife. Our commitment is to at least 20% biodiversity net gain (double the government’s target within the recent Environment Act 2021) on all our developments post-2025 with attractive and functional green and blue infrastructure. • Through placemaking and the implementation of sustainable travel plans, Thakeham prioritises walking and cycling over car travel, helping people make more sustainable choices around walking, cycling and taking public transport, as well as highlighting innovative car-sharing online platforms such as LiftShare to reduce single-occupancy car use and facilitating use of autonomous vehicle/pods. • Thakeham provides electric car charging points at all of their homes both market and affordable alike, reducing barriers to customers purchasing emission-free vehicles. • Thakeham is keen to champion low carbon transport in the local area, encouraging local transport services such as buses to electrify their fleet. • Mechanical Ventilation with Heat Recovery (MVHR) is installed in our homes, which has a filter built-in to capture incoming pollution to provide fresh filtered air. • Thakeham works with its supply chain with an aim that all mechanical plant on site is less than 18 months old, which means it is less polluting and more fuel efficient.

Response to Options
Thakeham has reviewed the consultation documents and has chosen to comment on key questions and themes where relevant to our business to comment on.

Vision and development strategy
Vision and aims Thakeham supports the Council’s vision for new development to come forward with sustainability and healthy place shaping at the forefront. As we’ve touched on above, Thakeham supports the focus on healthy place shaping, with a need to ensure that future development maximises opportunities for journeys to be made on foot or bicycle. This will necessitate ensuring new developments prioritise non-motorised transport and easy access to full range of day-to-day services and facilities. Thakeham has made a number of commitments in respect of its own carbon impact, ensuring that all its development will be net zero carbon in lifetime use and carbon neutral in production by 2025. Additionally, Thakeham has made a commitment to achieve 20% biodiversity net gain on all projects post-2025 which is double that set out in the Environment Act 2021.

How much development, and where – general comments

Whilst Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.

S/JH: New jobs and homes
Thakeham is supportive of the Councils’ conclusions that adopting the suggested ‘standard method minimum homes and related jobs’ approach would not be appropriate for Greater Cambridge and would not support its economic growth aspirations.

It is acknowledged that the Councils’ have sought to accommodate an uplift to accommodate their economic growth aspirations, suggesting that the ‘medium level of homes’ approach is justified, resulting in a need for 44,400 homes over the plan period 2020-2041 amounting the 2,111 homes per annum, alongside provision of 58,500 new jobs over the plan period.

Whilst the ‘maximum level of homes’ does not represent the Councils’ preferred approach; it is worth noting that this approach does acknowledge housing need arising out of fast job growth and therefore the Employment Land Review makes recommendations to provide more that the ‘medium’ scenario level of jobs to provide flexibility.

Thakeham is supportive of the Councils’ intention to accommodate their full objectively assessed needs for housing and jobs within the plan area. It is also acknowledged that a 10% buffer has also been added into their housing requirement to provide flexibility, amounting to a housing requirement of 48,840 over the plan period.

The Greater Cambridge Local Plan will need to ensure that it is planning for a sufficient number of new homes to support its economic growth aspirations. Whilst it is acknowledged that the medium option for new homes does incorporate an uplift for economic growth in the area, in addition to the application of a 10% buffer to reach the suggested housing requirement. Thakeham would suggest that the Councils undertake further work to ensure that the correct uplift has been applied to ensure that the Councils can meet their relevant aspirations in terms of job creation and growth, and as a result provide the right level of housing to support this. This is important to ensure that existing employers in the area can continue to thrive and expand retaining and attracting staff including graduates, in what is a global recruitment marketplace for many of the industries already located in Greater Cambridge. Further, in order to ensure Greater Cambridge continues to be a focus for inward investment into the UK, following on from the successes of the past, continued focus on supporting employment growth will be key and part of that will be providing housing to attract not just highly skilled staff but also for the variety of lower paid workers such as cleaners, delivery drivers and shop workers. These lower paid workers are necessary to support the wider community and economy such as in Greater Cambridge where land and house prices are high. These people are either driven out, much has been the case in London and has been seen in parts of Greater Cambridge to more affordable locations, but with the consequence of a longer commute, or greater affordable housing provision is required to accommodate them

S/DS: Development strategy

The first proposals consultation is suggesting a focus on existing commitments and expansion of existing sites to meet the suggested housing need. Where new sites are proposed these are focussed predominantly within and around the edge of Cambridge.

The background text to S/DS suggests that very limited development is proposed in rural areas due the Councils’ desire to focus growth to more readily sustainable locations. Whilst, as we have touched on above, Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery. In particular, growth in rural areas can contribute to improving and maintaining the vibrancy of these areas and is of great importance to ensuring these communities thrive. The important role that development in these rural areas can play should not be overlooked in the GCLP development strategy.

S/SH: Settlement hierarchy
The settlement hierarchy seeks to group together similar settlements into categories that reflect their scale, characteristics and sustainability. It then seeks to limit development in any settlements which fall within the ‘Minor Rural Centre’ category and below.

Thakeham considers this view is overly prescriptive. The Settlement hierarchy identifies just 8 settlements which would have no limit on individual scheme size:
City: Cambridge
Town: Cambourne, Northstowe and Waterbeach New Town
Rural Centres: Bourn Airfield New Village, Histon & Impington, Great Shelford and Stapleford and Sawston

The Greater Cambridge Area covers a significant geographical area and this suggested policy approach limits development opportunities across the plan area. It is suggested that development at Minor Rural Centre’s should incorporate schemes of a maximum scheme size of 30 dwellings with lower tiers suggesting significantly less.

Policies should retain a flexible approach to ensure that promotion sites and applications can be assessed on a site-by site basis on the merits and positive contribution they could make to an existing and future community. Development opportunities in these communities could have significant longer term sustainability benefits by helping existing services remain, and where appropriate levels of growth are accommodated, new services could be provided as a result of development.

Rest of the rural area
Rest of the rural area - general comments

As we have discussed above, Thakeham do not consider that the Greater Cambridge Local Plan goes far enough to support rural villages to allow them to thrive and grow in a sustainable way.

The supporting text and preferred options throughout this consultation suggest that growth has been directed away from rural areas to meet the plans climate objectives and encourage a modal transport shift from private car use. The importance of rural communities and ensuring they have the ability to grow appropriately to accommodate their needs and improve their services is paramount to ensuring these communities thrive alongside larger towns and cities. Importantly, appropriate growth at smaller settlements can help contribute to local services and facilities, including public transport provision and internalisation.

As discussed in these representations, Thakeham is promoting Land east of Long Road, Comberton as a sustainable extension to the village. Thakeham prides itself on being and infrastructure-led placemaker who seeks to ensure that social, physical, green and technological infrastructure is delivered as a result of its developments, in appropriate manner in relation to scale and siting of such sites. As part of its promotion at Land east of Long Road. Comberton Thakeham has sought to adopt a landscape a social infrastructure-led approach to its proposals. Alongside open space and play provision the proposals also include a co-working hub, community allotments and a Multi Use Games Area. Thakeham has proven track record for early infrastructure delivery, ensuring that existing and new communities’ benefit from the outset.

In addition, Thakeham has its own approach to sustainable movement starting with the principle of reducing the need for travel, which in part can be achieved by offering bespoke home offices for all of our houses. The focus is then on shifting the mode of travel by ensuring pedestrian and cycle movement is prioritised and links into the existing network where possible, encouraging private vehicles to be a tertiary mode of transport. Thakeham has also made a commitment to provide easily accessible cycle storage with charging for electric bikes and scooters and the provision of fast electric vehicle charging points for all houses.

Climate change
Climate change - general comments
Thakeham is supportive of the Councils’ objectives to enhance climate change resilience and transition Greater Cambridge to net zero carbon by 2050.

As a developer, Thakeham prides itself in the objectives it has set in respect of climate change and the impact development can have. Thakeham has a key focus on sustainable practices both in construction and placemaking. Our approach sets us apart from our competitors. Thakeham’s schemes are delivered with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham homes will be carbon neutral in production and zero carbon in lifetime use. Thakeham are a founding member of the HBF Future Homes Task Force, which examines how the house building industry can work toward delivering net zero carbon homes in order to support the Government’s target of the country delivering ne zero carbon emissions by 2050. Thakeham has a particular focus on first improving the fabric of buildings, constructed from sustainable timber sources, consideration of sustainable energy features and a sustainable procurement strategy which encourages the use of recycled materials. Thakeham intends to open a new MMC factory in the future, which will provide locally sourced MMC constructed homes further helping to reduce the environmental impact of construction.

CC/NZ: Net zero carbon new buildings
Thakeham considers that the proposed policy direction is too prescriptive and does not provide sufficient flexibility for advances in technologies and Building Regulations. Policy wording should be less prescriptive on the measures used to achieve net zero carbon buildings, rather there should be sufficient flexibility to allow the methods for achieving such targets to be assessed on a site-by-site basis. This is critical as technology is advancing quickly and will continue to do so during the lifetime of the emerging local plan and consequently to set prescriptive policies will have the effect of the local plan being out of date before or at adoption.
As above, Thakeham prides itself in its own objectives for all its new homes to the zero-carbon in lifetime use and carbon neutral in production by 2025.

Biodiversity and green spaces
BG/BG: Biodiversity and geodiversity
Thakeham is supportive of the policy direction of BG/BG and the Councils’ aspiration to require a minimum of 20% biodiversity net gain, whilst also acknowledging the difficulties this may bring for smaller sites with a suggested contribution mechanism to allow these sites to meet the requirements of the proposed policy. However, the current policy direction seeks to limit off-site habitat measures to align with the Greater Cambridge green infrastructure network strategic initiatives. Whilst it is acknowledged that this may represent a preferred approach, this may cause issues in deliverability due to availability of such land.

Policy BG/BG should incorporate sufficient flexibility to allow sites to achieve the required biodiversity net gain requirements by measures which are most appropriate to that site, if this requires off-site habitat creation there should be sufficient flexibility to allow consideration of all suitable options to ensure such requirements do not stifle development. Thakeham itself has already made a commitment to achieve at least 20% biodiversity net gain as a result of our projects post 2025.

Wellbeing and Inclusion
Policy WS/HD: Creating healthy new developments
Thakeham supports the objective and policy direction of Policy WS/HD, requiring health principles to be applied to new development, drawing on the ten principles developed from the Healthy New Towns Initiative.

In our view, relevant policies in respect of wellbeing and inclusion could go further to set out requirements on not only creating healthy new developments, but other measures which maximise wellbeing benefits that developments can offer those who build them, those who live in them and the communities around them now and into the future.

As one of 12 members of the NHS Healthy New Towns, Thakeham supports such policy initiatives and itself is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable zero carbon communities. Our approach sets us apart from our competitors, Thakeham is passionate about having a positive impact on people’s wellbeing, constantly striving to deliver against our four key focus areas:
-Building local communities via excellent placemaking that creates interconnected communities that challenge issues of loneliness and promoting healthy living, and via our long-term charity partnerships.
-Building future generations via our school engagement programmes, including our industry leading holistic ecology programme ‘Eddie and Ellie’s Wild Adventures’ for primary age pupils, and providing inspiring careers support to secondary age pupils through our Cornerstone Employer status with The Careers Enterprise Company.
-Building a stronger Industry with our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.
-Building Sustainable places by tackling issues of climate change, biodiversity loss and societal disconnects via our ambitious Sustainability Strategy.

WS/IO: Creating inclusive employment and business opportunities through new developments
Thakeham is supportive of the policy direction of Policy WS/IO and as touched on above, adopts its own approach to creating inclusive employment and business opportunities through our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.

Homes policies Policy
H/AH: Affordable housing
Thakeham support the Councils’ policy direction in respect of Affordable Housing and the importance that such homes are built with inclusion, health and wellbeing at the forefront. Thakeham continues to provide policy compliant affordable housing across all of our developments whilst adopting a truly tenure blind approach to affordable housing which creates cohesive communities.

H/SS: Residential space standards and accessible homes
Whilst Thakeham supports the Councils’ aspiration to see good quality homes delivered across their districts, such policy requirement which seeks all dwellings to meet NDSS needs to be supported by robust evidence that there is a specific need to introduce such standards. Any policy requirements in respect of housing accessibility requirements should be based on identified need, with sufficient flexibility incorporated to ensure that provision is directed to the right places. In particular, blanket policy requirements for M4(2) in all new developments should not be adopted as these requirements should be based on identified need, whilst requirements in relation to M4(3) can be particularly onerous and should only be directed to developments where there is an identified end user.

H/CB: Self- and custom build homes
Whilst Thakeham is supportive of self and custom build home provision in Greater Cambridge, it is not considered that a blanket policy as suggested by H/CB on developments of 20 or more is appropriate or feasible. Self and custom-build products should be directed towards key strategic allocations to ensure such homes are deliverable. Self and custom build home provision should also be based on an identified need.

Land east of Long Road, Comberton

The accompanying Evolution Document outlines the constraints and opportunities associated with Land east of Long Road, Comberton and provides a high-level illustrative masterplan and delivery strategy. The site can accommodate circa 400 dwellings alongside significant community benefits on an edge of settlement location, with close proximity to existing facilities and services, with main vehicular access from Long Road.

The landscape and social infrastructure-led scheme is planned around the provision of open space incorporating a number of community benefits including: play space, a Multi Use Games Area, community allotments and a new flexible co-working space.

On the edge of Comberton, the site is situated in a sustainable location with opportunities to access existing local services and amenities within the village. There is also access to public transport provision within close proximity of the site.

The site is within single ownership, within the control of Thakeham and on that basis Thakeham confirms that the site is available and deliverable within the first five years of the plan period.

We trust that these representations are useful and clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any further queries or require any further information.

Policy S/DS: Development strategy directly contradicts para 69 of the NPPF July 2021

(Table of proposed allocations included in attached document)

NPPF July 2021 - New National Planning Policy – Para 69 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. To promote the development of a good mix of sites local planning authorities should: a) identify land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved; b) use tools such as area-wide design assessments and Local Development Orders to help bring small and medium sized sites forward; c) support the development of windfall sites through their policies and decisions – giving great weight to the benefits of using suitable sites within existing settlements for homes;

To date the Planners seem to have used the “dollop” theory to identify predominantly large sites. This contradicts new Planning Policy above.

It also ignores the Plan’s stated objective to propose some development in the rural area south of Cambridge, the Rural Southern Cluster, where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links, including: New smaller sites for housing and employment in villages that have very good public transport access and are close to jobs, some through release of land from the Green Belt; and
• Development on GB is not generally acceptable, but to release a small site from the GB which in parallel secures greatly enhanced bio-diversity, and some informal rural public access, is a factor that weighs heavily in favour of the release.
• In these two latter respects dialogue will continue with National and Local Conservation Bodies focusing on the substantial area available around Hauxton Pits for enhanced bio diversity, and some informal rural public access Attached are three plans:
• Area further East for Biodiversity Enhancement – the plan shows areas of 1.75 ha and 3.83 ha (5.58 ha) plus possible further woodland enhancement and access • Hauxton plan detail
• Garfit site shown on site plan

Other Matters
• Dramatically changed accessibility of Hauxton since Bayer re-development (see attached Local Plan Examination Statement 2017 submission re Bayer)
• Good public transport and public services – see above Employment. There is employment on the Bayer site AND local interest from a Nursing Home Operator

What happens next? “After this consultation, we will consider what you have told us carefully, and develop the Plan in more detail. We hope to publish a full Draft Plan in 2022” For our part, we wish to maintain a dialogue with the planners and submit more detailed material

1. INTRODUCTION

1.1 This representation has been prepared by Strutt & Parker on behalf of Countryside Properties (UK) Ltd to support the promotion of land to the north-west of Balsham Road, Linton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA), which provided an initial assessment of the sites put forward for consideration for allocation as part of the Call for Sites consultations within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Preferred Options Consultation and 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 Proforma for the site.

1.4 The HELAA excludes the Balsham Road site from allocation primarily on the basis of landscape issues, notably that the proposed development “would have substantial and unacceptable landscape and visual impacts that would not be sufficiently mitigated by the proposed landscape treatments”.

1.5 The site was submitted as part of the Call for Sites for circa 300 dwellings and a rural business park. In response to the HELAA consultation, an updated Landscape Technical Note and Opportunities and Constraints Plan has been prepared by Barton Willmore to respond to the landscape and townscape comments regarding the sensitivity of the site. As a result, it is proposed to set development back from the northern boundary and provide key landscape corridors through the site. The site is considered to have capacity for the provision for up to 300 dwellings and up to 1 hectare of employment land. The Technical Note by Barton Wilmore on the landscape and visual impact has been provided within appendix A of this response.

1.6 The Opportunities and Constraints Plan demonstrates where the most and least sensitive areas within the site are. This has been produced in conjunction with the Technical Note on landscape and visual impact and the Council’s Landscape Character Assessment (2021). This has informed a reduced developable area. The revised scheme has been set back from the north, with clear landscape corridors, to allow clear landscape views to the Grade II Listed Water Tower to be fully maintained. The proposed development area represents a logical rounding off and extension to the large Minor Rural Centre of Linton which is a well-served village with a number of existing services and facilities.

1.7 Therefore, in view of the above, it is considered that several of the assessments criteria, particularly regarding the landscape impact should be re-categorised. It has been demonstrated in the supporting information provided that the allocation of this site would not have a significant adverse impact the landscape and townscape such that the site should be considered as a suitable, achievable and deliverable site for housing and should therefore be put forward for allocation in the emerging Local Plan. Further analysis of this is set out within section 7 of this report.

1.8 In support of this report, the following documents have been prepared; • Landscape and Visual Technical Advice Note – Barton Willmore; and • Opportunities and Constraints Plan – Barton Willmore.

1.9 In addition to the above documents, where relevant reference is also made to documents prepared and submitted previously as part of earlier rounds of consultation on the Local Plan.

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 for 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 The Development Strategy Topic Paper, that accompanies this consultation acknowledges 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 focus for housing and employment growth with associated infrastructure

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. Consistent with this strategy, it is considered to be very important that some growth is delivered in the larger more sustainable villages that are located outside of the Green Belt, such as Linton. National policy is clear within paragraph 79 of the National Planning Policy Framework (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 CPIER report, which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. The proposed Cambridge South-East Transport Project (CSET), proposes significant sustainable transport improvements between Cambridge and Haverhill. This includes significantly improved public transport, including an off-road rapid transit bus route, along with significant cycleway improvements along the A1307, some of which have already been implemented. For ease of reference appendix D of this representation provides accessibility plans, prepared by Richard Jackson Partnership, which were previously submitted as part of the Issues and Options Consultation. The Accessibility Plans demonstrate the significant transport improvement measures within Linton and in between Linton and Cambridge.

3.3 In addition, Linton, benefits from being a sustainable settlement in its own right. As referred to within our previous representation at Issues and Options Stage (refer to Appendix C), Linton is the largest Minor Rural Service Centre (As defined within the adopted and emerging Local Plan) that is not situated within the Green Belt. It is also benefits from both primary and secondary education facilities and a large range of services, including shops, pubs, restaurants and community facilities.

3.4 Linton did also not receive any allocations within the 2018 Local Plan and therefore provision for additional growth as part of the Local Plan 2041 would be appropriate and assist with maintaining viability and vibrancy of the village by sustaining and enhancing rural services.

3.5 For the above reasons, it is considered that additional growth within Linton would be consistent with the objective of the Local Plan, which seeks to minimise car travel. Of the 6 sites submitted within Linton as part of the Call for Sites process, land to the north-west of Balsham Road, is considered to be a particularly sustainable and suitable site for residential development.

3.6 It is suggested that the provision for increasing the range of sites modestly to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and secure affordable housing more immediately. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report: “In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).

4. QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?

4.1 We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new Local Plan. To support this objective, it is imperative therefore that a proportion of new housing growth is located along sustainable transport corridors from the Biomedical Campus, to support the objective of the Local Plan outlined above (in section 3 of this statement), which seeks to minimise car travel.

4.2 It is also very important that the emerging Local Plan 2041 aligns housing and employment growth, with major transport schemes that are being promoted in and around Cambridge. The First Proposals provide a number of references to East-West Rail and the provision for Cambridge South Station, both of which are important new transport infrastructure projects. However, additional focus needs to be given the major infrastructure projects being promoted by the Greater Cambridge Partnership. Of particularly relevance to the Biomedical Campus expansion, is the Cambridge South East Rapid Transit Route (CSET), which is proposed to provide a rapid transit route from the Biomedical Campus to the market town of Haverhill, the majority of which will be provided as an off-road bus way route. It is considered important that substantial housing growth is provided to the south east of Cambridge along this rapid transit route, to ensure ease of access to the Biomedical Campus by sustainable transport means.

4.3 It is understood that the CSET Project has progressed significantly since the Issues and Options Consultation in 2020. It is understood that the Greater Cambridge Partnership are intending to submit a Transport for Works Order in early 2022. It is also an identified route within the current Local Transport Plan.

4.4 Linton is one of the largest settlements with South Cambridgeshire that will be served by the CSET route. Therefore, growth in this settlement would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure. Linton is situated outside of the Green Belt and therefore it is considered that Linton should be the focus for growth ahead of settlements that lie within this designation such as Sawston.

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

5.1 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. Countryside Properties are responsible for the promotion of land to the north-west of Balsham Road, Linton and have a track record of delivering high quality housing developments, which provide a mix of dwellings and tenures to meet objectively assessed housing needs. Countryside Properties are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Linton Parish Council regarding the mix and type of housing to be delivered on land to the north-west of Balsham Road. The proposals also include the provision for the delivery of a substantial area of public open space with associated landscaping and Countryside Properties are flexible on the proposed use of this open space.

5.2 The submission of the site, also includes the provision for a Rural Business Centre of up to 1 hectare in size. This Rural Business Centre has the ability to ensure that jobs are provided within the application site and to support smaller start-up businesses within the local area. This further strengthens the sustainability case for development of this site.

5.3 It should however be noted that Linton is strategically well located to provide housing growth in close proximity to large employment generators and jobs such as the Genome Campus, Granta Park, Haverhill, the Biomedical Campus as demonstrated by the attached accessibility plan, prepared by Richard Jackson Partnership, that is provided within Appendix D.

6. 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?

6.1 Yes, land to the north-west of Balsham Road, Linton should be allocated for development and would be a sound allocation as part of the emerging Local Plan being brought forward by a housebuilder that has a good track record for delivery. Countryside is a leading national housebuilder and has established a strong reputation for delivering high-quality mixed-tenure housing developments and award-winning places to live and are committed to delivering a landscape led development at Balsham Road, Linton.

6.2 The land to the north-west of Balsham Road, Linton is being promoted for a residential-led mixed use development which comprises an employment area. The proposals consist of up to 300 dwellings and a rural business centre of up to 1 hectare in size.

6.3 Having reviewed the settlement morphology, the area of proposed built form is now concentrated away from the northern boundary, thereby extending the village in such a way that respects the more sensitive landscape views in the northern part of the site.

6.4 The proposed development is focussed towards the south of the site which is the least visible from the surrounding landscape, and will comprise of up to 300 dwellings. To the east the site is well screened by the existing scrap yard and structural vegetation.

6.5 Medium to long distant views are available of only the northern parts of the site and as such these areas are proposed as open green space, in order to protect the character of the rolling Chalkland, as well as views of the listed Rivey Hill Water Tower, as a prominent feature on the horizon above Linton, as seen from the landscape to the south, which is identified in the Greater Cambridge Landscape Character Assessment.

6.6 The opportunity and constraints plan also allows provision for clear views to the water tower, along green corridors within the site. This will also help protect views of the water tower to the north. The aim of integrating the settlement with the rural landscape is also furthered by the inclusion of lower density housing towards the northern parts of the area proposed for development, forming an outward-facing, transitional porous settlement edge.

6.7 Structural vegetation is proposed along the western extents of the southern boundary, in order to provide a buffer between the proposed development and the existing housing to the south, as well as the western boundary in order to reinforce and strengthen the existing vegetated buffer to the bridleway. Further structural vegetation is proposed along the northern boundary, following the natural contours of the land form in order to soften the artificially straight line of the hedgerow that cuts across the landscape. Belts of structural 10 vegetation running broadly east/west more centrally within the site similarly follow the existing contours in order to soften the proposed development and integrate it within the surrounding rural landscape - see The Landscape and Visual Opportunities and Constraints plan (LN-LP-04 Rev A).

The proposed development strategy for Greater Cambridge is stated to be 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 proposed development strategy for Greater Cambridge directs the vast majority of growth to the Cambridge Urban Area, the edge of Cambridge and new settlements. A smaller proportion of growth is directed to the Rural Southern Cluster and the Rest of the Rural Area. Of the allocations proposed, the vast majority of these are existing commitments (adopted allocations, sites with planning permission etc.). The Council are only proposing a need for an additional 11,640 homes to be allocated through the emerging Local Plan. This further emphasises that the Plan is failing to proactively plan for sufficient homes as discussed in respect of Policy S/JH.
Countryside support the principle of the proposed development strategy and recognise that a range of sites will be required in order to deliver this strategy.
Concern however is raised regarding how the proposed strategy has been interpreted into the allocations proposed. Furthermore, in light of our discussions in relation to Policy S/J, it is clear that additional allocations will be required in order to deliver an appropriate and effective quantum of housing to support the wider plan aspirations.

5.0 POLICY S/DS: DEVELOPMENT STRATEGY

5.1 In line with the above, policy S/DS seeks the plan to provide 44,400 dwellings with a 10% buffer added for flexibility, totalling a need for 48,840 dwellings within the plan period. Page 32 of the First Proposals document shows that 37,200 are commitments, windfall etc, leaving a further 11,640 to be planned for. Curiously, when totalled together, the proposed allocations only total 11,596 leaving a shortfall of 44 dwellings.

5.2 In order to make up this shortfall, the Coton site could come forward. Whilst it has a capacity for 77 dwellings, the additional 33 dwellings would assist the Council should any other site provide delayed delivery. However, concern is raised below about delivery potential within the Strategy, which would significantly increase shortfall within the Plan period. These representations show why the Coton site is considered appropriate, although this can be summarised as: • The Green Belt assessment for a wider plot shows a ‘moderate’ harm, whereby an assessment by EDP shows the Site itself provides a ‘Low’ contribution to Green Belt objectives; • Coton is within 2 miles of West Cambridge and the village has seen limited growth in recent years, not allowing the village to evolve; • The Comberton Greenway is improving access to West Cambridge for cyclists and pedestrians, with Grange Road, Cambridge a 17 minute cycle ride form the village; • Coton is situated on the proposed Cambourne to Cambridge Busway (as shown on Figure 11 of the First Proposals document) and a station at Coton will provide further transport alternatives to the car; • Delivery of 40% affordable housing; • Development would benefit services and facilities within the village including the public house, post office and garden centre.

5.3 When assessing the Development Strategy, it is important to look at past delivery rates. Unfortunately, there are no formal figures available beyond 2019/20. However, this does provide useful context when looking at ‘current’ delivery rates. The table below summarises housing delivery in the past four years. The ‘total’ figure shows a fluctuating delivery rate that falls well below emerging Local Plan target of 2,114 dwellings per annum. It highlights that a robust strategy is necessary to increase delivery rates beyond this level. Area 2016/17 2017/18 2018/19 2019/20 Cambridge 1,183 1,112 868 460 South Cambridgeshire 551 737 1,152 1,107 Total 1,734 1,849 2,020 1,567

5.4 It is well known that larger sites have significant constraints to delivery compared to smaller sites. They have larger lead-in times, and therefore any delay will significantly impact delivery figures. A good example of this is Bourn Airfield. It is an allocated site in the current plan, yet it still does not benefit from a formal outline planning permission. The application (ref S/3440/18/OL) has now been with the Council for over 3 years without formal determination.

5.5 Given the need to then submit reserved matters applications, prepare necessary infrastructure and clarify the route of the Cambourne to Cambridge Busway, the ability for the site to commence delivery in 2023/24 seems very optimistic. Given the delays to the development already, the proposed delivery rates at Bourn Airfield does not appear reliable or robust.

5.6 The Development Strategy appears to have two key directions, those being development on the edge of Cambridge and increased delivery rates at the new settlements.

5.7 A key site at Cambridge is the North East Cambridge site. The proposed policy shows that the site will provide 3,900 dwellings between 2020 and 2041. The area has not been subject to a planning application as yet given the reliance upon the production of an Area Action Plan.

5.8 The Area Action Plan has been subject to a recent public consultation, and a report to the Joint Local Planning Advisory Group on 30 November 2021 sets out proposed changes to the Area Action Plan as a result of an assessment of the public responses. Of note, the proposed changes include a reduction in densities of development, a reduction in building heights and an increase in proposed open space provision by 17 hectares. However, despite these significant changes, the total housing numbers within the Local Plan remains the same. However, the nature of the changes to the Area Action Plan must impact upon delivery by its very nature. Proposed delivery rates at North East Cambridge must therefore be revised in line with the recommendations to the Joint Local Planning Advisory Group.

5.9 In addition to this, North East Cambridge is reliant upon the relocation of the existing sewage treatment works on the site. This is highly contentious locally and will no doubt be subject to legal challenge ahead of any relocation. The process has the potential to delay development and delivery at North East Cambridge. The ability of the area to provide 3,900 dwellings by 2041 therefore appears overly-ambitious, with any delay to the treatment works seriously impacting upon the Council’s delivery ambitions.

5.10 With regards the increase in delivery rates at new settlements, the emerging policy specifies this will relate to the new settlements of Northstowe and Waterbeach. This raises an immediate concern regarding how this is to be achieved. The ‘Housing Delivery Study for Greater Cambridge’ October 2021 document provides a justification for Northstowe given the quicker delivery methods of Urban Splash within phase 2A. As per Waterbeach, the development is expected to deliver an additional 50 dwellings per annum from 2026/27 onwards, resulting in 750 additional dwellings by the end of the proposed plan period.

5.11 However, unlike Northstowe, there is no justification as to how Waterbeach will achieve this increase in housing delivery. It is assumed the figures factor in another ‘peak outlet’ to deliver the additional 50 dwellings per annum. However, if the scheme was capable of having 7 developers on site at the same time, why was that part of the original build out rates from the current iteration of the Local Plan? The proposals seem overly generous and lack any clear justification that the increased delivery rates are achievable.

5.12 Historically, South Cambridgeshire District Council has relied upon new settlements and urban extensions to deliver the majority of its housing need. Martin Grant Homes has previously argued that this is to the detriment of villages, which as a result become dormant and suffer from a lack of inward investment.

5.13 The above information confirms there is significant doubt regarding the spatial strategy and the associated housing trajectory. There are serious concerns regarding delivery rates at Bourn Airfield, Waterbeach and North East Cambridge, which will impact upon Greater Cambridge’s ability to provide a five year housing land supply.

5.14 The solution therefore would be to add further small and medium sized sites within the trajectory. This would cover off any delays in delivery. Smaller sites benefit from limited infrastructure improvements, and take significantly less time in the planning system. These advantages are set out in paragraph 69 of the National Planning Policy Framework 2021.

5.15 The emerging Local Plan is reliant upon some Green Belt release to meet the housing delivery targets. This includes release of land around the edge of Cambridge, as well as two sites within Green Belt villages.

5.16 Martin Grant Homes support the release of Green Belt land in order to meet some of this housing need. By their location, Green Belt villages such as Coton are situated in close proximity to Cambridge and as such can play an important role in supporting the City. These representations justify why Green Belt release in Coton would promote sustainable development opportunities. The Local Plan however does not fully capitalise on appropriate Green Belt release, instead shifting development to more unsustainable locations (such as Melbourn and Duxford) where there will be more reliance upon the car.

5.17 Martin Grant Homes reserve the right to further assess delivery rates through the further phases of Local Plan preparation.

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. Consistent with this strategy, it is considered to be very important that some growth is delivered in villages that are located outside of the Green Belt, such as Melbourn. 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.

3.2 The CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. The proposed Cambridge South Station proposes significant sustainable transport improvements between Cambridge and Meldreth Station, which is within walking distance to Melbourn.

3.3 In addition, Melbourn, benefits from being a sustainable settlement in its own right. Melbourn is a Minor Rural Centre (as defined within the adopted Local Plan) that is not situated within the Green Belt. It is also benefits from both primary and secondary education facilities and a large range of services, including shops, pubs, restaurants and community facilities.

3.4 One of the 19 new sites being considered for allocation in the local plan is located to the north east of Melbourn (Land to the West of Cambridge Road, 120 housing units). It is considered that Land off Water Lane is in a more sustainable location, being closer to the village centre. Furthermore, the Water Lane site is located further from any listed buildings and the Melbourn Conservation Area than the West of Cambridge Road site, reducing the chance of adverse effect on these heritage assets. Unlike at the Water Lane site, archaeological evaluation has identified significant archaeology of Roman date at the West of Cambridge Road site. This could lead to complications in delivering the site. Given the acute need for housing in the area, it is considered that making multiple allocations at Melbourn could also be a suitable approach to ensure much need housing is delivered in this sustainable settlement.

3.5 Section 3 of the Technical Note (2021) provide a transport assessment on the sustainability of the site in terms of accessibility to local services and facilities. It demonstrates that the site is well located to access the wide range of existing facilities and public transport links not just in Melbourn but also further afield without the need to use a private car.

3.6 For the above reasons, it is considered that additional growth within Melbourn would be consistent with the objectives of the Local Plan, which seeks to minimise car travel. Of the sites submitted within Melbourn as part of the Call for Sites process, Land off Water Lane, is considered to be a particularly sustainable and suitable site for development. The site would better integrate into the existing built form and relate to the housing development to the north-east.

The Council’s over-reliance on a few major sites (and critically the complex nature of some), we believe, is flawed and likely to result in delivery challenges.
As such, we think it would be prudent for the Councils to allocate more sites in a variety of locations for a wider range of housing. Additional allocations in the villages will help in this regard, as would less complex/constrained sites closer to Cambridge.
Policy S/DS states that the proposed development strategy for Greater Cambridge is to direct development to where it will have the least climate impact and where active and public transport is the natural choice.
In general, we support the principle of focusing development on sites 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. In relation to minimising car travel, this needs to be considered holistically along with a number of other competing objectives, and provision for car travel is not the only criteria to consider when selecting the most appropriate sites to allocate. It is also very important that due regard is given to the national policy and the three objectives of sustainable development set out in the NPPF 2021 (economic, social and environmental). This means allocating land for development to ensure choice and competition for market land, along with ensuring growth to ensure vitality of villages. Growth within villages can also assist with meeting localised housing need (particularly for affordable housing), which will not be met by a small number of strategic allocations around the largest settlements. In accordance with national policy it is also important that where possible growth is directed to sites that are situated outside of the Cambridge Green Belt.
In this regard, it is also important that a suitable level for growth is directed to the villages within South Cambridgeshire. 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. This, however, has not been reflected within the First Proposals within the Local Plan, with minimal allocations within the villages of South Cambridgeshire.
It is suggested that the provision for increasing the range of sites to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and secure affordable housing more immediately and more reliably. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report.
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).
Accounting for the clear recommendations from the Planning Inspector on the 2018 Local Plan, it is not clear why this strategy has not been followed as part of the First Proposals.
Orwell, benefits from being a sustainable settlement in its own right. Orwell is a Group Village (as defined within the adopted Local Plan) that is not situated within the Green Belt. It benefits from primary education facilities, and a range of services, including shops, a pub, and community facilities.
Orwell has a very tightly drawn Development Framework which has remained unaltered since 2003. This does not allow for any windfall development. Orwell did not receive any allocations within the 2018 Local Plan and therefore provision for additional growth as part of the Local Plan 2041 would be appropriate and assist with maintaining viability and vibrancy of the village and meeting identified affordable housing need within Orwell.
For the above reasons, it is considered that the distribution of growth needs to be revisited and that the First Proposals are unsound in their current form. Whilst, clearly allocations that seek to minimise car travel has significant benefits, this should not be the only factor that dictates the most appropriate locations for new housing and employment development. In this regard, policy S/DS is not in accordance with national policy and it is not considered to be justified or effective in its current form.

QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?
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 National Planning Policy Framework (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.
The CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. The proposed Cambridge South Station proposes significant sustainable transport improvements between Cambridge and Meldreth Station, which is within walking distance to Melbourn.
The site at Redgate Road is located in a sustainable area, with the development not overly reliant on car travel, with many public transport options easily accessible. Girton is a Minor Rural Centre (as defined within the adopted Local Plan) which benefits from both Girton Glebe Primary School and Girton Nursey and Pre-School, and a large range of facilities, including shops, pubs, restaurants and community facilities.
The release of the site from the Green Belt would facilitate the creation of a cycleway/footway that could link into the Darwin Green development to the south, on the opposite side of the A14. It is proposed that as part of any development of the site, of any size, a cycleway/footway route connecting Girton to Cambridge to the south would be incorporated and provide an improved linkage over the A14 and directly to the existing cycle and pedestrian links within Cambridge. This would further encourage a shift away from car use and towards more sustainable modes of transport.
It is considered that this limited additional growth within Girton would be consistent with the objectives of the Local Plan, which seeks to minimise car travel. The site would easily integrate into the existing built form of the settlement and relate to the housing development to the west.

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?
We agree that it is very important that housing delivery keeps up for demand for increased jobs within the area.
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.
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.
The Development Strategy Topic Paper that accompanies this consultation acknowledges 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.
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.
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 focus for housing and employment growth with associated infrastructure.
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore carbon emissions, can be minimise?
Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. Consistent with this strategy, it is considered to be very important that some growth is delivered in villages that have existing employment areas and have good access to local services and public transport links. 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 growth strategy is to create nearly 60,000 (58,500) new jobs across within the plan period to support the economic growth of Greater Cambridge. This growth scenario is at the medium level which aligns with the medium scenario for the housing growth strategy. This strategy requires 2,786 new jobs to be created per year. Greater Cambridge is in a unique position outside London that it has a strong growing economy. The main factor holding back the unleashing the economic potential for Greater Cambridge is housing supply. Therefore, it is essential that the Greater Cambridge Local Plan puts forward an ambitious growth strategy so that it can attract and maintain the work force required to enable companies to grow.
The aim of the jobs policies in the First Proposals is to encourage a flourishing and mixed economy in Greater Cambridge with a wide range of jobs. Sensitive small-scale employment development can help sustain rural economies, and provide a wider range of employment opportunities for local residents. Providing jobs near to residents to reduce the need to travel is a key issue. Therefore, it is important that jobs are created in existing employment locations close to existing settlements in order to reduce car travel.
The CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. Histon & Impington is a highly sustainable location with excellent transport links including the Guided Busway and other bus services. It also has a strong employment area which is located alongside the Guided Busway. In the settlement hierarchy, Histon & Impington is identified as a ‘Rural Centre’ which has no limitation on the size of individual schemes.
It is therefore essential that the existing employment areas which are located adjacent to the existing settlement are enabled to grow, particularly in such a sustainable and attractive location as the Villa Road site. The allocation of the Villa Road site for employment use (B2 and E use classes) would attract companies to an establish employment area which has excellent links to a range of existing facilities which can be accessed without the need for car travel.
The Villa Road site is located within close proximity to the NIAB Agricultural Research facility which lies to the north along Villa Road which would complement the employment allocation of the site.
The Villa Road site is enclosed on three sides by an electricity terminal site to northwest, the Guided Busway to the north with large warehouses beyond, and housing to the south-east in Primrose Lane. No sites have been allocated for employment in Histon & Impington. The site represents an ideal and suitable site for employment due to having excellent transport links, being highly accessible by sustainable modes of transport and would not have a detrimental impact on the wider landscape context.

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?
We agree that it is very important that housing delivery keeps up with demand for increased jobs within the Greater Cambridge area.
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. However, a significant proportion of this growth is made up of existing allocations within the current Local Plans.
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.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth; it generally exceeds it. This is in particular due to 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. Therefore, a more ambitious growth strategy should be prepared.
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.
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.
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?
Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. Consistent with this strategy, it is considered to be very important that some growth is delivered in villages. 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 CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. Histon and Impington is on the Cambridge Busway and as such is located along a key public transport link into Cambridge, and also nearby towns of St Ives and Huntingdon within Huntingdonshire District. The Busway provides a service every 7 minutes, providing residents and employees with a reliable and sustainable option for travel. A potential new stop on the busway is currently being considered within Histon and Impington, within close proximity to land owned by our client, this is supported by the Histon and Impington Neighbourhood Plan and would further encourage a shift away from car use, towards more sustainable modes of transport for both existing and future employees and residents.
The release of Land West of South Road, Impington from the Green Belt would facilitate the creation of a cycleway/footway that could link into the Darwin Green development to the south, on the opposite side of the A14. It is proposed that as part of any development of the site, of any size, a cycleway/footway route connecting Histon and Impington to Cambridge to the south would be incorporated and provide an improved linkage over the A14 and directly to the existing cycle and pedestrian links within Cambridge. This would further encourage a shift away from car use and towards more sustainable modes of transport.
The encouragement of the use of public transport, cycling and walking in and around the South Cambridgeshire District and City of Cambridge would assist in addressing a key and fundamental issue, congestion. New development should aim to address this problem which would also be compliant with the key issue of Climate Change, a big theme underlying the new Local Plan. This new link has the potential to reduce pressure on the Strategic Road Network which currently does not have capacity to accommodate any new growth in the area.
In addition, Impington (and Histon), benefit from being sustainable settlements in their own right. Histon and Impington are identified in the current South Cambridgeshire Local Plan as a Rural Centre (Policy S/8) and are described as ‘the largest, most sustainable villages of the District.’ Due to this, there is no strategic constraint on the amount of development land for housing within their development frameworks. They benefit from both primary and secondary education facilities and a large range of services, including shops, pubs, restaurants and community facilities.
For the above reasons, it is considered that additional growth within Impington would be consistent with the objectives of the Local Plan, which seeks to minimise car travel.

Representations to Greater Cambridge Local Plan – First Proposals
On behalf of TTP Campus Ltd

Savills (UK) Ltd are instructed by the TTP Group to make the necessary and relevant submissions to the Greater Cambridge Local Plan – First Proposals document which has been published for consultation.
TTP Group (The Technology Partnership) was established over 34 years ago to create a world leading technology and development organisation. This work has evolved into the TTP Group which is formed by a range of businesses focused on the needs of companies planning to flourish through the use of technology and innovation.
As the enterprise has grown, new companies have been created, some of which have remained within the TTP Group whilst others have been sold, demerged and floated on the London Stock Exchange. The Group is quite rightly proud of its heritage and legacy and an integral part of its success is reflected in its long standing close links with the local community in Melbourn where more recently TTP secured a very significant planning permission to relocate its headquarters building to a site directly north of the existing Melbourn Science Park.
The granting of planning permission on the Birchwood Site
In 2018, TTP submitted a planning application for some 10,000 sq.m. of new commercial floorspace on land north of Melbourn Science Park. Consequently, planning permission was granted in March 2019 for “new office and technology research facilities” under planning application reference S/2941/18/FL. The granting of this permission enabled TTP to set out a clear business strategy for expansion which consented 10,974 sq.m. of new floorspace in two phases comprising:
• The main building (known as The Hive”)
• The Technology Barn
• The Service Building
• The Conference Pod
• The Forum Pod
Since the granting of the original permission a number of design changes were made and resulted in the issuing of a new permission (Section 73) granted in June 2020 (planning application reference S/4535/19/VC). A number of non material amendments were made and all relevant conditions were discharged to enable development to begin on site. Works are at advanced stage on site. A copy of the approved site layout granted planning permission together with the red line application boundary is submitted alongside this text.
It is important to acknowledge at the time of the submission of the application back in 2018 and importantly at the time of determination by the local planning authority, the application site lay outside the identified settlement boundary for Melbourn in the Adopted South Cambridgeshire Local Plan 2018. It was the case at the time of the submission of the original application back in 2018 that the proposals were considered as a departure to the Adopted Local Plan having regard to the Council’s policy position and largely due to the site’s location within what was considered to be countryside where restrictive policies would apply .

Whilst acknowledging that the proposed development would have an impact on the landscape and there would be a loss of agricultural land, the Council also recognised the significant case put forward by the applicant demonstrating the importance of new research and office buildings to support the future needs of TTP adjacent to its existing group of companies and workforce - they acknowledged the continuing importance of TTP in the content of the delivery of important technologies at the regional, national and international market and the planned expansion being able to contribute to local amenities.
The adopted Local Plan policies which sought to ensure the promotion of employment clusters, the development of the employment sector within village frameworks as well as a policy which supported new employment development on the edge of villages were all relevant to the consideration of the planning application. However, the Local Planning Authority acknowledged that there was no specific employment policy within the adopted plan which was directly relevant to the development proposal but it was the case that TTP put forward a case of other material planning considerations to take into account when determining the application. This included the assessment of the economic and social role that TTP play both in terms of the village but also their wider role within the employment sector as a hugely successful home-grown company maintaining significant links to the village.
Consequently, when weighing up the material considerations, officers considered that the adverse impacts arising from the development in terms of environmental harm would not be significant and were demonstrably outweighed by the economic and social benefits of the proposal when taken as a whole.
The granting of this planning permission for the site and its implementation and the current construction on site has clearly changed the character of the area. The previously agricultural character of the land has now been transformed into what will now become a new large modern office and research campus encompassing a series of buildings set in a redesigned landscape with the consequent infrastructure requirements of parking and internal road, cycleways and pathways. The consented scheme and this change in character as a result of the planning permission being implemented now means that this needs the new emerging Joint Local Plan to recognise this context. ie, a change to the inset boundary to include that application boundary within the settlement limit for Melbourn. (see enclosed plan)
This is reflective of the Council’s approval for the development and the recognition that the character of the site and its immediate surroundings will change as a result of the built form and the necessary infrastructural and landscaping works which will come forward as part of the proposal.

Policy S/DS – Development Strategy
One of the key roles for a new Local Plan for the Cambridge area is to set out the proposed strategy for the pattern, scale and design quality of places. The overall strategy is one of directing development to where it has the least climate impact, where active and public transport is a 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 that all necessary utilities can be provided in a sustainable way.
Clearly, there is a significant change in the character between the built area and the rural area around it and therefore it is imperative that wherever new development comes forward that the distinctive character of the City, towns and villages are not adversely affected through new development.
In this context it is important that any development strategy being adopted by the planning authorities exploits and takes up the opportunities to use brownfield land (previously developed land) to ensure ,where appropriate, the protection of other more sensitive locations in the countryside. In the context of Melbourn, submissions have been made to amend the village framework to acknowledge the change in character of the landscape having regard to the granting of the planning permission for the new TTP headquarters north of Melbourn Science Park. Placing the new buildings within the settlement envelope is the logical approach and acknowledges the policy context where potential expansion could occur on that site having regard to its location within the development envelope. Clearly, the normal development management policies would apply of design, materials, privacy and amenity but importantly the principle of development in that location should not be one that is an issue.
Certainly the principle of supporting new employment development within existing settlements is not new to the plan and we are pleased to see under Policy J/NE “New Employment Development Proposals” that the proposed policy direction with the new local plan is one that acknowledges that employment development (classes E9g), B2 and B8) will be supported “within towns and villages, where it is of an appropriate scale and character to the location and scale of development. The policy would cover both new premises and the expansion of existing premises” (page 228 of the consultation document)
The policy direction for new employment development as set out in the consultation document on page 228 reflects the need of the Councils to acknowledge the crucial role that the Cambridge area plays in terms of the local and national economy. It must provide the policy context for positive growth in the economy and has sought to do this by supporting identified employment clusters for the larger employment locations such as Babraham and at Granta Park as well as the new towns at Northstowe and at Waterbeach.
At the more local level the Councils have allocated a mixed use site adjacent to Melbourn Science Park including some 2.5 has for employment use. The wording under proposed policy S/RRA/CR on page 128 of the consultation document states that such an element represents an opportunity to expand Melbourn Science Park . the allocation is supported by TPP on the basis that such an allocation reflects an acknowledge of the role that Melbourn plays as a Minor Rural Centre in the Plan and the very real important links that the Park has to the local community.

Bruntwood SciTech are the recent new freehold owners of Melbourn Science Park and as landowners, seek to engage proactively with the plan making process. Established in 2018, Bruntwood SciTech is a 50:50 joint venture between Bruntwood and Legal & General and is the UK’s largest property provider dedicated to driving the growth of the science and technology sector.

With 10 campuses in six locations across Birmingham, Cheshire, Leeds, Liverpool, Manchester, Oxford and Cambridge, Bruntwood SciTech provides significant opportunities for science and tech businesses to connect, collaborate and grow.

With the new Joint Local Plan that is intended to run up to 2041, it is imperative that landowners such as Bruntwood Sci Tech are involved in the process of shaping policies and plans over this period of time.
Savills (UK) Ltd are instructed by Bruntwood SciTech to make the necessary submissions. (Savills have acted for Melbourn Science Park Ltd as previous owners of the site).
We confirm that a strategy of preparing the first Joint Local Plan for the Cambridge area is supported. There is a very strong symbiotic relationship between the built up area of Cambridge and the surrounding 101 villages as well as the market towns lying further afield. Given that many living within the surrounding villages turn to the City for work, retail, leisure and entertainment it is clear that a planning framework that acknowledges this relationship needs to be developed.

Paragraph 2.1
Figure 4 is an illustrative map showing the locations of proposed new housing development 2020 – 2041 and identifies a site at Melbourn for 140 homes. On the basis of the supporting paragraphs, it is logical to assume that the reasons behind the Council identifying new development in Melbourn is consistent with the strategy of directing development to where it has the least climate impact, where active and public transport is the natural choice, or green infrastructure can be delivered alongside new development and where jobs, services and facilities can be located near to where people live.
In the context of the proposed new housing development in Melbourn, it is the case that the village retains a very strong employment base and the history of major companies being attracted to the village continues to evolve - the current expansion of the new TTP group headquarters on the northern side of Melbourn Science Park and the aspirations of the new owners of that Park (Bruntwood SciTech) reflect the strong commitment of firms to invest in Melbourn. It is Bruntwood Sci Tech’s objective to become the leading network of thriving innovation districts acquiring buildings and sites for the long term and currently brings together a collaborative community of over 500 businesses across the UK. Its business strategy is to continue to grow the business through further acquisitions and the steady growth of existing sites and aims to provide 40,000 high value jobs over next 10 years whilst helping to level-up and rebalance the UK economy. As part of this growth, the company provides business support as standard, supporting science and tech companies to form, scale and grow. This includes facilitating access to finance, talent and new markets through connections and an extensive partner network to support the growth of the UK knowledge economy.
The recognition that the Plan gives to Melbourn as a location where growth can occur is important. The relationship between homes and jobs is, of course not a direct one but the provision of major employment opportunity in villages such as Melbourn is intended to reduce travel to work distances and provide the very opportunities that should exist in every settlement for people who wish to live in that village.


Policy S/JH “New Jobs and Homes”
The proposed new Local Plan is intended to follow the objectively assessed needs for development within the plan period 2020 – 2021 to meet the following:
• 58,500 jobs
• 44,400 homes which reflects an annual objectively assessed need of 2,111 homes per year.
The identification of 58,500 jobs reflects the choice of the Councils to provide for the medium growth level from the strategic options that were published in November 2020. The Council contend that this is the most likely figure of new jobs coming forward and whilst they are cognisant of the fact that the research identified the higher growth forecast, it is intended that the plan builds in some flexibility in case the market delivers more jobs than anticipated.

Policy S/DS “Development Strategy”
This policy sets out the proposed strategy for the pattern, scale and design quality of spaces created within Greater Cambridge and sets out where the homes identified in Policy S/GH should be located in order to meet the vision and aims of the Local Plan. In such a context, a development strategy is proposed which reflects the Councils’ intention to largely retain the Cambridge Green Belt whilst directing growth within Cambridge (20%, the edge of Cambridge (24%), new settlements (38%) and finally the rural areas (18%). The broad strategy is one where jobs and homes can be located close to each other and served by good quality public transport, cycling and walking lengths. Whilst the text does not specifically relate to Melbourn which is the home of Melbourn Science Park now owned by Bruntwood SciTech, it does refer to housing and employment in villages that have good public transport access and are close to jobs.

The development strategy needs to continue to tackle significant commuting patterns that have been established over many years between the outlying villages and Cambridge City. The presence of a tightly drawn Green Belt around the edge of the City and then tightly around the necklace villages and beyond means that the opportunities for expansion on the edge of Cambridge and on the surrounding villages is extremely limited. Consequently, this strategy places great reliance on those areas outside of the Cambridge Green Belt to develop and consolidate their employment sector to provide attractive locations for new investment and jobs. Melbourn Science Park provides such a significant opportunity and the new owners will continue to work with the local planning authorities in order to introduce new investment into the Park whilst ensuring that the very qualities and legacy that has been established over many years continues to thrive and prosper.

Policy S/SH “Settlement Hierarchy”
This policy within the Joint Local Plan is intended to group similar settlements into categories that reflect their scale, characteristics and sustainability. The village of Melbourn remains as a Rural Centre within this emerging Local Plan and is supported having regard to the acknowledgement that the Council’s recognise the role that the village can play in accommodating new development and in particular the allocation for a mixed use site on the eastern side of Melbourn Science Park. A Rural Centre places a settlement in a settlement hierarchy which acknowledges its sustainable location and the opportunity that this brings for new investment in terms of new housing as well as supply of new jobs.
In such a context, with Melbourn Science Park having been developed in its current form some 40 years ago, the demands of tenants, new sustainability targets and technology require a review and assessment of new building provision in order to attract new jobs and investment. Bruntwood SciTech as the new owners of Melbourn Science Park recognise the opportunity for the redevelopment of Melbourn Science Park as a previously developed site to bring forward new buildings and open spaces and land uses which are forward thinking and much better reflect the needs and demands of tenants, the businesses in general as well as visitors and the local community. The opportunity to make the best use of previously developed land in this location in a settlement identified as a Rural Centre is logical and reflects a sensible strategy with the opportunities of growth need not all be on greenfield land but rather need to critically analyse existing forms and sites to make best use of a limited resource.
It is the case that the acquisition of Melbourn Science Park is seen as a key strategic component of Bruntwood SciTech ’s science and technology business and will enable them to share knowledge and expertise across these sectors. The intention is to ensure that the site grows as a successful science and technology cluster that is sustainable in the long-term and contributes to the wider Cambridge economy. The company’s experience in these sectors, and with their relationship with funders, aligned to their commitment to expansion ensures that Bruntwood Sci Tech are ideally placed to deliver further growth at Melbourn Science Park.


Policy S/RRA/CR – Land to the West of Cambridge Road, Melbourn
A new mixed use allocation is identified on a 6.5 hectare site immediately to the west of Cambridge Road, Melbourn adjacent to Melbourn Science Park. This allocation has an indicative capacity for approximately 120 homes and some 2.5 hectares for employment uses. As a site that lies adjacent to Melbourn Science Park, there is a clear opportunity to enhance the village’s existing employment sector through more jobs and investment and providing a logical extension to the Park whilst planning for the adjacent residential development in an appropriate manner. Clearly, the layout and the integration with the adjacent Park will be critical and the ability to provide a sensible and logical arrangement for such uses can be achieved and consequently the identification of this allocation is supported by Bruntwood SciTech as the new owners of Melbourn Science Park.

Policy J/NE “New Employment Development Proposals”
This policy is intended to set out criteria which will determine whether proposals for employment development in urban areas, villages and the countryside are acceptable.
Having regard to our clients’ interests within the existing Melbourn Science Park which is already contained within the built up area of Melbourn, it is entirely appropriate that the proposed policy direction within the Greater Cambridge Local Plan is one that simply assesses the appropriate scale and character having regard to its location and the scale of settlement. It is entirely appropriate in this context to acknowledge that the present use of the site as a employment park is accepted and that the nature and scale of its existing character provides the opportunity for redevelopment to develop a much more modern approach to employment parks and to work alongside the authorities and the local community to develop a strong vision that continues the legacy of this part of the village to the village of Melbourn. As the Local Plan quite rightly acknowledges, for developments within town and village settlement boundaries, it is the scale and character that are key to ensuring that the overall character of the settlement is maintained. In such a case the Council expect that larger proposals are likely to be considered favourably in towns and Rural Centres and where Melbourn as identified as the latter within the settlement hierarchy it is entirely appropriate that our client looks positively at the opportunities that exist for redevelopment of the park. Whilst the Local Plan similarly does not list Melbourn Science Park as one of the key employment sites outside the Green Belt as stated in the Local Plan 2018, supporting text to Policy J/NE states that development in locations which provide a range of suitable units, including for start ups, SME’s and incubatory units will be supported.

General Comments
Our client is generally supportive of the Plan’s vision and overall aims as set out at Section 2 of the consultation document, and in particular with the aim to plan for enough housing to meet needs, including significant quantities of housing that is affordable to rent and buy, and different kinds of homes to suit diverse communities.
The First Proposals document supports the delivery of 44,400 new homes over the Plan period 2020 to 2041. This reflects an objectively assessed need for 1,771 homes per year to be built in the Greater Cambridge area and evidence showing a need to plan for about 550 additional homes per year to meet need for housing. The Plan explains that this is the number associated with the most likely future level of jobs and assumes that all the additional homes generated by forecast jobs above those supported by the Standard Method will be provided in full within Greater Cambridge.
The Plan’s strategy is to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live. The strategy proposes 19 additional sites for development, and states that these sites together with those already within the Cambridge City and South Cambridgeshire 2018 Local Plans, will be adequate to meet this housing need.

Addressing Housing Delivery.
As set out above, the Plan’s strategy proposes 19 additional sites for development, and states that these sites, together with those already within the Cambridge City and South Cambridgeshire 2018 Local Plans, will be adequate to meet this housing need. Figure 4 of the consultation document shows the proposed new housing allocations together with locations of additional new homes on existing allocated sites, locations for faster delivery of homes already planned, and currently planned
development to be delivered by adopted allocations, existing permissions and windfall allowance.
The majority of the locations for proposed new housing shown on the Figure 4 illustrative map are large sites of 500 or more homes which will deliver a slower rate in the early years being less likely to make a contribution to housing completions within the first five years in comparison with smaller or medium sized sites. NPPF paragraph 69 states 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.
We contend therefore that Policies S/JH and D/DS would not be sound on the basis because they would not be justified or effective. Our view is that for a housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of housing in the right place, including further small and medium sized additional housing sites.

Rural Housing Needs.
The First Proposals consultation document confirms that Greater Cambridge wants its rural villages to continue to thrive and sustain their local services but doesn’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. The strategy is for some development in and around larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, the two authorities will continue to support infill development
and affordable housing on suitable sites, but that village growth is not proposed. The Plan explains that the evidence shows that villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of our villages. Alongside rolling forward a number of existing housing sites, the consultation explains that a limited number of new sites for housing have been identified at more sustainable villages and a design-led approach has been taken to identifying housing capacity at these sites.
The development strategy proposes some development in the rural area south of Cambridge, the Rural Southern Cluster, where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links. In the rest of the rural area, the Plan proposes a very limited amount of development including small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive.
The Plan acknowledges that providing a limited amount of development in the rest of the rural area can help meet the specific needs of specific employment sectors, support delivery of a range of types and sizes of housing across the Greater Cambridge area, and can support the social sustainability of villages and help support community aspirations but that this must be balanced with the implications for climate change of distributing development.
It is clear from Figure 4 (illustrative map showing the locations of proposed new housing development) that no new housing is proposed across the rural southwestern part of South Cambridgeshire except for housing allocations proposed at Melbourn: Moor Lane (up to 20 homes – site ML) and land to the west of Cambridge Road (up to 140 homes – site CR).
A considerable body of evidence demonstrates that there is a lack of affordable housing in rural areas across the UK and this is particularly acute in the Cambridgeshire. In South Cambridgeshire the affordability ratio of the 25% lowest house prices and 25% lowest incomes is 10.8 (September 2020, Housing Market Bulletin) is more than 3 times the level considered to be affordable. Failure to deliver an appropriate supply of new homes within this part of the Greater Cambridge rural area will mean that
affordability will worsen.
We consider that for the housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of rural housing, the right type of rural housing and in the right place to meet local needs for this part of Greater Cambridge, including much-needed affordable homes. The absence of additional housing allocations within the rural southwestern part of South Cambridgeshire other than the two sites at Melbourn, means that Plan is unlikely to meet the specific housing needs of this part of Greater Cambridge.

Additional growth arising from Oxford-Cambridge Arc.
The consultation document acknowledges that Greater Cambridge sits at the heart of several economic corridors including the Oxford-Cambridge Arc and that an Oxford-Cambridge Spatial Framework is in the process of being prepared by Government. Reference is made to the consultation undertaken in September and October 2021 which sought views on a vision for the Arc. The First Proposals Consultation acknowledges that the outcome of the Oxford-Cambridge framework is unknown at this point but that it is hoped that by developing a clear and positive vision for the future of the Greater Cambridge area, the joint authorities will be able to shape the proposals.
Notwithstanding that the level of growth to be delivered in the Arc has yet to be quantified - a July 2021 statement by the Housing Minister clarified that the National Infrastructure Commission 2017 report target of up to one million new homes within the Arc is not Government policy - our view is that the development strategy proposed by Greater Cambridge is unlikely to be sound in terms of providing an effective housing strategy given the limited number of additional housing sites would be likely to be incapable of providing a sufficient level of flexibility to deliver additional growth which will come through the Oxford-Cambridge Arc.

Summary
We act on behalf of our client, Mill Stream Developments, and have been instructed to submit this representation to the Greater Cambridge Local Plan First Proposals Consultation. We look forward to continuing to work with the Shared Planning Service as it prepares a new Local Plan for the Greater Cambridge area and would welcome the opportunity to comment on further iterations of the Plan.
We contend therefore that Policies S/JH and D/DS would not be sound on the basis because they would not be justified or effective. Our view is that for a housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of housing in the right place, including further small and medium sized additional housing sites.
We consider that for the housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of rural housing, the right type of rural housing and in the right place to meet local needs for this part of Greater Cambridge, including much-needed affordable homes. The absence of additional housing allocations within the rural southwestern part of South Cambridgeshire other than the two sites at Melbourn, means that Plan is unlikely to meet the specific housing needs of this part of Greater Cambridge.
Our view is that the development strategy proposed by Greater Cambridge is unlikely to be sound in terms of providing an effective housing strategy given the limited number of additional housing sites would be likely to be incapable of providing a sufficient level of flexibility to deliver additional growth which will come through the Oxford-Cambridge Arc.
Finally, we continue to be of the view that our client’s site represents a sustainable opportunity to deliver residential development with significant benefits and only very limited adverse impacts. Against this background, we would request that our client’s site is included for
consideration at the next plan-making stage.

I am writing to give feedback on the local plan after recently visiting an exhibition.

My view is that you are moving forward with extra housing without a clear idea of how this will impact the rest of the city/wider area. You can't tell us how these developments will affect us, but you want us to tell you what we think - I think you need to do the work and publish clear models showing the impact on traffic and public transport usage and then on the basis of those models ask us what we think. Until that information is available, then I think we should proceed as slowly as central government allows and certainly not seek to accelerate already approved projects.
I agree that the most important factors when considering a new development should be its environmental impact and its impact on local traffic. Building near workplaces and in a way to encourage green travel makes sense, but it will only mitigate the extra travel - you need to tell us how many potential journeys you think these mitigating factors will save and how many journeys you think will still be made. I also agree that encouraging use of public transport is a good thing, but with the scale of the developments proposed the strain on existing public transport infrastructure would be unbearable - again before we can say if we approve of the developments you have to have a plan as to how the public transport system will be transformed to cope with all those extra journeys, and you have to tell us that plan in a clear and easily understood fashion. If the plan is: "build the houses and then see what we need" then the new occupants of the new houses will establish habits around car travel, habits that will be hard to break and the impact on congestion will be severe.
In summary, if you don't provide fuller, better information on the impacts of developments then my response will be "NO" to them all.

Can I also say how extraordinary your webpage on providing feedback is - these two sentences stand out on a page that seems entirely designed to discourage feedback while at the same time saying it welcomes it:
" We would be grateful if you avoided emailing us comments or documents, as we will have to manually enter them into the consultation system and ascribe them to policies or sites."
" If you want to know more about how to comment and how we take comments into account, please join our webinar about the comment process."
Obviously I have ignored the first of these, not out of spite but simply because I could see no other way of providing feedback that wasn't the quick questionnaire.

We broadly support the proposed policy direction in terms of where development should be focused (where it has the least climate impact etc). Our main concern, as detailed in previous sections, is the amount of development proposed.
We do however wish to raise concern over the amount of Green Belt that is likely to be destroyed through these plans. In particular, the NE Cambridge development is referred to as being on brownfield land, but this is only made possible by displacing Cambridge Wastewater Treatment works to Honey Hill, which is in the Green Belt.
As a general point, existing buildings should be re-used wherever possible before new building is considered (“The Greenest building is the one that already exists”– Carl Elefante [1]).
We have commented on some of the specific area proposals under the relevant sections.
[1] https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists

SUMMARY BELOW, REPRESENTATION DOCUMENT ATTACHED

ADDITIONAL DOCUMENTS SUBMITTED TO HELAA SITE 40096

7. Summary & Conclusions

7.1. The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

7.2. The JLP also does not identify how Cambridge can meet its future job targets or identified need, particularly in the mid-tech sector. To achieve the transport, employment and socio economic aims of the JLP, and separately the NECAAP, a radical reappraisal and interrogation of its supporting evidence base is required.

7.3. The evidence base is inconsistent and in places flawed. An allocation for CSPN provides the supporting policy and development management framework to recognise and harness CSP’s continued evolution and regional role as a significant contributor to employment, research and development for the Cambridge and UK economy. Additionally, an allocation for CSPN provides the capacity to deliver on the JLP’s stated employment aims. Its allocation is also an exciting opportunity to keep Cambridge at the forefront of innovation, securing a mid-tech future for Cambridge, the region, and the UK as a Scientific Superpower. Cambridge Science Park

7.4. Cambridge Science Park is the most sustainable location for further employment growth within Greater Cambridge, therefore the emerging JLP should reference the continued importance of Cambridge Science Park as an employment site.

7.5. Given the recognition of all other comparable science parks and employment destinations within the emerging JLP, and the recognition that North East Cambridge is the most sustainable location for development in Greater Cambridge.

7.6. The emerging JLP should therefore include the following policy: Policy S/CSP: New Employment Provision – Cambridge Science Park Appropriate proposals for employment development and redevelopment on Cambridge Science Park (as defined on the Policies Map) will be supported, where they enable the continued development of the Cambridge Cluster of high technology research and development companies. The need for Mid-Tech

7.7. As part of our Call for Sites submission we provided a 2019 report by Volterra (resubmitted for ease of reference), which clearly set out the floorspace requirements of mid-tech occupiers, to 2031 as ranging between c. 80,000 - 450,000 sqm of new floorspac.

7.8. A further Technical Note by Volterra is submitted with these representations setting out our feedback on the methodology and why we believe that the emerging mid-tech sector is not appropriately considered or acknowledged in these requirements, leading to a substantial under-provision of space which, if taken forward, will result in constraints on employment growth in the future. The importance of mid-tech and why it is not covered in the Employment Land Review are summarised as follows: • Mid-tech is not included in the ‘key sectors’ that are used to forecast employment need as these identify previously growing sectors, rather than future growth sectors; • The densities and use classes used to estimate future floorspace need may not be appropriate for the mid-tech sector.

7.9. We would urge Greater Cambridge to review the evidence with regard to mid-tech needs, and to engage with the Cambridge Science Park team to understand the needs of the sector.

7.10. We ask why has there been no consideration of mid-tech as a growth sector? Had this been done, it would be clear that (i) it has a large growth potential and (ii) it would benefit from clustering with CSP.

7.11. Our own analysis of the sectors which make up mid-tech highlights a very significant concentration of mid-tech in the local area. Why is this not acknowledged or given any weight?

7.12. The emerging JLP should recognise the importance of the research, development & innovation that occurs within the Cambridge economy and the need to accelerate the move to net-zero by supporting scientific innovation. The appraisal of CSPN

7.13. A review of the HELAA results for the other large employment sites identifies that there are other sites scoring similarly that are taken forward for Green Belt release.

7.14. Interrogating the two red scores for CSPN these relate to Landscape and the Strategic Highways Impact, the former has been considered on a strategic basis and takes no account of the local landscape (ie the impact of the A14) nor the landscape improvements included within the proposals. The Strategic Highways Impact is questioned for a scheme committed to no net increase.

7.15. However, despite CSP North being categorised as Red for its suitability, the site has been carried forward for the SA and an appraisal undertaken.

7.16. The site again scores similarly to other Green Belt sites taken forward for release. The SA then undertaken for the policies relating to those sites includes the policy mitigation, for example where landscape improvements are included within the policy, those sites are then afforded a more positive score than a site not taken through to policy wording. If this approach were undertaken for CSPN the site would score similarly well through the SA process.

7.17. The arguments made for other sites could also be said of CSP/CSPN but in the context of midtech rather than life sciences. CSP plays a recognised role in the clustering and growth of high-tech firms, supporting start-ups and scale-up businesses, but now needs space to enable mid-tech firms to continue to innovate and grow here. Whilst this growth could occur to a lesser scale on alternative sites outside the Green Belt, this would not benefit from the clustering with CSP and therefore the growth would be lower and less productive (the opportunities provided by a co-located Campus). CSP has, and CSPN will, be subject to significant private sector investment (just as valuable – arguably more so – than public investment) which in turn will deliver benefits to the public sector, such as playing a crucial role in delivering the sustainable travel objectives of the area.

7.18. It is therefore questioned as to why these arguments are recognised in the context of other Green Belt sites but not CSPN? Exceptional circumstances

7.19. The need for mid-tech is demonstrated, and the need for this type of employment space in close proximity to Cambridge Science Park and Cambridge Science Park has a distinct and unique set of characteristics, not available anywhere else at other research facilities in the sub-region and fully aligned with the Government’s Industrial Strategy.

7.20. CSPN would benefit from proximity to CSP and the long term custodianship of Trintiy College Cambridge, the later having made CSP one of the most successful Science Parks in Europe.

7.21. The socio-economic benefits in this location are illustrated, and links to Cambridge Regional College and wider educational institutions will benefit the next generation of innovators.

7.22. The sustainability credentials of delivering this site on a key transport route are clear, whilst the vision for a site with the highest environmental quality are demonstrated. Risks to NECAAP

7.23. Without significant interventions such as those which may be delivered by CSPN, a reduction in vehicle trips at CSP, sufficient to allow the delivery of the wider NECAAP will be difficult to deliver.

Conclusion

7.24. The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

7.25. The JLP also does not identify how Cambridge can meet its future job targets or identified need, particularly in the mid-tech sector. To achieve the transport, employment and socio economic aims of the JLP, and separately the NECAAP, a radical reappraisal and interrogation of its supporting evidence base is required. The evidence base is inconsistent and in places flawed.

7.26. An allocation for CSPN provides the supporting policy and development management framework to recognise and harness CSP’s continued evolution and regional role as a significant contributor to employment, research and development for the Cambridge and UK economy. Additionally, an allocation for CSPN provides the capacity to deliver on the JLP’s stated employment aims. Its allocation is also an exciting opportunity to keep Cambridge at the forefront of innovation, securing a mid-tech future for Cambridge, the region, and the UK as a Scientific Superpower.