S/SH: Settlement hierarchy

OBJECT

Bloor Homes Eastern is promoting land west of Linton for residential development, and in representations has requested that the site is allocated in emerging GCLP. Linton is defined as a Minor Rural Centre in the settlement hierarchy for South Cambridgeshire, and Bloor Homes Eastern agree with the status of the village because of the very good range of services and facilities in the village and the good accessibility by sustainable modes of transport.

As set out in the representations to Policy S/SB: Settlement Boundaries, it is considered that there is limited capacity within the settlement boundaries of most villages. There are few outstanding development opportunities for 30 dwellings within existing settlement boundaries in Minor Rural Centres, and Linton is an example where there are no opportunities within the boundary for sites of 30 dwellings or more. It is likely that in most cases only small sites for one or two dwellings would be available. It is considered that the site size thresholds for each category of village are largely irrelevant and ineffective because very few sites are actually available, and those that are available would fall below the threshold where affordable housing is required e.g. less than 10 dwellings.

Requested Change

It is requested that a capacity assessment is undertaken of all villages in South Cambridgeshire to determine which potential housing sites might be deliverable or developable during the plan period to 2041, and the number of dwellings that might be delivered from each of those sites.

It is requested that the site size limits for each category of village are deleted and replaced with a general policy that supports development within existing settlement boundaries, in conjunction with a revised development strategy that allocates suitable sites on the edge of existing sustainable villages including at Linton.

“Alongside this, we want our new towns to mature into great places to live and work, making the most of their existing and planned public transport links to Cambridge and other centres. In the case of Cambourne, East-West Rail means that it will be one of the best-connected places in our region, and whilst things like the location of the new station are yet to be resolved, we do think it can develop into a more substantial town with a more fully developed and lively centre.”

• This does not apply only to new towns. Other scales of settlements will be extremely well connected also, e.g. Papworth Everard.
• Papworth Everard is currently a minor rural centre but one that is highly sustainable and has real growth potential. It too could grow, in a sensitive manner, to provide new services and support and improve existing services, helping to make it a vibrant and attractive place to live.

“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, we’ll continue to support infill development and affordable housing on suitable sites, but we do not propose lots of village growth.”

• Given all of the transport improvements planned for the A428/E-W Rail/OxCam Arc corridor, and connecting directly to Papworth Everard, there will be a multitude of transport options available for residents from early in the plan period. Car travel will not therefore be the easiest or only option for getting around.
• Papworth Everard stands out from the other minor rural centres and villages in the plan as what will be one of the best connected villages, if not the best connected village, in the plan area. Unlike many other villages in the plan, therefore, it is a logical location for growth. The southern side of the settlement is the obvious location for such growth in view of its proximity and connection to the various forthcoming new transport and transport upgrade schemes.
• Land at Crow's Nest Farm, Papworth Everard (Greater Cambridge HELAA (2021) Site Reference: 48096) would have excellent transport links and could provide a Rural Travel Hub to optimise and maximise the use of those links, making sustainable travel modes easier and more attractive than car travel for those living at the site, and residents of Papworth Everard more generally.

Policy S/SH Settlement Hierarchy (P48)
Given the range of services and facilities we support Fowlmere’s continued identification as a Group Village over and above an infill village. It is not clear however why the level of housing to come forward in such locations need be pre-judge i.e. ceiling of 8 units or exceptionally 15.

Recommendation: Policy should allow for development in Group Villages up to a scale that can be demonstrated to support and enhance the village moving forward.

1. The settlement of Impington and Histon is located immediately to the north of Cambridge and lies within South Cambridgeshire. Its proximity to the city has the consequence of it functioning as part of the wider city urban area. Policy S/8 of the adopted Local Plan (2018) identifies Histon and Impington as a Rural Centre, this designation is to be carried forward through the GCLP. Rural Centres are classed as the largest, most sustainable villages in Greater Cambridge and are only behind Cambridge and New Settlements in the proposed GCLP Settlement Hierarchy. Indeed, as set out in the submitted Site Promotion Document (SUBMITTED WITH UPDATED CALL FOR SITES FORMS) , the settlement possesses a wide range of shops, services, infrastructure, employment opportunities and public transport links. Our client supports and endorses Histon & Impington’s status as a Rural Centre and this designation should be continued in GCLP.

2. Whilst adopted and proposed policy approach resists development outside of the settlement boundary at Rural Centres, there is no development limit (in terms of no. of dwellings) for sites within the settlement boundary. This policy reflects the positive sustainability credentials of Rural Centres such as Histon & Impington.

3. As set out in our representations on the Development Strategy, sustainable settlements in rural areas have an important role to play in accommodating growth to allow for a flexible and varied supply to be development and to ensure established settlements continue to grow incrementally and thus support the long-term vitality of local services upon which residents rely. The level of growth afforded to each sustainable settlement should be based on:
- Size of the current settlement;
- Service provision and any planned improvements to local community infrastructure such as schools;
- Access to Cambridge Bus Way and rail links;
- Access to high quality local bus services;
- Access to employment opportunities
- Proximity to Cambridge
- Proximity to key public transport corridors

4. As set out in our submitted Site Promotion Document Histon and Impington performs exceptionally well in respect of these key criteria. It is of vital importance that the Councils adopt a highly flexible approach to directing growth to the edge of sustainable villages in the emerging GCLP; especially the Rural Centres, such as Histon & Impington, which have sound and robust sustainability credentials.

The proposed settlement hierarchy will not be effective at delivering required levels of growth to support the vitality of rural villages. Policy S/SH proposes to continue the current policy allowance for certain sized developments to come forwards in each tier of the settlement hierarchy, but in combination with Policy S/SB it will only allow development on sites that are within settlement boundaries.

For the majority of villages, current settlement boundaries are drawn tightly around the built up area and there are few if any sites suitable for redevelopment within them. As set out under Policy S/DS, to resolve this issue, we consider that some growth should be allocated to all settlements or a flexible policy should be adopted to allow a certain level of development on the edge of all villages according to their position in the settlement hierarchy. One such flexible policy would be to draw settlement boundaries more loosely so that they include small sites promoted for development on the outskirts of villages. In this way, it would be possible allow suitable sites to come forward under Policy S/SB.

We are also concerned that the proposed settlement hierarchy has not sufficiently distinguished between the sustainability of settlements based on access to high quality public transport connections. In this respect, we note that the accompanying assessment (Greater Cambridge Local Plan: Topic paper 1: Strategy (Settlement Hierarchy Review appendix) gives 1 point for settlements that are within 8km of Cambridge or a market town (where active travel is deemed possible) and 1 point for settlements with a railway station. It is clearly absurd to suggest that being able to cycle 8km to a nearby town is as sustainable as being able to walk to a railway station. People will not generally cycle 8km to work, but they will get on a train.

The consultation document proposes that this Policy will group together “similar settlements into categories that reflect their scale, characteristics and sustainability”. For each category, it is proposed that the Policy will also set out the scale of development that would be considered acceptable through windfall applications on unallocated sites.

Categories
The approach proposed is very similar to that set out in the adopted South Cambridgeshire Local Plan 2018, including the following categories:
• City
• Town
• Rural Centre
• Minor Rural Centre
• Group Village
• Infill Village

Supporting text (page 47-48) states that “an updated assessment of settlements has been carried out, informed by the level of services and facilities, education, public transport and employment available at each settlement”. It proposes to change the position of only three settlements: Cambourne, Cottenham and Babraham. We have no objection to these three changes. However, given that the categorisations are stated to be based on an assessment of existing services, we believe that it is premature to include both Waterbeach New Town as one of three ‘Towns’ (alongside Cambourne and Northstowe) and to include Bourn Airfield New Village as one of four ‘Rural Centres’ (alongside Histon & Impington, Great Shelford & Stapleford and Sawston). Given the stage of development at both locations, these categorisations are not consistent with the approach taken to assessing existing settlements. They are based entirely on the future development of these strategic sites.

We consider that the policy approach is confusing and should be clarified. If the revised Settlement Hierarchy is to consider not only the existing levels of services and facilities within a settlement, but also the settlement’s potential as a location for sustainable future growth during the plan period, then this approach should be taken to all of the villages. In the absence of this evidence and approach, the strategy is inherently flawed. Where a village lacks existing services for its size, the development plan offers the potential to address that lack of provision in a planned manner.

We are strongly of the view that, based on a current assessment, Hardwick Village should be re-classified as a ‘Minor Rural Centre’ within the Settlement Hierarchy. However, if the future development potential of the village is to be taken into consideration (as per Waterbeach New Town and Bourn Airfield New Village), then Hardwick Village should be identified as a ‘Rural Centre’ and a key location for sustainable development.

The Site Assessment findings are set out in Topic Paper 1 (page 246 onwards). The text on Hardwick is as follows:
“Hardwick has a population of 2,550. It has a high proportion aged between 16 and 69 (70%) and a low proportion of the population is over 70 (10%). Hardwick does not have a secondary school. It has good public transport links as it is on the Citi 4 bus route, although the bus stop is approx. 10-minute walk from the village centre. It is also on the planned Greater Cambridge Partnership route between Cambourne and Cambridge and is awarded an additional point for transport to reflect this. Although well connected, Hardwick does not offer a range of shops and services to warrant moving up the hierarchy. It is in close proximity to the proposed new settlement at Bourn Airfield which will perform as a centre for the surrounding rural hinterland.”

Firstly, it is important to note that the planned centre for Bourn Airfield is 3.5km (as the crow flies) from Hardwick. Further, development is yet to progress at Bourn, has been subject to delay and uncertainty, and will take at least 10 years to deliver a centre that can serve the wider area. In this context; (a) why should residents of Hardwick have to travel 3.5km to additional services at Bourn, when it can be provided in the village; (b) why should residents of Hardwick be subject to the uncertainty over what comes forward there; and (c) why should they have to wait 10 years for these to be available? Travel to Bourn (for what is likely to be limited local services that could be provided in Hardwick) is not considered to be a sustainable strategy.

Whilst somewhat dispersed between the old village core, the 1970s village centre and St Neots Road, there are a range of facilities within Hardwick. These include: a school, pre-school, post office, pub, village store, veterinary surgery and a range of additional shops and services on Cambridge Road and St Neots Road (beauty, hairdressers, pet shop, cafe, tutoring services, etc). In addition, there is an active social club at the recreation ground and a number of community, sport and church groups.

Hardwick scores strongly in terms of accessibility (markedly better than Bourn) to Cambridge and occupies a sustainable location that will benefit from the Cambourne-to-Cambridge public transport scheme, once implemented. In the meantime, the Citi 4 bus route provides a fast and efficient route along St Neots Road with as many bus services as Cambourne and yet benefiting from being significantly closer to Cambridge. In addition, there are safe cycle routes and Hardwick is a commutable cycling distance from both Cambridge and Cambourne. It would seem entirely appropriate to plan for the local needs of Hardwick within the village (as opposed to reliance on Bourn Airfield), given that Hardwick is closer to Cambridge, which will serve its broader needs.

At the strategic scale, Hardwick lies within the Cambridge-Milton Keynes-Oxford (CAMKOX) arc, a key focus for future infrastructure improvement including East West Rail.

Recent developments in Hardwick include Grace Crescent and Land south of St Neots Road. Like the previous Meridian Close development, both of these recent developments were unallocated, windfall sites. However, each site was granted planning permission for major residential development – of a scale much greater than the thresholds suggested for Group Villages within the second part of S/SH (see below). The Green Belt designation has led to the development of Hardwick extending westward from the centre of the village. Our proposed development site at ‘Land east of Cambridge Road’ (Site No. 40414) provides a strategic opportunity for the future sustainable development of the settlement.

Limits of Windfall Developments
It is proposed in the consultation document that S/SH should place a restriction on individual housing scheme size, based on the categorisation of the village in question within the Settlement Hierarchy. This proposes that Cambridge, the Towns and Rural Centres have no limit on windfall scheme size. However, the following are suggested for the remainder of the Hierarchy:
• Minor Rural Centre: indicative maximum scheme size of 30 dwellings.
• Group Village: indicative maximum scheme size of 8 dwellings, and exceptionally consist of up to about 15 dwellings where this would make the best use of a single brownfield site.
• Infill Village: indicative maximum scheme size of 2 dwellings, and exceptionally consist of up to about 8 dwellings where this would lead to the sustainable reuse of a brownfield site bringing positive overall benefit to the village.

We object to this policy approach, and do not consider that these limits should be included as they are overly restrictive and inflexible. We would highlight the policy approach set out in NPPF (paragraph 78) for rural housing:
“In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs.”

Particularly given the lack of village allocations that are proposed in the consultation document, it is important that the policy allows adequate flexibility to respond to needs – which should be the subject of a more rigorous and informative assessment of settlements. As mentioned previously, one of the benefits of allowing medium- and large-scale housing development within villages is that it facilitates the delivery of affordable housing. By comparison, schemes of 2-8 dwellings will rarely include affordable accommodation and therefore does little to address existing or emerging local need.

As mentioned above, Hardwick is currently categorised as a Group Village and yet the scale of windfall developments permitted in recent years has been significantly larger than the thresholds suggested in S/SH. This is considered to provide further evidence that the village should be re-categorised to a higher tier of settlement in the hierarchy. Taking into account recent and ongoing development within Hardwick, and the settlement’s potential within the Plan Period – including the development of the promoted site at land east of Cambridge Road (Site No. 40414) – it is realistic that Hardwick be re-categorised as a Rural Centre.

The settlement hierarchy methodology and tiers are generally supported. The recognition of Cambridge city at the top followed by the existing new settlements/towns including Cambourne is logical. However, decisions on the status of specific settlements within the remaining categories should be paused until the spatial strategy has been finalised. For example, the identification of any new or expanded settlements in the next stage of plan-making may alter the status of other villages.

For example, a new Garden Village or expanded settlement could take on a different role, potentially as a rural Centre or a Minor Rural Centre. Any new settlement should not solely be assumed to be within the same category or status as the three proposed ‘new towns’ of Northstowe, Waterbeach and Cambourne.

Given the proximity to Cambourne, Caxton should have no limit on the scale of individual developments as it lends itself to be a highly sustainable location for future growth in Cambridgeshire given the proposed new railway station at Cambourne as part of the Cambridge to Oxford Arc.

For the reasons set out previously we disagree with the settlement hierarchy and particularly the scale and location of the permissible development in the Minor Rural Centres and Group Villages.

The proposed settlement hierarchy identifies Cambridge at the top of the hierarchy and as the main urban centre in Greater Cambridge. Outside of Cambridge, it is proposed the hierarchy remains as set out within the South Cambridge Local Plan, subject to a number of changes. One of these changes is including Cambourne as a new town, along with Northstowe and Waterbeach new towns. The changes have been informed an updated settlement assessment which identifies that Cambourne is a growing centre, with a growing level of services, facilities, and transport opportunities. As identified at page 48 of the First Proposals, these areas of growth for Cambourne have been “recognised by it now having a town council, and it is considered that this should be recognised in the local plan”. The Church Commissioners for England agree with this assessment and support the identification of Cambourne as a new town within the emerging settlement hierarchy.

Development should be assigned across the settlement hierarchy, with development proportionate to the provision of services and facilities and the public transport network. The proposed policy direction relating to the settlement hierarchy includes restrictions on the indicative maximum scheme sizes that will comprise acceptable windfall development for each settlement tier. Coupled with the overall development strategy for only a small number of site allocations within the rural area, the ability for sustainable developments to come forward is overly restrictive.

Paragraph 009 (Reference ID: 67-009-20190722) of the Planning Practice Guidance (PPG) states “a wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness”. It is not considered that there is robust evidence to demonstrate that the policy direction putting a limit on development in the rural areas is appropriate.

Applying restrictions on the maximum amount of development that is appropriate to any particular tier is not considered to be a justified approach, as the sustainability of settlements and the availability of suitable sites for development can vary between settlements within the same tier. A more appropriate strategy would be to identify additional site allocations within the villages, considering each of the rural settlements on an individual basis. This would assist in meeting the Government’s objective of significantly boosting the supply of homes by ensuring that that a sufficient amount and variety of land can come forward where it is needed (NPPF 2021; Paragraph 60).

It should also be acknowledged that new development can increase the sustainability of an existing settlement through the provision of additional services and facilities, or through enhancing existing services and facilities. New development that is well related to the existing settlement can also have a positive impact upon the long term viability of a place through indirect spending from future occupiers and through supporting rural schools and facilities.

Fowlmere - Settlement Hierarchy - Group Village
Fowlmere is identified in the Settlement Hierarchy as a “Group Village”. In accordance with S/SH, the Group Villages can accommodate indicative maximum scheme size of 8 dwellings, and exceptionally consist of up to about 15 dwellings where this would make the best use of a single brownfield site.

Notwithstanding our fundamental concerns with regards to the lack of development allocated to the Villages and the overly prescriptive restrictions on the quantum of development to come forward within the various tiers of the settlement hierarchy, we are also concerned by the lack of assessment given to Fowlmere in terms of its ability to accommodate growth.

The settlement hierarchy divides the Group Villages into two key categories, those with good transport links and those without good transport links. It is assumed that this division of the Group Villages is as a result of the findings within the transport evidence base, notably the Existing Transport Conditions Report (2020). We have significant concerns with regards to this approach which appears to adopt a simplistic method of categorising settlements and their ability to accommodate development.

Those Group Villages identified as benefitting from very good public transport access were subsequently assessed in terms of their ability to accommodate rural allocations for housing (as confirmed through the Councils’ Development Strategy Topic Paper 2021). Whilst it is noted on Page 263 of the Development Strategy Topic Paper 2021 that all Group Villages were assessed using the points system, only those considered to have good existing or proposed sustainable transport links were assessed in further detail in terms of their ability to accommodate development.

Fowlmere was not further assessed as it was not considered to benefit from very good transport links. We disagree with this conclusion and consider this to be an omission in the Councils’ assessment as a result of overlooking a key bus service within the settlement, as discussed below.

The Councils’ Existing Transport Conditions Report (2020) fails to identify a bus service which serves Fowlmere (Stagecoach 915). This bus service provides frequent links between Cambridge/Trumpington Park and Ride and Royston. At particular points in the day, bus services 915 and 31 collectively service Fowlmere with two buses an hour.

Bus Service 915 Bus Service 31
06:46 -
07:46 07:27
08:46 -
09:46 09:37
10:46 -
11:46 11:07
12:46 12:37
13:46 -
14:46 14:07
15:46 -
17:22 -
18:22 -
19:22 -

This bus route also connects Fowlmere with nearby Melbourn and Foxton, offering existing and future residents the ability to access a train station. It should also be noted that Fowlmere is a 6 minute journey to Foxton, which benefits from a train station and busway, and also a 9 minute journey to Melbourn, which also benefits from a train station. Fowlmere therefore represents a sustainable location for accommodating development.

A number of the Group Villages that are considered to benefit from good transport links, including Longstanton, are only currently serviced by an hourly bus service into Cambridge, which is less frequent than Fowlmere (which is occasionally throughout the day serviced by two bus services). Fowlmere is also located 2.6 miles from the train station in Foxton, which provides frequent links with Cambridge City. It is therefore unclear why Fowlmere has not been included within the Group Villages considered to benefit from good transport links.

The Councils’ Development Strategy Topic Paper 2021 clearly states that only those sites that were tested in the HELAA and identified as potential development options in the better served villages were subsequently subject to site specific consideration for allocation and for sustainability appraisal.

It is strongly considered that the failure of the evidence base to consider all modes of transport and bus services within Fowlmere and its connectivity to the surrounding settlements represents a flaw in the overall settlement assessment. Modes of public transport should not be viewed in isolation, rather should also be viewed collectively, with future residents being able to use both bus and train links to travel across the Greater Cambridge area, rather than a single mode of transport. This has subsequently resulted in sites that are being promoted within Fowlmere not being properly considered for development and not being subject to an independent site assessment.

Employment Opportunities
It is acknowledged that an existing employment site off The Way, Fowlmere, is subject to a pending Outline planning application for mixed use development comprising the demolition of the existing buildings and the erection of 45 dwellings and a new office building (reference 21/00542/OUT).

A large proportion of this employment site was previously occupied by Welding Alloys Ltd. However, Welding Alloys has moved its production element of the business to France which has left an extensive vacancy of buildings on site. The buildings on the site are understood to be purpose built for Welding Alloys and despite enquiries during the marketing of the site, the units have not been desirable to new potential occupiers, with more suitable premises elsewhere, including other premises within Fowlmere.

Despite the lack of suitability of the existing employment site leading to proposals for redevelopment, the Outline planning application includes a new office building as part of the scheme, which will be a modern and fit for purpose building. This demonstrates that Fowlmere remains a desirable location for new employment.
The desirability and suitability of Fowlmere as an employment location is reinforced by the presence of long-standing employers within the village. One of these is Ion Science (a world leader in gas detection equipment and research), who has been a key employer in Fowlmere since 1989.

In August 2021, planning permission was granted (reference 21/02683/FUL) for the erection of a new 3,050 sq.m Science Research and Development Office for Ion Science at the Butts Business Centre on the Manor Farm Business Park. The new facility will supplement production and management options at the company’s existing headquarters.

Ion Science is an established company and values Fowlmere as an employment location and are committed to staying there. The provision of the new Science Research and Development Office will allow Ion Science to continue operating in the local area and will provide additional jobs. Despite the proposed redevelopment of the existing employment site off The Way, it is evident that Fowlmere is a desirable employment location.

As well as desirable, Fowlmere is also a sustainable employment location. This is demonstrated through the car parking thresholds for the recently approved Ion Science application (21/02683/FUL). The required parking standard for the size of unit was 29 spaces, whilst the application was approved on the basis of 17 car parking spaces, taking into consideration the travel patterns of existing Ion Science employees. This demonstrates that access to Fowlmere is not reliant on the private car and sustainable modes of transport are available.

Fowlmere is an employment destination and a desirable location for companies, as shown through Ion Science’s desire to retain within the settlement. To ensure that employment growth is supported by sufficient housing, Fowlmere should accommodate housing sites, failing which could be at risk of falling short of meeting criterion c) of Paragraph 82 of the NPPF (2021). Land West of London Road Fowlmere lies adjacent to the employment opportunities at the Manor Farm Business Park, offers a sustainable and suitable location for development and is immediately available.

Development should be assigned across the settlement hierarchy, with development proportionate to the provision of services and facilities and the public transport network. The proposed policy direction relating to the settlement hierarchy includes restrictions on the indicative maximum scheme sizes that will comprise acceptable windfall development for each settlement tier. Coupled with the overall development strategy for only a small number of site allocations within the rural area, the ability for sustainable developments to come forward is overly restricted.
Paragraph 009 (Reference ID: 67-009-20190722) of the Planning Practice Guidance (PPG) states “a wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness”. We are unaware of any robust evidence to demonstrate that the policy direction putting a limit on development in the rural areas is appropriate.
Applying restrictions on the maximum amount of development that is appropriate to any particular tier is not considered to be a justified approach, as the sustainability of settlements and the availability of suitable sites for development can vary between settlements within the same tier. A more appropriate strategy would be to make additional site allocations, considering the rural settlements on an individual basis. This would help meet with the Government’s objective of significantly boosting the supply of homes by ensuring that that a sufficient amount and variety of land can come forward where it is needed (NPPF 2021, Paragraph 60).
New development can increase the sustainability of a wider settlement through the provision of additional services and facilities, or through enhancing existing services and facilities. New development that is well related to the existing settlement can also have a positive impact upon the long term viability of a place through indirect spending from future occupiers.

Melbourn (Minor Rural Centre)
Melbourn is identified in the Settlement Hierarchy as a ‘Minor Rural Centre’. We do not disagree with Melbourn’s position in the Settlement Hierarchy and endorse its recognition as a sustainable location and able to accommodate additional residential growth.
The policy direction in the First Proposals document, however, is that Minor Rural Centres will support an indicative maximum scheme size of 30 dwellings. It is evident that Melbourn is capable of accommodating larger sites, with the proposed allocation for 120 dwellings at land to the west of Cambridge Road (Policy reference S/RRA/CR). We do not support the overly prescriptive restriction on the quantum of dwellings to come forward within this tier in the Settlement Hierarchy, which does not align with its position and identification as the largest district within the south west of the district.

Grosvenor objects to the settlement hierarchy classification of Whittlesford. These concerns are explained in detail in section 4 of the Representation and Design Vision reports attached. The settlement hierarchy methodology should increase scoring of locations with excellent public transport access to the City of Cambridge, employment and services. Choices of active transport underpin sustainable patterns of living. Figure 8 of the Design Vision contains a recalibration of the settlement scoring for Whittlesford. This results in an additional 3 points, increasing Whittlesford’s status to Minor Rural Centre, reinforcing its suitability as a sustainable location for growth.

LVA consider the levels of growth attributed to Infill Villages (indicative maximum scheme size of 2 dwellings, and exceptionally consist of up to about 8 dwellings where this would lead to the sustainable reuse of a brownfield site bringing positive overall benefit to the village) far too restrictive.

The Local Plan should take a more flexible approach to development at Infill Villages and thus encourage an increased amount of growth that that currently proposed, particularly at those that are capable of doing so such as Caxton. This can provide an important contribution to housing land supply over long and short-term period. Housing is needed in villages to support and retain local services and allow vitality. This is highlighted in paragraph 79 of the Framework to promote sustainable development. There is also a need to provide affordable homes suitable for elderly and younger residents to continue living in villages – market housing can support the delivery of such need. LVA would welcome the identification of housing requirements for all villages, particularly so at Infill Villages. The Council must make absolutely certain that sufficient land is identified for development to provide a supply of deliverable sites through the way of allocations.

The Infill Village of Caxton is an example of such a settlement that would be suitable for new housing growth over the Local Plan period. Caxton sits approximately 9 mile west of Cambridge City Centre, 9 miles to the east of St Neots and 1.5 miles to the centre of Cambourne, and contains the following services:
• A church;
• Village hall;
• Allotments; and
• Informal open space and children’s equipped play areas.
• Regular bus services to Cambridge and St Neots.

Caxton also benefits from a number of services and facilities which are available for the local community but are located just outside the settlement boundary. In most cases, Caxton is the closest built-up area to some of these facilities:
• Shopping and food facilities at Caxton Gibbet including McDonalds, Subway, Costa and a Costcutter convenience store.
• Shell Petrol Station (including an ATM) and a car wash;
• A pet store;
• Soft play centre for young children.

The consideration of the sustainability of settlements, especially at villages, should also not be done so in isolation. Instead, access to services and facilities within surrounding settlements within its hinterland should be appropriately considered as people do not meet their needs solely within the settlement they reside. They rely upon the network of urban areas within the locality. Caxton not only benefits from the services and facilities within its village area but is within close proximity to Cambourne and Cambridge City. The site sits approximately 0.6km from Lower Cambourne and less than 9 miles from Cambridge City Centre. Cambourne contains a large range of shops, services and facilities, and is also due to be served by a new East West Rail station. Such a strategic decision to create a new town and rail station is clearly intended to support the local outlying villages and settlements. To a large extent this is the spatial purpose of the creation of this new town.

Whilst in many Infill Villages there will have been little change to the composition of local facilities, that is not the case since 2014 in Caxton. Existing and planned services and facilities at Cambourne are readily accessible to residents of Caxton either via bus, foot, bicycle or car. The Bourne Airfield allocation is also expected to build upon the services and facilities in the wider area; and is within the bus route currently serving Caxton.

The village of Caxton itself stands out as one of the better located and served (in terms of facilities and services) of the ‘Infill Villages’. When considering the wider area and surrounding settlements which support Caxton, the village can be considered to be more sustainable than any of the ‘Infill Villages’. Caxton is not only amongst the most sustainable settlements considered as ‘Infill Villages’ but can also be compared to higher tier settlements such as ‘Group Villages’. Taking all into account, Caxton can be considered a sustainable location for development.

Sustainability is not solely based upon a snapshot in time, and by definition it is considered now and for future generations. The village of Caxton itself could already be deemed a sustainable location for development based on existing access to local facilities and services. The surrounding area is to be the focus of significant and sustained growth and to that end LVA believe the village of Caxton should also be apportioned a level of new housing.

Scott Properties considers that Bassingbourn and Kneesworth should be recognised as a single settlement for the purposes of the hierarchy, owing to their close proximity and functional relationship. Both settlements fall within the Parish of Bassingbourn-cum-Kneesworth, served by the same Parish Council and contained within the Neighbourhood Plan Area. Geographically, there is no physical separation between Bassingbourn and Kneesworth to the north of the Causeway, with the parts of Kneesworth along this route benefitting from close proximity to the services and facilities within Bassingbourn.

Bassingbourn is classified as a Minor Rural Centre within the adopted South Cambridgeshire Local Plan, recognised as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire. Kneesworth is classified as an Infill Village, which are generally the smallest villages in South Cambridgeshire whereby it is often necessary for residents to travel outside the village for most of their daily needs. The hierarchy fails to recognise that the residents of Kneesworth would only have to travel a very short distance to access day-to-day facilities that are located adjacent to the settlement and accessible within a short walking and cycling distance.

In order to recognise the functional relationship and close physical proximity between Bassingbourn and Kneesworth, we consider that these settlements should be recognised as a single settlement within the hierarchy. This approach has been taken in respect of other settlements in District, including Great Shelford & Stapleford and Histon & Impington.

Objection is raised to the Settlement Hierarchy approach set out in the South Cambridgeshire Local Plan. The restriction on housing numbers for smaller settlements, such as group villages which limits development to 8 to 15 homes, reduces the scope for the recycling of underutilised sites and buildings and predicates the amount of development that could be achieved through windfall development. As a result, not being able to utilise such sites will lead to the needless release of undeveloped greenfield land, some of which is Green Belt.

It is therefore recommended that the proposed limit of housing for settlements identified in the hierarchy should be reviewed with a view to increasing the development threshold, and should not be a mandatory requirement but instead serve as a guide, with the relative sustainability of the site/settlement providing a basis for increasing the development threshold of a site. Such an approach would place sustainability at the heart of decision taking and ensure that development opportunities are not needlessly inhibited by a negatively conceived blanket policy approach.

Meldreth is an example of a settlement which will suffer as a result of the Settlement Hierarchy approach advocated. It is classed as a group village, which means that the draft Local Plan imposes a maximum scheme size of 8 dwellings, or 15 dwellings if the site represents the best use of a brownfield site. However, the settlement contains farm buildings such as Bury Farm that are within/contiguous with the settlement and boasts excellent public transport infrastructure and connectivity to major employment. In this regard, the settlement has exceptional access bus services and railway services, which provides access to Cambridge in 17 minutes, or London St Pancras in approx. 60 minutes. Additionally, a large existing commercial site neighbours the settlement which means sustainable living and travel patterns can be enhanced with commensurate housing to align with the jobs and infrastructure that already exist.

Willingham is a Minor Rural Centre, central within the overall hierarchy, but towards the top end of the village categories. Willingham benefits from a large number of services and facilities including a primary school, medical practice, Post Office, shops, pubs, takeaways, library, various social, leisure and recreational facilities, a bus service and close proximity to Longstanton Park and Ride. Despite Willingham being sustainable, no sites are proposed for allocation within the village. Land South of Newington, Willingham would offer the opportunity for a site that benefits from sustainable travel opportunities, in addition to service and facilities within the village.

Cambourne Town Council is supportive of the policy and agrees that Cambourne should be included in The Towns category.

Shepreth Parish Council (SPC) supports the retention of Shepreth as an “Infill” village. Some of the (now rejected) submitted sites would have overwhelmed the village and its infrastructure. It is hoped that any pushback from developers will be resisted.

Agree with identification of Dry Drayton as Group Village and associated scheme size limit of 8 dwellings. Some concern about the rate of growth of Cambourne. Landscape and habitat should be significant factors in the assessment of developments in group villages. OK unless used to push more development into villages.

Representations to the Greater Cambridge Local Plan - The First Proposals Regulation 18 Consultation
West Cambourne,

On Behalf of MCA Developments Ltd November 2021

Contents
1. Introduction 3
2. Vision and Development Strategy 4
3. New Settlements – Cambourne 8

Nichola Traverse-Healy nichola.traverse-healy@turley.co.uk
Client
MCA Developments Ltd

1. Introduction

1.1 These representations are submitted by Turley on behalf of Taylor Wimpey UK Ltd and the Vistry Group (the applicants) who together comprise the consortium MCA Developments Ltd (MCA (herein referred to as MCA), in response to the Greater Cambridge Local Plan – First Proposals Regulation 18 Consultation (January 2020). MCA are the developers behind Cambourne, a maturing new settlement, located within the administrative area of South Cambridgeshire (SCDC) approximately 7 miles to the west of Cambridge. The aim of this document is to assist the Council in formulating their Local Plan.

1.2 We have set out below responses to the questions raised in the Draft Consultation Document in the order in which they appear.

1.3 The remaining part of this document is structured as follows:

• Chapter 2 – Vision and Development Strategy
• Chapter 3 – New Settlements: Cambourne
• Chapter 4 – Conclusion

1.7 MCA would be pleased to discuss any aspect of these representations in more detail if this would be of assistance to the Council and we look forward to engaging positively with the Council and other stakeholders in the ongoing preparation of the emerging Local Plan

2. Vision and Development Strategy

Vision

2.1 The proposed Vision for Greater Cambridge is set out at page 20 of the Draft Local Plan and states that:

“We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

2.2 Whilst MCA supports the Council’s objectives with regards to climate changes and protecting the environment, it is disappointing that the Vision as currently drafted makes no reference to the Oxford-Cambridge Arc.

2.3 The Oxford-Cambridge Arc is an area covering Oxford, Milton Keynes and Cambridge, identified by the Government as a unique opportunity to become an economic asset of international standing. In July the Government held a 12 week consultation which closed on 12 October 2021 seeking views on the vision for the Arc. The consultation document ‘Creating a vision for the Oxford-Cambridge Arc’ (July 2021) confirmed that it is still the Government’s intention to prepare a ‘Spatial Framework’, which will provide a national planning policy framework for the Arc.

2.4 As set out at paragraph 1.1 of the Government’s consultation document the Oxford- Cambridge Arc ‘is a national economic priority area’. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. As advised by the National Infrastructure Commission, without urgent action, a chronic under-supply of homes could jeopardise growth, limit access to labour and put prosperity at risk.

2.5 If the Arc to reach its full potential local authorities will need to plan positively in their areas to deliver the transformational growth required. On this basis we would suggest that the Vision is revised as follows:

“Greater Cambridge is a leading UK and global hub of innovation, which plays a key role in the internally recognised Oxford-Cambridge Arc. We want Greater Cambridge to be a place of great prosperity and innovation where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

Policy S/JH: New Jobs and Homes

2.6 Policy S/JH of the Draft Local Plan proposes to meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year

2.7 For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.

2.8 For Greater Cambridge the housing need using the Standard Method would equate to 1743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario, the modelling predicted that 78,700 jobs would be required over the plan period.

2.9 Whilst MCA is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.

2.10 We would strongly advise the Council to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.

2.11 As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

Policy S/DS: Development Strategy

2.12 At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.

2.13 To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:

• North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.

• Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.

• Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.

• Expansion of Cambourne to around 2,000 new homes; and
• Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.

2.14 MCA strongly supports the proposed expansion of Cambourne for circa 2000 homes, which aligns with the Councils’ objective to provide jobs and homes in close proximity to major public transport routes. As stated page 44 of the Draft Local Plan locating growth at Cambourne takes advantage of the proposed new East West Rail station at Cambourne and the Cambourne to Cambridge Public Transport Scheme being brought forward by the Greater Cambridge Partnership.

2.15 Notwithstanding these proposed new transport links, Cambourne is an established and successful new settlement which benefits from a range of services and facilities, including three primary schools, secondary school, library, health centre, Morrison’s superstore, pub, leisure centre, numerous restaurants and takeaways together with a number of retail uses and professional services within two parades of shops.

2.16 The development of Cambourne West, a fourth linked village will further enhance the range of services and facilities at Cambourne. In 2017 South Cambridge District Council (SCDC) granted planning permission for the development of 2350 homes at Cambourne West including a new retail and community hub, two primary schools and an extension to the existing secondary school.

2.17 Cambourne is one of the largest and most sustainable settlements in Greater Cambridge, which since development commenced in 1998 has continued to make an invaluable contribution to Greater Cambridge’s housing land supply. The settlement is not only well placed in terms of access to major transport corridors and new infrastructure, including

the new rail station as part of East West Rail but benefits from an extensive range of shops, services, facilities and recreational opportunities. For the reasons set out above, Cambourne is considered a logical location to accommodate additional growth to meet the needs of South Cambridgeshire and Cambridge City. The proposed expansion of Cambourne is considered a soundly based strategy, which is justified by the Councils’ supporting evidence base and will deliver sustainable development in accordance with the policies of the NPPF.

Policy S/SH: Settlement Hierarchy

2.18 The purpose of Policy S/SH is group together similar settlements into categories that reflect their scale, characteristics and sustainability. In view of its sustainable credentials MCA strongly supports the Councils decision to reclassify Cambourne from a rural centre to a town.

2.19 As set out at page 49 of the Draft Local Plan:

“Cambourne is a growing centre, with a growing level of services, facilities and transport opportunities. This has been recognised by it now having a town council, and it is considered that this should be recognised in the local plan”

2.20 Cambourne performs far beyond the role of a rural centre and MCA agrees that this should be recognised in the new Local Plan. Given the excellent range of services and facilities in Cambourne and the wider catchment it serves, the Councils’ are considered completely justified in the new Local Plan to include Cambourne in the ‘Towns’ category of the settlement hierarchy.

3. New Settlements – Cambourne

3.1 Policy S/CB: Cambourne of the Draft Local Plan seeks ‘to identify Cambourne as a broad location for longer term strategic scale growth’ and carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’.

3.2 As stated previously in our response to Policy S/DS: Development Strategy, given Cambourne’s position in the settlement hierarchy and proximity to new major public transport schemes, MCA strongly supports the Councils’ decision to identify Cambourne as a broad location for longer term strategic scale growth. Cambourne has been identified as the location for a new railway station as part of the East West Rail scheme to connect Oxford with Cambridge and potentially beyond, along with the Cambourne to Cambridge public transport scheme being brought forward by the Greater Cambridge Partnership. The Draft Local Plan recognises that these schemes ‘provides an opportunity to consider how further development could make the most of these connections, but also make the overall Cambourne area a more sustainable place’.

3.3 MCA is also supportive of the Councils’ decision to carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’. Policy SS8: Cambourne West in the adopted South Cambridgeshire Local Plan (2018) currently requires at part 12 (g) ‘Vehicular access to be provided through an enhanced route through the Business Park, one or more access points from the Caxton Bypass, and via Sheepfold Lane’

3.4 The outline planning application for Cambourne West, approved in 2017, did not include an access through the Business Park, as this land was under the control of a third party. As set out in the Committee Report, relating to the West Cambourne outline planning application, dated 11th January 2017, Officers were satisfied to approve the application without the business park access but on the basis that the ‘opportunity would still exist with any future application for the development of the business park land’. To provide the Council with comfort that the business park access could be delivered in the future, the site wide masterplan submitted by MCA as part of the planning application was designed to facilitate an access. In addition plans were submitted as part of the application, demonstrating how the business park road could be brought up to adoptable standards.

3.5 In May 2021, it was announced that the South Cambridgeshire Investment Partnership (SCIP) a 50:50 partnership between South Cambridgeshire District Council and the Hill Group, would be purchasing the remaining undeveloped land at the Business Park. It is our understanding that it is the intention of SCIP to submit an application for the development of the site to provide 275 homes.

3.6 As set out at paragraph 260 of the Committee Report, relating to the West Cambourne outline planning application, Officers stated that:

“…the council would continue to encourage the delivery of an all vehicle access through the business park due to the benefits through greater connectivity that it would bring for early Cambourne West residents”

3.7 A top priority of the Draft Local Plan is to minimise vehicular movements. It has always been the Councils’ aspiration that walking and cycling links through the business park would be delivered as part of any vehicular connection. This would mean greater permeability between Cambourne and Cambourne West for pedestrians and cyclists. Given that the legal impediments to the delivery of the road no longer exist and for the benefit of Cambourne residents, it should be a requirement in Policy S/CB: Cambourne of the new Local Plan that future planning applications for the development of land at the Business Park should be required to provide an enhanced access through the Business Park to the development at Cambourne West.

3.8 As has been the approach at North West Cambridge, when drafting Policy S/CB: Cambourne for the next stage of the Local Plan, the Councils’ should be seeking to maximise the opportunities for intensifying development within the existing boundary of Cambourne West. The updated policy should enable the development of additional dwellings on the site beyond those identified in the current outline planning permission at Cambourne West, provided through changes to the dwelling mix and appropriate intensification of development areas that have yet to be built. MCA are currently undertaking a detailed review of the site wide masterplan, and will advise in due course the likely increase in dwellings that could be achieved.

3.9 Under Policy SS/8 of the adopted Local Plan any future planning application would need to provide an equivalent quantity of employment land to that lost on the Business Park (8.1ha), to be delivered in the northern part of the Cambourne West site rather than its current location. The outline planning application submitted by MCA and approved by SCDC made for provision 6.25ha of employment space for offices. At the time the outline planning application was being determined, SCDC provided limited justification with regards to the need for this level of employment land at Cambourne West. As set out at paragraphs 208 and 209 of the Officer’s Committee Report dealing with the application:

“The history of Cambourne has shown that the employment and retail units are rarely built on a speculative basis and have only come forward when an occupier has been identified…. the reality is that the majority of employment in Cambourne is outside the business park and can be found in the schools, hotel, retail units etc. There are also a large number of residents who run successful companies out of their homes.”

3.10 Current lettings data from CoStar, the commercial property database, provides a more up to date indication of the role of Cambourne in accommodating demand for office space that arises throughout South Cambridgeshire on an annual basis.

3.11 CoStar has recorded some 1,125 lettings of office space throughout South Cambridgeshire over the last ten years to November 2021, but only 34 – or little more than three lettings per annum, on average – have been in Cambourne1. It has therefore been the location for only 3% of all such lettings in South Cambridgeshire, which is

1 Lettings have been assigned to Cambourne based on postcodes

notable where the town accommodates more than twice as much (7%) of the district’s population2.

3.12 While around three lettings have been recorded annually in Cambourne over the whole decade, this had been slowing even prior to the pandemic as shown by Figure 1 below which tracks the annual average over rolling three year periods. This shows, for instance, that there were more than four transactions per annum on average in the three years to November 2016, which remained relatively stable over the subsequent two years. This was followed, however, by the recording of less than three office lettings per annum over the three years to November 2019, which has fallen even further to the point where there have been only 1.7 lettings per annum over the past three years – equivalent to one office letting every seven months.

Figure 1: Office lettings per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.13 The amount of office space taken up in Cambourne has also been falling, averaging nearly 4,900sqm per annum over the three years to November 2016 before reducing by almost a fifth to a little under 4,000sqm per annum over a similar period to November 2019, predating the pandemic. This has since more than halved to the point where only 1,700sqm of office space has been taken up annually in Cambourne over the last three years, the reduction being far starker than seen across South Cambridgeshire where the rolling average has fallen by only a quarter.

2 ONS (2021) Population estimates, mid-2020. This is the number of residents living in the officially defined Built-up Area (BUA) of Cambourne, divided by the number of people living in South Cambridgeshire (10,544/160,904)


Figure 2: Office space leased per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.14 The above analysis indicates that there has long been relatively limited demand for office space in Cambourne, which appears to have reduced even further during the pandemic. On this basis, we do not consider it justified and appropriate under proposed Policy S/CB to reserve the entire 6.25ha of employment space at Cambourne West for the provision of further office space.

3.15 For the reasons stated above and to be considered sound, MCA request that in drafting Policy S/CB the Council ensures the following:

• There is an requirement as set out under Policy SS/8 of the adopted Local Plan, to provide an enhanced access through Cambourne Business Park to link with the development at Cambourne West;

• The Policy is not overly prescriptive and allows for the intensification of development areas that have yet to be built at Cambourne West; and

• The Policy promotes and allows for the development of residential uses on land previously identified for employment on the Cambourne West Masterplan. This is on the basis of clear evidence demonstrating that the market for employment floorspace in this location is limited.


Turley Office 8 Quy Court Colliers Lane Stow-cum-Quy Cambridge CB25 9AU

T 01223 810990

Barrington Parish Council (BPC) is pleased to have the opportunity to respond to the Greater Cambridge (GCP) Local Plan First Proposals (FP).

1. Overall
1.1. BPC supports the FP development strategy in general terms and supports the principles of plan-led, sustainable development that underpin the FP. BP also supports the general themes of responding to climate change, biodiversity and green spaces, well-being and social inclusion, and great places.

1.2. The wording of many of the proposed policies is incomplete and as always, the devil is in the detail - especially regarding Jobs, Homes and Infrastructure which have the greatest potential impact on the quality of the local environment. BPC is of the view that while these issues are obviously central to any Development Plan, mitigating potentially detrimental effects on rural communities in South Cambridgeshire needs to be managed through effective, carefully worded policies in the Plan.

1.3. BPC particularly welcomes the recognition of and need for reinforcement of the distinctive character of South Cambridgeshire villages.

1.4. However, BPC wishes to make some general strategic and some specific comments as follows.

2. Strategic Issues
2.1. The 2018 Local Plan for South Cambridgeshire is to be succeeded by a Local Plan for a much wider constituency developed by a Partnership for “Greater Cambridge”. This inevitably creates tensions between the interests of the city and those of the surrounding, primarily rural areas. It has to be acknowledged that development pressures in and from the city of Cambridge have significant effects upon the surrounding areas and not all of these are positive and beneficial.

2.2. The First Proposals also seek to support both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail connection - both of which introduce additional development pressures and significant environmental impacts upon South Cambridgeshire.

2.3. The First Proposals are therefore in a key sense no longer for a “Local” Development Plan but in effect have been transformed into a Regional Development Plan where the local interests and concerns of villages such as Barrington lie at the bottom of the hierarchy of interest and control.

2.4. Policy S/DS. BPC has already placed on record and wishes to re-state its fundamental opposition to both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail southern route into Cambridge. BPC has concerns that these may lead to central government-imposed rather than locally-agreed development in South Cambridgeshire which will be highly detrimental to the area.

3. Specific Matters
3.1. Policy S/DS BPC agrees that brownfield development should be prioritised and in locally - agreed not nationally targeted locations. Development “around” the villages is not considered sustainable.

3.2. Policy S/SH. BPC supports the retention of the settlement hierarchy, and the definition of Group Villages should be retained as proposed from the 2018 Local Plan, possibly reinforced with stronger wording to restrict exceptional development of up to 15 dwellings only on brownfield sites.

3.3. Policy S/ JH. BPC has concerns about the notion of “Windfall Development”. Either we have a Development Plan or not – the notion of “unplanned” “windfall” or “opportunistic” development – especially if it were to be determined by officers as opposed to councillors – is not compatible with “plan-led development”. The opening the door to opportunistic applications that run counter to the direction of the Development Plan.

3.4. Policy GP/GB. Similarly, BPC opposes development intrusion into the Green Belt. Development “creep” – even for “nationally significant” development should be resisted.

3.5. Policy S/SRC. BPC is concerned about the definition and implications of the “Rural Southern Cluster” and this requires much more detailed elucidation, explanation and justification.

3.6. Policy WS/CF. BPC believes that Community Healthcare facilities should be prioritised as they have been poorly provided for under the current Plan. Much stronger policy definition is required.

3.7. Policy CC/WE. The FP recognise that availability of water resources is a major issue in Greater Cambridge and that the level of growth has significant constraints with regards to water supply. BPC shares these concerns. Policy should address this issue more comprehensively.

4. The Consultation Process
4.1. BPC is pleased to have the opportunity to engage to the extent that it is able with the FP consultation.

4.2. However, GCP’s consultation on the Local Plan is a convoluted process. The material is voluminous, there are 60 policies and the maps are often difficult to interpret electronically, and this militates against inclusion of the diverse age and socio-economic groups in a rural population. It comes across as an IT driven process designed for an urban sophisticated readership. Further thought needs to be put into reducing the complexity but increasing the inclusion, accessibility, and meaningfulness of this consultation.

OBJECT. The size of individual developments should be subject to limits until the effects of unprecedented growth already in the pipeline can be evaluated in relation to provision of utilities, health care, education, transport, carbon expenditure and climate change. Limits could be specified in line with the Windfall allowance calculated.
It is recommended limits are placed on the individual scheme size of developments in Cambridge, Town and Rural Centre’s until such time as the unprecedented amount of growth in Greater Cambridge already in the pipeline (a 37% increase in homes from those existing in 2020) can be evaluated and the realisation of sustainable solutions eg Water, Electricity , health provision, access to education etc. ; new sustainable public transport infrastructure are known/resolved.
It is recommended Limits could be specified in line with the Windfall allowance calculated. The Vision & Aims of the Local Plan are at risk should there be no limit on the size and scale of schemes brought forward and approved.
An intensified and creative approach to sustainable transport options, use / improvement of existing rail networks/services for example, is recommended to address the CO2 objectives more so, than simply squeezing greater numbers of people into Greater Cambridge. The Aims of the Local Plan: ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here. As the CPIER (2018) report states high levels of economic growth will not be achieved if the good things about Cambridge are lost.

FORM RESPONSE

Vision and development strategy
Section / Policy Your comments
Vision and aims
How much development, and where – general comments Support the approach to contain any development to major clusters.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support Steeple Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support tightly drawn development boundaries are important to reduce encroachment into the countryside and particularly for linear villages protecting their character. Also assists in delivering exception sites.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity so do we have an obligation to consider where we might generate this locally? There should be clear comments on how and where solar PV farms and windfarms are going to be planned
CC/NZ: Net zero carbon new buildings Should not be specific about not connecting a gas pipe to new housing. This might prevent the future distribution of Hydrogen. Should keep this option open
CC/WE: Water efficiency in new developments Absolutely necessary.
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation. Especially managing hard surface run off.
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding.
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedialaction if required.
BG/GI: Green infrastructure Support for recognition of Pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support particularly providing enhanced protection to existing mature trees.
BG/RC: River corridors Support Steeple Morden has an important tributary of the Cam flowing through the Parish – The Rhee. There should also be recognition enhancement and protection for the brooks which emanate from the aquifer spring line and help feed the river system.
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety Support

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character particularly those villages with a predominantly linear form.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support Need to complete Conservation Area Assessments for villages
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support but condition included that if part of Pub is agreed for another use the marketing policy remains.

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Strongly support particularly in the light of grade I peat soil requiring remedial action and the need for increased food security.
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support but would stress the importance of ensuring that structures are sound.
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support and encouraged where there is no conflict with exception site policy.

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.

Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff from hard surfaces to minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but Improvements required to rural public transport and the last mile congestion into Cambridge City.
I/EV: Parking and electric vehicles Support for rural public charging points at community facilities
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support. Should also include disused railway lines with potential for future use.
I/AD: Aviation development Airfields are an important resource and difficult to replace. Local Plan should recognise the need for National Network of General Airfields.Government National Planning Policy Framework section 106.f, to ensure that planning decisions have regard to the importance of the national network of General Aviation airfields is clear. Environmental health concerns should be taken into account when deciding on housing location to avoid new occupants stress, disappointment and possible conflict.
I/EI: Energy infrastructure masterplanning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Supporting documents on which we are consulting
Policy Your comments
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)
Habitats Regulations Assessment

Firstly, the Form To Assist gives a comment column for Vision and Aims.
We have numerous comments to make under this heading but I have not been able to locate this on the online system.
Secondly, the online system asks "Did you raise the matter that is the subject of your representation with the LPA earlier in the process?"
Guilden Morden Parish Council have not been involved earlier in the process. I have therefore clicked "No" but the system will not allow me to proceed further.
The online system allows only 100 words for each comment and to summarise the comments to avoid exceeding 100 words. It would have been helpful if the Form To Assist had stated that.
Vision and development strategy
Section / Policy Your comments
Vision and aims 1.Guilden MordenParish Council has concerns that the increase in population resulting from the additional homes target of 44,000 will have a negative impact on an already struggling traffic, school and healthcare infrastructure.
Specifically on traffic and congestion:
Commuting into and out of Cambridge at peak times already attracts significant congestion and delay for commuters.
This not only effects commuting by car but also bus and the Park&Ride buses as these typically use the same roads as the other commuters and the bus lane network doesn’t extend to where it’s needed.
Links between the train stations and the city centre are also currently inadequate and equally effected by commuter congestion.
The guided busway is too infrequent to be a viable alternative and typically the Park& Ride parking is at capacity leaving commuters with little alternative other than to drive into the city centre.
All of the above describes the current situation which will clearly be significantly worsened by the addition of 44,000 homes by 2041.
2. Is the methodology used in arriving at the figure of 44,000 defendable?

How much development, and where – general comments Support that the proposed developments are to be in major clusters in areas with good public transport.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support. Guilden Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support. Tightly drawn development boundaries are important to reduce encroachment into the countryside.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity. Where might this be generated locally by solar and/or wind?
CC/NZ: Net zero carbon new buildings Support
CC/WE: Water efficiency in new developments Absolutely necessary
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedial action if required
BG/GI: Green infrastructure Support for recognition of pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support
BG/RC: River corridors Support
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Support
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.
Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff fromhard surfacesto minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but improvements required rural public transport and congestion into Cambridge (see comments under Vision and Aims)
I/EV: Parking and electric vehicles Support
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support
I/AD: Aviation development Support
I/EI: Energy infrastructure master planning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

The HBF do not agree with the proposed policy that will limit the size of schemes within minor rural centres, group villages and infill villages. To set an indicative maximum scheme size fails to recognise the full potential of a site in such locations nor the potential benefits of such schemes in ensuring existing services remains sustainable into the long term. As such maximising development opportunities in such communities could have longer term sustainability benefits by ensuring existing services are maintained and, in some circumstances, new services are provided to the benefit of these communities. Rather than place an arbitrary limit on the size of development in these communities we would suggest a more appropriate approach would be to reflect paragraph 124 and 125 of the NPPF to make the most effective use of land whilst taking into account housing needs, market conditions, infrastructure and serves as well as the character of the area. Such an approach would provide the necessary flexibility to maximise delivery whilst also taking into account wider considerations regarding the wider sustainability of such sites.

Introduction

Thakeham Homes Ltd (Thakeham) is pleased to be participating in this consultation and has outlined its position below in response to the consultation on the Greater Cambridge Local Plan – The First Proposals (1st November to 13th December 2021).

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 (MHVR) 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
Section / Policy Your comments
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 support 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 are easily accessible 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 consequence 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 importantly 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.
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.

Climate change
Policy Your comments
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
Policy Your comments
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 Your comments
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.

Thakeham itself 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 Your comments
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 district, 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 off 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 off 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 off identified need.

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.

It is proposed in the Draft Local Plan that the village of Fulbourn remains a Minor Rural Centre rather than being upgraded to a Rural Centre.
Rural Centres are described in the adopted South Cambridgeshire Local Plan as the most sustainable villages of the district and are described as having:
“….good access to a secondary school (either within the village or accessible by good public transport), employment opportunities, a variety of services and facilities and have good public transport services to Cambridge or a market town”
In terms of population, the 2011 Census confirmed the population of Fulbourn to be 4,673.
Fulbourn has a wide range of services and facilities. These are located across the village as a whole. The village has a High Street, where a number of retail outlets and other facilities are grouped, and this is located close to the library, health centre, primary school and St Vigor’s with All Saints Church.
In addition to a functioning High Street, there is also a 24hr Tesco superstore on the edge of the village, which is located approximately 3km from the village centre. This facility is well served by public transport to and from Fulbourn, and can be easily accessed by bicycle. This is a valuable facility for the residents of the village.
In terms of promoting sustainable modes of transport, Fulbourn has excellent bus links and dedicated cycle routes to the city of Cambridge. The Citi 1 and Citi 3 link Fulbourn to the major local employment destinations such as Capitol Park, ARM, Addenbrookes and the city centre. They also provide routes to Cambridge Station, retail destinations such as Tesco’s and Cambridge.
In addition to being within a reasonable distance of a wide range of employment opportunities in Cambridge the village has historically had a positive work population: employment ratio. This includes Fulbourn Hospital and Capital Park, as well as various units throughout the village.
Bottisham Village College provides the secondary education for the residents of Fulbourn. A direct private bus services serves Fulbourn, allowing safe and consistent access to the College.
In conclusion, Fulbourn scores highly on the factors assessed and should not reasonably fall within the category of Minor Rural Centre. Such villages are described as having ‘a lower level of services, facilities and employment than Rural Centres’. The high service provision, high quality public transport and the employment opportunities clearly demonstrates that Fulbourn should be re-classified as a Rural Centre.

It is proposed in the Draft Local Plan that the village of Melbourn remains a Minor Rural Centre rather than being upgraded to a Rural Centre.
Rural Centres are described in the adopted South Cambridgeshire Local Plan as the most sustainable villages of the district and are described as having:
“….good access to a secondary school (either within the village or accessible by good public transport), employment opportunities, a variety of services and facilities and have good public transport services to Cambridge or a market town”
In terms of population, the 2011 Census confirmed the population of Melbourn to be 4,689.
Melbourn has a wide range of services and facilities, including schools at both primary and secondary level, a health centre, a community hub, two garden centres, cafes, restaurants, takeways, pubs and two convenience stores.
In terms of promoting sustainable modes of transport, Melbourn has excellent bus links, with the Intalink 915 providing a direct hourly service to Royston and Cambridge. The village is also within a 30 minute walk/7 minute cycle of Meldreth Train Station, which is on the mainline between Cambridge and London Kings Cross. There is dedicated public footpath linking Melbourn village with the train station. Journeys by train into Cambridge are half hourly and take 16‐18 minutes. Journeys to London’s Kings Cross take approximately 1h 10m.
In addition to being within a reasonable distance of a wide range of employment opportunities in Cambridge the village has historically had a positive work population: employment ratio. This includes the Melbourn Science Park, a growing science and tech cluster, specialising in combined life sciences and engineering.
In conclusion, Melbourn scores highly on the factors assessed and should not reasonably fall within the category of Minor Rural Centre. Such villages are described as having ‘a lower level of services, facilities and employment than Rural Centres’. The high service provision, high quality public transport and the employment opportunities clearly demonstrates that Melbourn should be re-classified as a Rural Centre.

This policy aims to group similar settlements into categories that reflect their scale, characteristics, and sustainability. Gladman support the use of a settlement hierarchy, but in line with previous comments regarding the development strategy, do not agree that schemes in Minor Rural Centres should be limited to 30 dwellings and this would not be in keeping with the national policy imperative that seeks to boost significantly the supply of housing. Additional development should be directed across the hierarchy and to villages to support their vitality and future viability, and larger schemes are capable of delivering more affordable housing and significant benefits to local residents.
The NPPF (2021) is clear that development in rural areas should be supported ‘where it will enhance or maintain the vitality of rural communities.’ The policy direction does not currently identify opportunities for villages to grow and thrive, nor does the settlement hierarchy explicitly consider how development in one village may support services in other nearby villages such as is the case with villages such as Meldreth and Melbourn.