S/RRA: Allocations in the rest of the rural area

This email is sent with the blessing of Whaddon Parish council. Both my chairman and I have already commented on the proposals, but we would like to add this additional comment into the mixing pot by email as the consultation is ending today.

I have tried to upload this on the detailed comments page, but I have been unable to find a suitable place for a short response. Hence I am sending this by email as the deadline for consultation is today.

----

[Some of us have already replied on the online consultation system but we can find no easy way of sending you a short comment as the following:]

Whaddon PC strongly supports the Local Plan proposals insofar as they affect Whaddon. We would like to ensure that is clear.

We would also like to add our support to the more detailed comments sent to you by our neighbours, Bassingbourn Parish Council. We completely agree with them on their comments on the areas classified red; however, we also share their concerns on the selection of sites in the Amber category. Bassingbourn have requested that you consider reclassifying the sites 40073, 40164, 40216 and 40463.

We are in complete agreement with what Bassingbourn have had to say about this and we support the request to reclassify 40073, 40164, 40216 and 40463 from amber to red.

In considering site 47529, it is necessary to check that all surface water drains to the west, away from Highfields. If it were to be allowed to drain to the east, it would run into the Highfields Road drainage system, and there would be a high risk that it would cause flooding in Highfields.

Please put this comment where it will be considered with this potential site.

6.0 POLICY S/RRA: SITE ALLOCATIONS IN THE REST OF THE RURAL AREA

6.1 In terms of residential development, there are extremely limited emerging allocations within the villages of Greater Cambridgeshire. Discounting those sites that already benefit from planning permission, development in villages in the ‘Rest of the Rural Area’ is restricted to the following: • S/RRA/ML – The Moor, Moor Lane, Melbourn – 20 dwellings • S/RRA/H – Land at Highfields (phase 2) Caldecote – 64 dwellings • S/RRA/MF – Land at Mansel Farm, Station Road, Oakington – 20 dwellings • S/RRA/CR – Land to the West of Cambridge Road, Melbourn – 120 dwellings

6.2 Martin Grant Homes supports the opportunity for growth in villages. Villages are often located in highly sustainable locations, and provide significant opportunities at appropriate scales, to meet objectively assessed housing and employment needs. This brings significant benefits to the future vitality of villages, especially those such as Coton which have seen very limited growth in recent years. A failure to consider the villages as appropriate locations for growth could lead to a stagnation of these villages, and will locate development in less sustainable locations.

6.3 Village development will assist in meeting immediate delivery rates, which will benefit if larger allocations are delayed coming forward. No sites are allocated for development within Coton, despite its proximity to west Cambridge and the investment in infrastructure now (Comberton Greenway) and in the future (Cambourne to Cambridge Busway). This represents a missed opportunity to provide truly sustainable development in a village location.

6.4 Martin Grant Homes is keen to understand how the emerging sites have been chosen and as such have sought to compare these sites to Silverdale Close. A study has therefore been undertaken to compare the village allocations that form emerging allocations within the Local Plan. This study also includes the following residential sites allocated within emerging policy S/RSC: • S/RSC/HW - Land between Hinton Way and Mingle Lane, Great Shelford – 100 dwellings • S/RSC/MF – Land at Maarnford Farm, Hunts Road, Duxford - 60 dwellings

6.5 The following table shows a summary of the assessment proformas undertaken by the Council and shows the results for each of the sites. It shows that when compared to the emerging allocations, the Site has an equal if not better assessment result: Site Suitable Available Achievable Silverdale Close, Coton. Amended to ‘amber’ as described in chapter 3 above The Moor, Moor Lane, Melbourn Land at Highfield (phase 2) Caldecote Land at Mansel Farm, Station Rd, Oakington Landscape and Townscape & Historic Environment impacts Land W of Cambridge Rd, Melbourn Land between Hinton Way & Mingle Lane, Great Shelford Land at Maarnford Farm, Hunts Rd, Duxford

6.6 It has been noted within chapter 3 of these representations that the assessment of suitability for the Silverdale Close site is incorrect. Necessary rights of way are available into the Site, and as such, the ‘red’ assessment is shown in the table above as the more appropriate ‘amber’ assessment. The Coton site would therefore score no worse than any of the emerging allocations.

6.7 The Oakington site also has a ‘red’ assessment for suitability and this is based on landscape and townscape impacts, and historic environment impacts. On the former, the proforma states: “The proposed development of 102 dwellings (approximately 27 dph) would produce a large, dense area of development on the village edge that would be highly visible in the landscape at odds with the linear form and lower existing housing densities. It would also significantly reduce the separation between Oakington and Westwick.”

6.8 It is acknowledged that this assessment is based on a larger area for a larger quantum of development. However, the points regarding the linear form of development and coalescence remain pertinent to the smaller scheme. On the historic environment, the proforma states “Within 100m of a Conservation Area. Would cause significant harm to Conservation Area. Development of the site would cause substantial harm or severe or significant “Less than substantial harm” to a designated heritage asset or the setting of a designated heritage asset which cannot be reasonably mitigated.”

6.9 The reduced area to the emerging Oakington allocation is situated directly adjacent to the Conservation, and the relationship of a reduced scheme would not be altered. As a result, the text above from the proforma remains relevant and there remains no mitigation proposal to ensure a satisfactory relationship to the Conservation Area. No evidence is put forward by the Council to demonstrate that a reduced area mitigates this harm.

6.10 Both the Oakington and Great Shelford sites are also located within the Cambridge Green Belt. A study of the Green Belt Assessment has also taken place to understand the potential harm to the purposes of the Green Belt. The Purposes are described as follows: • Cambridge Purpose 1 (to preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre) – for land to contribute to this purpose it needs to be located in the immediate vicinity of Cambridge • Cambridge Purpose 2 (to maintain and enhance the quality of Cambridge’s setting) - a two-element approach was taken considering: 1) the extent to which land constitutes countryside (that is to say has a rural character) based on its usage and distinction from an inset settlement; and 2) the extent to which land forms or contains other features or aspects that contribute to the quality of Cambridge’s setting. Cambridge Purpose 3 (to prevent communities in the environs of Cambridge from merging into one another and with the city) – an analysis was undertaken of the distribution of villages in and around the Green Belt and the physical features that separate and/or connect them from each other or from Cambridge, in order to determine the fragility of each settlement gap

6.11 The scale of Green Belt harm is listed as low, moderate, moderate-high, high, and very high. The table below summarises the Green Belt assessments for Coton, Oakington and Great Shelford.

SEE TABLE IN ATTCHED DOCUMENT

6.12 The table above therefore confirms that the Site would result in a lower impact to the Green Belt purposes than the two Green Belt sites that form emerging allocations. To further justify this point, a Green Belt Assessment undertaken by EDP (see Appendix 2) relating to the Site only (rather than the wider parcel) concludes the Site to have an overall ‘Low’ rating when assessed against the five purposes of the Green Belt noted in the NPPF.

6.13 No justification is put forward by the Council as to why these two sites are put forward for Green Belt release ahead of sites such as Silverdale Close, Coton, which score more successfully in terms of reduced Green Belt impact. Topic Paper 1 suggests that the proximity to the bus stop for 20 dwellings would provide the exceptional circumstances to provide Green Belt release. The Topic Paper does not reference the landscape and historic environment harm identified in the site proforma. However, the benefits of 20 dwellings in this location is not considered to overcome the moderate/high harm to the Green Belt. Green Belt release at Great Shelford appears to be based entirely on proximity to the railway station, despite moderate/high Green Belt harm being identified.

6.14 The result of these two assessments is that the Site is more appropriate for development and Green Belt release than both the Mansel Farm, Oakington and the Hinton Way/Mingle Lane site at Great Shelford.

6.15 The other sites are located outside of the Green Belt. However, their distance away from Cambridge is a disadvantage. The addition of a further 140 dwellings in Melbourn will increase pressure on the A10 and would likely see a reliance on the motor car. This would also be the case for the Duxford and Caldecote allocations, villages with limited services and facilities. Coton however benefits from the Comberton Greenway and will be on the proposed Busway route between Cambridge and Cambourne. It also benefits from proximity to Cambridge, ensuring that it provides valuable alternatives to the motor car for future residents.

6.16 The Coton site should therefore be considered more favourable and allocated for 77 dwellings, which would mean less Green Belt release or countryside development at more inappropriate sites.

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

6.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. CALA Homes are responsible for the promotion of Land of Water Lane, Melbourn, and have a track record of delivering high quality housing developments, which provide a mix of dwellings to meet Objectively Assessed Housing Needs. CALA Homes are fully committed, to engagement with the GCSPS and Melbourn Parish Council regarding the mix and type of housing to be delivered on Land off Water Lane, Melbourn. The site also has the potential to provide open space to serve the new and wider local community and would trigger contributions towards improvements towards local facilities.

7. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?

7.1 Yes, Land off Water Lane, Melbourn should be allocated for development and would be a sound allocation as part of the emerging Local Plan. The Land off Water Lane, Melbourn site was promoted originally at Call for Sites stage. We have also demonstrated with the agreement of Cambridgeshire County Highways that access from the site to the adopted highway can be achieved without any significant impact.

7.2 To the north of the Site, Water Lane gives access to increasingly recent housing development as it runs south from its junction with Melbourn High Street. From the High Street until its junction with Greengage Road, Water Lane is a metalled road bounded by a footway on one or both sides of the carriageway. South of its junction with Greengage Road, the lane changes in character to a rough surfaced track bounded on both sides by mature hedgerows.

7.3 CALA’s access arrangements to serve the proposed development is to provide vehicular access via Water Lane, in effect extending the road southwards along the lane from the junction with Greengage Road to a point of access to the development formed at an appropriate point along the eastern boundary of the site.

7.4 While the lane is classified as BOAT 15 (Byway Open to All Traffic), it is highway maintainable at the public expense and capable of being upgraded to an appropriate standard for its subsequent adoption by the highway authority to serve CALA’s housing development.

7.5 The fact that BOAT 15 is presently only roughly surfaced and very lightly maintained, with the boundary hedges being allowed to encroach into the highway, is simply indicative of the fact that it has hitherto been maintained to a standard that is commensurate with its present use by the public. Its current condition does not preclude Cambridgeshire County Council’s from entering into a section 278 agreement to upgrade the lane in order to serve the site. Therefore the principle of providing a safe highway connection to the adopted highway on Water Lane is acceptable for the quantum of development proposed (circa 100 dwellings).

7.6 The Technical Note (2021) includes the results of a speed survey carried out in November 2021, approximately 75 metres north of the access into Greengage Rise. 12 The results concluded an average north bound speed of 24mph and a speed of 25mph for south bound. As a result, based upon Manuel for Streets, the required visibility splays are 31.4 metres to the south for north bound traffic, and 33 metres to the north for south bound traffic. These visibility splays can be achieved within the highway land as shown in Appendix F of the note.

7.7 In terms of pedestrian access, it was originally proposed in the TPA design that a 2 metre wide footpath could be provided on the eastern side of Water Lane with a 5.5 metre wide carriageway. However, upon reflecting on the Highway Authority’s feedback, where advised it would be preferable for the pedestrian access to be created on the western side to avoid pedestrians having to cross two carriageways to connect to the existing footpath, the design was amended.

7.8 A 2 metre wide footpath along the western side of the site within the highway boundary can be achieved and provision for two crossing points has been included. Therefore, safe pedestrian access can be provided from the site into the village.

7.9 In summary, as the principle of a safe and adoptable access can be provided from the site to the adopted highway including a 2 metre wide pedestrian link, this should be sufficient to overcoming the access concern with this site. The next stage would involve preparing detailed concept plans in agreement with GCSPS and the Highways Authority before preparing a detailed application. Beyond the application process, further work would be required to iron out the highways details through a S278 agreement. Developer funding through an obligation in the S106 could be used to make a contribution towards the highway improvements. Response to HELAA

7.10 The key concern raised in the HELAA towards the site’s allocation was with site access and not being able to connect to the adopted highway. It has been clear demonstrated through in the Technical Note provided by Peter Brett that a connection to the adopted highway on Water Lane.

7.11 The Technical Note includes a plan showing how a 5.5 metre wide (with 1.8 m footpaths either side) access can be provided including visibility splays to link the site to the adoptable highway on Water Lane. The proposed access, its design and the quantum of development off the proposed site was also considered acceptable to the Highways Authority during our initial pre-application discussions. The Technical Note includes correspondence from the Highways Authority confirming this.

7.12 Therefore, unless officers are able to demonstrate otherwise, the site allocation has resolved the key concern with site access and as such the site is suitable for development.

7.13 A detailed review of the HELAA assessment in respect of the Land off Water Lane, Melbourn site is set out below (IN ATTACHED DOCUMENT).

The supporting text for policies S/RRA and S/RRP states that the GCSPS wants rural villages to thrive and sustain their local services. However, this unfortunately has not been reflected within policy S/RRA or Policy S/RRP, which proposes a very limited number of allocations. In addition, the vast majority villages have had no growth allocated to them at all, which will not assist in thriving or sustaining rural services, nor meet local housing need.
For reasons outlined above within section 3 we consider that the strategy needs to be revised, to include appropriate distribution of growth in the villages. In particular, this additional growth should be focused on sustainable villages, such as Orwell, which benefit from a range of services and are located outside of the Cambridge Green Belt.
The proposed strategy for growth is considered to be over reliant on a few large sites, with which there are associated risks in relation to delivery. The larger sites are particularly complicated in of the infrastructure requirements, associated with the early stages of delivery. As required by the NPPF 2021, a more balanced approach is urged, which spreads growth more evenly, reducing risk, providing choice and competition for market land, and providing more homes where they are needed.
It is worth noting that recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in the local plan being withdrawn.
Accounting for the recent decisions on the St Albans and Uttlesford Local Plans, it is unclear why the GCSPS appear to be adopting a similar approach. The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.
It is important that a range of housing, jobs and facilities are provided within villages as part of new allocations to allow them to thrive and remain vibrant. Endurance Estates are responsible for the promotion of Land Rear of Fisher’s Lane, Orwell and have a track record of promoting high quality housing developments and setting clear parameters for future housebuilders. Endurance Estates are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Orwell Parish Council regarding the mix and type of housing to be delivered on Land Rear of Fisher’s Lane, Orwell. The proposals also include the provision for the delivery of an area of public open space.

QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?
It is acknowledged that the proposed strategy focuses on locating new development in and around Cambridge City, growing existing new settlements and a small degree in the rural southern clusters. An extremely small number of small to medium sized allocations have been identified with very little new growth proposed in rural communities. This is likely to result in the proposed growth having little impact on housing affordability.
It is worth noting that recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in the local plan being withdrawn.
As set out above, the current approach to allocating only a very limited number of larger sites is not considered to be sound in its current form. In particular, it is considered that additional growth should be provided within the most sustainable villages, such as Girton.
It is considered that the provision for increasing the range of sites modestly to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and securing affordable housing more immediately. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).
It is not clear why the Shared Planning Service have deviated from a clear recommendation provided by the Planning Inspectorate.
However, it is also important to acknowledge the employment sites/areas in Girton which will benefit from increased housing provision. The additional housing will allow people to live closer to work thus reducing car travel and increase employment opportunities. Additional housing would also contribute towards the local economy through spending on local provisions.

This representation has been prepared by Strutt & Parker on behalf of NIAB Trust to support the promotion of land to the East of Redgate Road, Girton as part of the Greater Cambridge First Proposals Consultation 2021.
In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA), which provided an initial assessment of the sites put forward for consideration for allocation as part of the Call for Sites consultations within Greater Cambridge.
This representation provides a response to the ‘First Proposals’ Preferred Options Consultation and has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Proforma for the site.
The HELAA excludes the land East of Redgate Road site from allocation primarily on the basis of landscape issues, notably that the proposed development would impact the rural character of the surrounding landscape.
The site covers an area of approximately 0.94ha and is able to accommodate 28 dwellings, associated access and landscaping. Additionally, there is an opportunity to provide a new pedestrian/cycleway link over the existing A14 crossover. This new link would provide a sustainable transport link which could even reduce overall pressure on the Strategic Road Network. It is noted that the NIAB Trust has also put forward two other sites at Park Farm (Villa Road and Land West of South Road).
It is considered that several of the assessment criteria, should be re-categorised. It has been demonstrated in the supporting information provided that the allocation of this site would not have a significant adverse impact and should be considered as a suitable, achievable and deliverable site for housing and should therefore be put forward for allocation in the emerging Local Plan.
In support of this report, the following document has been prepared;
• Prospective Site Feasibility Study, produced by pHp architects.

QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?
It is important that a range of housing, jobs and facilities are provided within villages as part of new allocations to allow them to thrive and remain vibrant. NIAB Trust are responsible for the promotion of the land East of Redgate Road, Girton, and have a track record of delivering high quality developments. NIAB Trust are fully committed, to engagement with the GCSPS and Girton Parish Council regarding the mix and type of housing to be delivered on land East of Redgate Road, Girton. The site also has the potential to provide open space to serve the new and wider local community and would trigger contributions towards improvements towards local facilities.

QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?
Yes, Land East of Redgate Road, Girton should be allocated for development and would be a sound allocation as part of the emerging Local Plan. The Land East of Redgate Road, Girton site was promoted originally at Call for Sites stage. We have also demonstrated that the site could be delivered without any adverse impacts on landscape.

QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?
Growth should be focused in villages, such as Histon & Impington, which benefit from having an established employment areas and excellent links to public transport. Histon & Impington is one of 5 Rural Centres which should be the focus of housing and employment growth.
It is considered very important that the Local Plan makes provision for a proportion of growth to be delivered from villages such as Histon & Impington to avoid them becoming dormitory villages where residents have to travel into Cambridge or further afield for work and leisure. It is therefore considered that additional growth should be provided within the most sustainable villages, such as Histon & Impington.
The allocation of the Villa Road site would provide an economic boost to the local area which would enable existing services and facilities to remain. The site is also located within close proximity to existing housing which the employment opportunity would be attractive to.

QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?
It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. NIAB Trust is responsible for the promotion of the Villa Road, Impington site, and have a track record of delivering high quality developments in Cambridge. NIAB are fully committed, to engagement with the GCSPS and Parish Council regarding the potential allocation of employment uses to be delivered on the Villa Road site.
The Villa Road site is located adjacent to an established employment area and within close proximity to local facilities and services in the village. It therefore essential to the local economy that there is space to cater for and attract the small to medium size firms to the area by providing an attractive location, close to sustainable transport links. The Villa Road site achieves both these objectives. The feasibility study demonstrates how the site could be laid out to respond to its context without impacting the uses on each of the site’s boundaries.
It is important that the GCSPS growth strategy includes provision that caters for all needs and requirements. The Villa Road site is located adjacent to an established employment base which is vital to the local economy and so should be the focus of a new allocation to allow some expansion. The site could also provide much-needed lab space in the Cambridge area. Therefore, it is considered that the Villa Road site should be allocated for B2 and E use class employment uses in the emerging Greater Cambridge Local Plan as it meets the objectives of the economic growth strategy.

QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?
Growth should be focused in villages, such as Impington, which benefit from having a range of services and sustainable transport links to Cambridge City Centre. As stated above, Histon and Impington are identified in the current South Cambridgeshire Local Plan as a Rural Centre (Policy S/8) and are described as ‘the largest, most sustainable villages of the District.’
It is considered very important that the Local Plan makes provision for a proportion of growth to be delivered from villages. As set out above, the current approach to allocating only a very limited number of larger sites is not considered to be sound in its current form. In particular, it is considered that additional growth should be provided within the most sustainable villages, such as Impington.
It is considered that the provision for increasing the range of sites modestly to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and securing affordable housing more immediately. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).
It is not clear why the Shared Planning Service have deviated from a clear recommendation provided by the Planning Inspectorate.
However, it is also important to acknowledge the employment sites/areas in Impington which will benefit from increased housing provision. The additional housing will allow people to live closer to work thus reducing car travel and increase employment opportunities. Additional housing would also contribute towards the local economy through spending on local provisions.

QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?
It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. NIAB Trust are fully committed, to engagement with the GCSPS and Histon & Impington Parish Council regarding the mix and type of housing to be delivered on Land West of South Road, Impington. The site also has the potential to provide open space to serve the new and wider local community and would trigger contributions towards improvements towards local facilities

S/RRA/SAS
Support Policy requirement to ensure that strong landscaping is provided to help the site fit into the surrounding rural countryside character.

Notwithstanding our comment above, whilst this is a good location for a regional distribution centre it cannot meet the aspiration that “last mile delivery” in Cambridge can be carried out by sustainable modes of transport (smaller electric vehicles, cargo bikes, etc). This would not be possible from this location.

S/RRA/OHD
Support policy requirement to ensure enhanced landscaping on its open boundaries and avoidance of any impact on the settings of the Grade 1 listed church and conservation area.

The previous spatial options considered and consulted upon included a ‘Dispersal: Villages’ option which sought to spread new homes and jobs out to the villages surrounding Cambridge. The Sustainability Appraisal indicated that the Dispersal:Villages spatial option performed relatively well against the various SA Objectives, including the same as the Preferred Option for a number of objectives (SA objectives 1, 3, 9, 10 and 14).

In addition, the Development Strategy Topic Paper indicates that the Dispersal: Villages spatial option was broadly supported by the public via the response to the First Conversation consultation, where it was the fourth most popular location. As set out in the Development Strategy Topic Paper, further consultation undertaken by the Councils also noted the opportunities associated with growth to existing villages include:
• The benefits of development for sustaining villages and schools and enhancing amenities including shops, healthcare provision and community facilities; and
• The need to provide affordable homes suitable for elderly and younger residents to continue living in villages.

The development of land at Boxworth End, Swavesey that is being promoted by Axis could deliver on both of these opportunities. The development would deliver c. 70 high quality market and affordable dwellings, including a mix of smaller and larger homes to suit a range of occupiers, from first time buyers and young families to older residents and those looking to downsize. Development in the location proposed, on the edge of Swavesey village, would also provide an additional population that would help to sustain existing local services and facilities and that would be sustainably located to promote the use of sustainable and active travel methods to access these amenities. Unlike all the other land being promoted in Swavesey, this site comprises a contained agricultural field that is already bound by existing development on three sides meaning that any further development forms a natural and small extension to the village boundary, and would not strictly result in further encroachment into open countryside. The majority of the site comprises open grazing land which is generally of limited ecological value. Features of ecological value, such as the existing pond and woodland will be retained and enhanced. In terms of the preferred growth strategy set out in the First Proposals Plan, the Councilshave proceeded with a blended strategy, considered to “meet a variety of needs and respond
to the opportunities provided by the sources of land supply”. The Councils propose to focus
a small number of new sites and allocations principally:
• within the Cambridge urban area;
• edge of Cambridge, outside of Green Belt;
• edge of Cambridge, Green Belt;
• new settlements;
• some development in the defined ‘Rural Southern Cluster’ (between the M11 and
the A1307); and
• limited development in the ‘Rest of the Rural Area’.

The land being promoted by Axis, comprising land east of Boxworth End, Swavesey, falls within the ‘Rest of Rural Area’ as defined by the Council. This follows the Dispersal: Villages option previously considered.
Our client’s site is not currently allocated for development in the consultation document.

However, the defined wider ‘Rest of Rural Area’, under Policy S/RRA, does comprise the allocation of a small number of new sites for housing and employment at villages that have good public transport access. This includes two new employment allocations proposed within close proximity of Swavesey village including land at Buckingway Business Park (Site BBP) and land to the south of A14 Services (Site SAS), both allocated to provide new
industrial and warehousing use. This provides direct employment opportunity for Swavesey
village, within easy commuting distance on foot, by bike or by bus.
Under Policy S/RRA there are only four sites allocated to provide new housing:
• Moor Lane, Melbourn – capacity for 20 homes.
• Land at Highfields – capacity for 64 homes, based on lapsed planning permission
so some uncertainty with regards to deliverability.
• Mansel Farm – capacity for 20 homes. The site is located in the green belt but in close
proximity to Cambridgeshire Guided Busway stop which provides the exceptional
circumstances for the sites release.
• Land west of Cambridge Road, Melbourn – capacity to provide 2.5ha employment land, albeit the deliverability of the employment site is yet to be confirmed, as well as capacity for 120 homes within a minor rural centre.
In total, these allocations provide for only 224 dwellings during the plan period. This equates to 2% of the additional housing need (11,640 dwellings) identified in the Plan.

We support that the ‘Dispersal: Villages’ option and the allocation of sustainable sites within or on the edge of villages and adjoining the settlement boundaries of villages within the rest of the rural area should form part of the overall development strategy. As above, we consider that the Plan needs to provide greater flexibility and resilience in its housing allocations, to ensure the Councils can meet the identified housing need at all stages of the plan period. It is therefore appropriate to allocate further small-medium size sites in sustainable locations to ensure consistent delivery across the plan period by not concentrating all development in a specific area or an over reliance on large strategic sites.
The allocation of land east of Boxworth Road comprises an appropriate and sustainable approach, noting the ability of the site to connect to existing public transport and active travel routes, make use of existing services and employment opportunities in and around Swavesey minor rural centre and provide a mix of housing for the local market. This approach is supported under Paragraph 79 of the NPPF, which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services.

Paragraph 69 of the NPPF acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that these can often be built-out relatively quickly.

We also note the recommendations of the report prepared by Lichfields, on behalf of the Land Promoters and Developers Federation and the Home Builders Federation – ‘Feeding GCLP First Proposals Plan – Promotion of Land at Boxworth End, Swavesey

the Pipeline: Assessing how many permissions are needed for housebuilders to increase the supply of homes’ (November 2021). The report seeks to explore how the delivery target for new homes (300,000 net additional homes per annum across England) could be achieved at a national level, including the important role that implementable planning permissions on medium to large sites of 50-250+ homes can play in order to meet the targets overall. The report concludes:
“To meet ambitions for 300,000 net additional homes per annum, the country will need to increase delivery by 59,200 homes per annum. This in turn illustratively necessitates between 474 to 1,385 additional implementable planning permissions on medium to large sites (50-250+ homes) making their way into the housebuilding sector”.
“This represents each district in England granting planning permission for the following,
over and above what they usually would:
a) 4-5 additional and new medium size sites each year or 4-5 additional and new large size sites which will deliver over the next five or more years; or
b) One or two additional and new medium size sites each year or one or two additional and new large size sites which will deliver over the next five or more years plus 12 or 13 new smaller sites each year”.

It is therefore considered that small and medium sized sites can make a significant contribution towards the housing need in Greater Cambridge during the plan period, and can help to fill the ‘gaps’ in the housing trajectory where housing provision falls short of the identified need and 10% buffer.

4.0 Policy S/RRA – Land adjoining 107 Boxworth End,
Swavesey
DETAILED COMMENTS ON HELAA ASSESSMENT IN ATTACHED DOCUMENT

The following allocations should be added:
1) Land North Of 26 - 46 Elbourn Way Bassingbourn (which is currently the subject of planning application 21/00543/OUT) should be allocated for 33 dwellings as part of this policy. The planning application has demonstrated that there are to technical grounds on which the development could not take place and the development would be capable of delivering appropriate mitigation through landscaping design. The development would also provide biodiversity and open space benefits to the village.
Please refer to the planning application documents submitted for application 21/00543/OUT and the relevant consultation responses thereto.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.
2) Land west of Oakington Road, Girton (c. 2.83 hectares) should be allocated for the development of c.40 dwellings together with associated public open space. The documents attached demonstrate that the development would be acceptable in planning terms and the land is available immediately for development.
Supporting documents are enclosed which relate to flood risk and Green Belt/visual impacts from the development of the site. A masterplan is also included. This information was submitted with the Call for Sites evidence.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.
3) Land at and to the rear of 30 and 32 New Road, Over (which is currently the subject of a pending appeal - Council ref: 20/03254/OUT is suitable for an allocation of 44 new homes plus public open space. The planning application has demonstrated that there are to technical grounds on which the development could not take place and the development would be capable of delivering appropriate mitigation through landscaping design. The development would also provide biodiversity and open space benefits to the village.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.

The following allocations should be added:
1) Land North Of 26 - 46 Elbourn Way Bassingbourn (which is currently the subject of planning application 21/00543/OUT) should be allocated for 33 dwellings as part of this policy. The planning application has demonstrated that there are to technical grounds on which the development could not take place and the development would be capable of delivering appropriate mitigation through landscaping design. The development would also provide biodiversity and open space benefits to the village.
Please refer to the planning application documents submitted for application 21/00543/OUT and the relevant consultation responses thereto.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.
2) Land west of Oakington Road, Girton (c. 2.83 hectares) should be allocated for the development of c.40 dwellings together with associated public open space. The documents attached demonstrate that the development would be acceptable in planning terms and the land is available immediately for development.
Supporting documents are enclosed which relate to flood risk and Green Belt/visual impacts from the development of the site. A masterplan is also included. This information was submitted with the Call for Sites evidence.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.
3) Land at and to the rear of 30 and 32 New Road, Over (which is currently the subject of a pending appeal - Council ref: 20/03254/OUT is suitable for an allocation of 44 new homes plus public open space. The planning application has demonstrated that there are to technical grounds on which the development could not take place and the development would be capable of delivering appropriate mitigation through landscaping design. The development would also provide biodiversity and open space benefits to the village.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.

1. These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2. Our client is promoting two parcels of land for residential development at Orwell, South Cambridgeshire. The sites were both previously promoted through the March 2019 and February 2020 consultation stages associated with the preparation of the GCLP. The two sites are referenced in the HELAA as follows: Land to the north east of Hurdleditch Road, Orwell (Ref: 40383) and Land to the south west of Hurdleditch Road, Orwell (Ref: 40378).

3. Our client welcomes the publication of the HELAA review which appraises the development potential of the site. However, our client has noted a number of specific technical flaws in the published appraisals which should be remedied as the GCLP preparation continues.

4. As set out in our previous representations masterplanning and technical work has been prepared to support the promotion of both sites for residential development. This work very much remains valid and robust. At this time, we are now also able to provide further technical evidence to support the promotion of the Site 40383. Please find attached to these representations the following documents:

a. Transport – Technical Note (Cannon Consulting Engineers)
b. Flood Risk Assessment (Cannon Consulting Engineers)
c. Preliminary Ecological Assessment (James Blake Associates)

5. In light of our review of the HELAA appraisal and our client’s site specific technical work we attach as a separate sheet a schedule of the HELAA inaccuracies and recommended amendments.

6. This set of representations has demonstrated that the proposed GCLP Development Strategy is flawed in its approach to supporting economic growth, providing a robust housing supply and supporting the long-term vitality of established sustainable rural settlements.

(See attachment)

7. In reviewing and amending the GLCP’s overall housing need requirement and development strategy it is strongly recommended that our client’s sites are allocated for residential development. Both of our client’s site are suitable and deliverable with only very limited development constraints (which can be overcome through planning conditions and careful design). The sites are located at a settlement which has been found to be sustainable location for residential development by a Planning Inspector at Appeal in 2017.

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable.

The Greater Cambridge area includes many large villages (currently classified as Rural Centres, Minor Rural Centres and Group Villages) which have train stations, guided busway routes, rapid bus connections and greenway cycle lanes with link to employment centres and Cambridge city centre. They are accessible to a variety of services and facilities by realistic alternatives to the car. Further, these villages contain a variety of services and facilities which would be supported by new residents.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for a significant number of affordable homes in many of the District’s villages. This identified need would not be met without allocations in these villages, which would include housing and affordable housing.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

It is requested that the development strategy for the rest of the rural area includes additional allocations in the following locations:

Glebe Farm, Twenty Pence Road, Cottenham Glebe Fen Farm
• Site area of 6.8 Ha
• Capacity of approx. 150 dwellings, including affordable housing and self/custom build
• Provision of significant new open space, including a buffer to the church yard
• Retain key views of the Church and Conservation Area and minimise harm to heritage assets

Land west of Cottenham Road, Histon (Buxhall Farm)
• Site area of 4.8 Ha
• Capacity of approx. 40 dwellings, including affordable housing, to the front of the site along Cottenham Road
• Provision of new open space and potentially community land to the rear, with biodiversity enhancements and strategic landscaping

Land adjacent to Histon School, Glebe Way, Histon
• Site area of 2.32 Ha
• Capacity of approx. 60 dwellings, including affordable housing and self/custom build
• Provision of new open space and landscaping, including links to Northern Buxhall Farm local green space

Land to the north of Cardyke Road, Waterbeach Cardyke Road
• Site area of 2 Ha
• Capacity of approx. 40 dwellings, including affordable housing and self/custom build
• Pedestrian and cycle links to Cambridge Road and Cardyke Road

Belsar Farm, Willingham
• Site area of 0.88 Ha
• Capacity of approx. 26 dwellings, including affordable housing
• Pedestrian and cycle links to neighbouring development and Sponge Drove

Tostock Farm, Cambridge Road, Melbourn
• Site area of 13.01 Ha
• Capacity for approx. 150 dwellings, including affordable housing and self/custom build
• Significant new open space and strategic landscaping
• New pedestrian links to Cambridge Road and Portway
• Enhancement of existing agricultural access to Cambridge Road

Herod’s Farm, High Street, Foxton
• Site area of 5 Ha
• Capacity of approx. 90 dwellings, including affordable housing and self/custom build
• Provide open space and green infrastructure, including enhanced biodiversity and landscape buffer as requested by Neighbourhood Plan
• Upgrade existing vehicular access on High Street and provide new links to Rowlands Close

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable.

The Greater Cambridge area includes many large villages (currently classified as Rural Centres, Minor Rural Centres and Group Villages) which have train stations, guided busway routes, rapid bus connections and greenway cycle lanes with link to employment centres and Cambridge city centre. They are accessible to a variety of services and facilities by realistic alternatives to the car. Further, these villages contain a variety of services and facilities which would be supported by new residents.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for a significant number of affordable homes in many of the District’s villages. This identified need would not be met without allocations in these villages, which would include housing and affordable housing.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

It is requested that the development strategy for the rest of the rural area includes additional allocations in the following locations:

Glebe Farm, Twenty Pence Road, Cottenham Glebe Fen Farm
• Site area of 6.8 Ha
• Capacity of approx. 150 dwellings, including affordable housing and self/custom build
• Provision of significant new open space, including a buffer to the church yard
• Retain key views of the Church and Conservation Area and minimise harm to heritage assets

Land west of Cottenham Road, Histon (Buxhall Farm)
• Site area of 4.8 Ha
• Capacity of approx. 40 dwellings, including affordable housing, to the front of the site along Cottenham Road
• Provision of new open space and potentially community land to the rear, with biodiversity enhancements and strategic landscaping

Land adjacent to Histon School, Glebe Way, Histon
• Site area of 2.32 Ha
• Capacity of approx. 60 dwellings, including affordable housing and self/custom build
• Provision of new open space and landscaping, including links to Northern Buxhall Farm local green space

Land to the north of Cardyke Road, Waterbeach Cardyke Road
• Site area of 2 Ha
• Capacity of approx. 40 dwellings, including affordable housing and self/custom build
• Pedestrian and cycle links to Cambridge Road and Cardyke Road

Belsar Farm, Willingham
• Site area of 0.88 Ha
• Capacity of approx. 26 dwellings, including affordable housing
• Pedestrian and cycle links to neighbouring development and Sponge Drove

Tostock Farm, Cambridge Road, Melbourn
• Site area of 13.01 Ha
• Capacity for approx. 150 dwellings, including affordable housing and self/custom build
• Significant new open space and strategic landscaping
• New pedestrian links to Cambridge Road and Portway
• Enhancement of existing agricultural access to Cambridge Road

Herod’s Farm, High Street, Foxton
• Site area of 5 Ha
• Capacity of approx. 90 dwellings, including affordable housing and self/custom build
• Provide open space and green infrastructure, including enhanced biodiversity and landscape buffer as requested by Neighbourhood Plan
• Upgrade existing vehicular access on High Street and provide new links to Rowlands Close

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable.

The Greater Cambridge area includes many large villages (currently classified as Rural Centres, Minor Rural Centres and Group Villages) which have train stations, guided busway routes, rapid bus connections and greenway cycle lanes with link to employment centres and Cambridge city centre. They are accessible to a variety of services and facilities by realistic alternatives to the car. Further, these villages contain a variety of services and facilities which would be supported by new residents.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for a significant number of affordable homes in many of the District’s villages. This identified need would not be met without allocations in these villages, which would include housing and affordable housing.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

It is requested that the development strategy for the rest of the rural area includes additional allocations in the following locations:

Glebe Farm, Twenty Pence Road, Cottenham Glebe Fen Farm
• Site area of 6.8 Ha
• Capacity of approx. 150 dwellings, including affordable housing and self/custom build
• Provision of significant new open space, including a buffer to the church yard
• Retain key views of the Church and Conservation Area and minimise harm to heritage assets

Land west of Cottenham Road, Histon (Buxhall Farm)
• Site area of 4.8 Ha
• Capacity of approx. 40 dwellings, including affordable housing, to the front of the site along Cottenham Road
• Provision of new open space and potentially community land to the rear, with biodiversity enhancements and strategic landscaping

Land adjacent to Histon School, Glebe Way, Histon
• Site area of 2.32 Ha
• Capacity of approx. 60 dwellings, including affordable housing and self/custom build
• Provision of new open space and landscaping, including links to Northern Buxhall Farm local green space

Land to the north of Cardyke Road, Waterbeach Cardyke Road
• Site area of 2 Ha
• Capacity of approx. 40 dwellings, including affordable housing and self/custom build
• Pedestrian and cycle links to Cambridge Road and Cardyke Road

Belsar Farm, Willingham
• Site area of 0.88 Ha
• Capacity of approx. 26 dwellings, including affordable housing
• Pedestrian and cycle links to neighbouring development and Sponge Drove

Tostock Farm, Cambridge Road, Melbourn
• Site area of 13.01 Ha
• Capacity for approx. 150 dwellings, including affordable housing and self/custom build
• Significant new open space and strategic landscaping
• New pedestrian links to Cambridge Road and Portway
• Enhancement of existing agricultural access to Cambridge Road

Herod’s Farm, High Street, Foxton
• Site area of 5 Ha
• Capacity of approx. 90 dwellings, including affordable housing and self/custom build
• Provide open space and green infrastructure, including enhanced biodiversity and landscape buffer as requested by Neighbourhood Plan
• Upgrade existing vehicular access on High Street and provide new links to Rowlands Close

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable.

The Greater Cambridge area includes many large villages (currently classified as Rural Centres, Minor Rural Centres and Group Villages) which have train stations, guided busway routes, rapid bus connections and greenway cycle lanes with link to employment centres and Cambridge city centre. They are accessible to a variety of services and facilities by realistic alternatives to the car. Further, these villages contain a variety of services and facilities which would be supported by new residents.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for a significant number of affordable homes in many of the District’s villages. This identified need would not be met without allocations in these villages, which would include housing and affordable housing.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

It is requested that the development strategy for the rest of the rural area includes additional allocations in the following locations:

Glebe Farm, Twenty Pence Road, Cottenham Glebe Fen Farm
• Site area of 6.8 Ha
• Capacity of approx. 150 dwellings, including affordable housing and self/custom build
• Provision of significant new open space, including a buffer to the church yard
• Retain key views of the Church and Conservation Area and minimise harm to heritage assets

Land west of Cottenham Road, Histon (Buxhall Farm)
• Site area of 4.8 Ha
• Capacity of approx. 40 dwellings, including affordable housing, to the front of the site along Cottenham Road
• Provision of new open space and potentially community land to the rear, with biodiversity enhancements and strategic landscaping

Land adjacent to Histon School, Glebe Way, Histon
• Site area of 2.32 Ha
• Capacity of approx. 60 dwellings, including affordable housing and self/custom build
• Provision of new open space and landscaping, including links to Northern Buxhall Farm local green space

Land to the north of Cardyke Road, Waterbeach Cardyke Road
• Site area of 2 Ha
• Capacity of approx. 40 dwellings, including affordable housing and self/custom build
• Pedestrian and cycle links to Cambridge Road and Cardyke Road

Belsar Farm, Willingham
• Site area of 0.88 Ha
• Capacity of approx. 26 dwellings, including affordable housing
• Pedestrian and cycle links to neighbouring development and Sponge Drove

Tostock Farm, Cambridge Road, Melbourn
• Site area of 13.01 Ha
• Capacity for approx. 150 dwellings, including affordable housing and self/custom build
• Significant new open space and strategic landscaping
• New pedestrian links to Cambridge Road and Portway
• Enhancement of existing agricultural access to Cambridge Road

Herod’s Farm, High Street, Foxton
• Site area of 5 Ha
• Capacity of approx. 90 dwellings, including affordable housing and self/custom build
• Provide open space and green infrastructure, including enhanced biodiversity and landscape buffer as requested by Neighbourhood Plan
• Upgrade existing vehicular access on High Street and provide new links to Rowlands Close

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable.

The Greater Cambridge area includes many large villages (currently classified as Rural Centres, Minor Rural Centres and Group Villages) which have train stations, guided busway routes, rapid bus connections and greenway cycle lanes with link to employment centres and Cambridge city centre. They are accessible to a variety of services and facilities by realistic alternatives to the car. Further, these villages contain a variety of services and facilities which would be supported by new residents.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for a significant number of affordable homes in many of the District’s villages. This identified need would not be met without allocations in these villages, which would include housing and affordable housing.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

It is requested that the development strategy for the rest of the rural area includes additional allocations in the following locations:

Glebe Farm, Twenty Pence Road, Cottenham Glebe Fen Farm
• Site area of 6.8 Ha
• Capacity of approx. 150 dwellings, including affordable housing and self/custom build
• Provision of significant new open space, including a buffer to the church yard
• Retain key views of the Church and Conservation Area and minimise harm to heritage assets

Land west of Cottenham Road, Histon (Buxhall Farm)
• Site area of 4.8 Ha
• Capacity of approx. 40 dwellings, including affordable housing, to the front of the site along Cottenham Road
• Provision of new open space and potentially community land to the rear, with biodiversity enhancements and strategic landscaping

Land adjacent to Histon School, Glebe Way, Histon
• Site area of 2.32 Ha
• Capacity of approx. 60 dwellings, including affordable housing and self/custom build
• Provision of new open space and landscaping, including links to Northern Buxhall Farm local green space

Land to the north of Cardyke Road, Waterbeach Cardyke Road
• Site area of 2 Ha
• Capacity of approx. 40 dwellings, including affordable housing and self/custom build
• Pedestrian and cycle links to Cambridge Road and Cardyke Road

Belsar Farm, Willingham
• Site area of 0.88 Ha
• Capacity of approx. 26 dwellings, including affordable housing
• Pedestrian and cycle links to neighbouring development and Sponge Drove

Tostock Farm, Cambridge Road, Melbourn
• Site area of 13.01 Ha
• Capacity for approx. 150 dwellings, including affordable housing and self/custom build
• Significant new open space and strategic landscaping
• New pedestrian links to Cambridge Road and Portway
• Enhancement of existing agricultural access to Cambridge Road

Herod’s Farm, High Street, Foxton
• Site area of 5 Ha
• Capacity of approx. 90 dwellings, including affordable housing and self/custom build
• Provide open space and green infrastructure, including enhanced biodiversity and landscape buffer as requested by Neighbourhood Plan
• Upgrade existing vehicular access on High Street and provide new links to Rowlands Close

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable.

The Greater Cambridge area includes many large villages (currently classified as Rural Centres, Minor Rural Centres and Group Villages) which have train stations, guided busway routes, rapid bus connections and greenway cycle lanes with link to employment centres and Cambridge city centre. They are accessible to a variety of services and facilities by realistic alternatives to the car. Further, these villages contain a variety of services and facilities which would be supported by new residents.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for a significant number of affordable homes in many of the District’s villages. This identified need would not be met without allocations in these villages, which would include housing and affordable housing.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Requested Change

It is requested that the development strategy for the rest of the rural area includes additional allocations in the following locations:

Glebe Farm, Twenty Pence Road, Cottenham Glebe Fen Farm
• Site area of 6.8 Ha
• Capacity of approx. 150 dwellings, including affordable housing and self/custom build
• Provision of significant new open space, including a buffer to the church yard
• Retain key views of the Church and Conservation Area and minimise harm to heritage assets

Land west of Cottenham Road, Histon (Buxhall Farm)
• Site area of 4.8 Ha
• Capacity of approx. 40 dwellings, including affordable housing, to the front of the site along Cottenham Road
• Provision of new open space and potentially community land to the rear, with biodiversity enhancements and strategic landscaping

Land adjacent to Histon School, Glebe Way, Histon
• Site area of 2.32 Ha
• Capacity of approx. 60 dwellings, including affordable housing and self/custom build
• Provision of new open space and landscaping, including links to Northern Buxhall Farm local green space

Land to the north of Cardyke Road, Waterbeach Cardyke Road
• Site area of 2 Ha
• Capacity of approx. 40 dwellings, including affordable housing and self/custom build
• Pedestrian and cycle links to Cambridge Road and Cardyke Road

Belsar Farm, Willingham
• Site area of 0.88 Ha
• Capacity of approx. 26 dwellings, including affordable housing
• Pedestrian and cycle links to neighbouring development and Sponge Drove

Tostock Farm, Cambridge Road, Melbourn
• Site area of 13.01 Ha
• Capacity for approx. 150 dwellings, including affordable housing and self/custom build
• Significant new open space and strategic landscaping
• New pedestrian links to Cambridge Road and Portway
• Enhancement of existing agricultural access to Cambridge Road

Herod’s Farm, High Street, Foxton
• Site area of 5 Ha
• Capacity of approx. 90 dwellings, including affordable housing and self/custom build
• Provide open space and green infrastructure, including enhanced biodiversity and landscape buffer as requested by Neighbourhood Plan
• Upgrade existing vehicular access on High Street and provide new links to Rowlands Close

Cambridgeshire County Council as landowner supports the proposed allocation of Mansel Farm, Oakington (reference S/RRA/MF). The site is sustainably located and adjacent to the busway station. The constraints set out in the GCLP can be addressed and the site remains suitable, available and achievable for the allocation proposed.

It should be noted that at a density of 25dph (suitable for a rural context), the site could support around 35 dwellings. This would still allow for a landscape buffer whilst ensuring development relates well to Meadow Farm Close. The 'Housing Statistical Information Leaflet' for South Cambs indicates a need for 20 affordable dwellings in Oakington, and an allocation of 35 homes (as proposed by the County) could support a greater proportion of this need than an allocation for 20 homes (as is currently preferred).

Cambridgeshire County Council supports the allocation of land at Buckingway Business Park, Swavesey (reference S/RRA/BBP). The site is located adjacent to the existing business park and close to the strategic highway network, and would be suited for a variety of B-class uses. The constraints set out in the GCLP can be addressed and the site remains suitable, available and achievable. Access is to be achieved via the existing agricultural access from Anderson Road.

Requested Change
S/RRA/MF Land at Mansel Farm, Station Road, Oakington
• Site area of 1.4 hectares
• Capacity for approximately 35 homes
• Provision of pedestrian access towards the busway stop
• Provision of substantial landscape buffer on eastern boundary

S/RRA/BBP Land at Buckingway Business Park, Swavesey
• Site area of 2.1 Ha
• Suitable for Class B2 or Class B8 uses
• Development should include a detailed odour assessment related to the nearby Uttons Drove Water Recycling Centre
• Access to be via Anderson Road

Land at Thorpes Farm, Swavesey (reference 40191)
• Site area: Amend to 7.54 Ha
• Proposed employment floorspace: Amend to 30,160sq.m
• Landscape and townscape: It is acknowledged that development in this location would encroach into the countryside, and for this reason it is proposed to amend the site area to only include the land between Buckingway Business Park and the wastewater treatment plant. Development would therefore be contained to the immediate north of the A1307. Whilst the site is open, the southern portion now proposed for allocation is already heavily affected by the A14 roadworks and the existing development to the east and west (wastewater treatment plant, hotel/services, and the Business Park). It is bound to the west west by proposed allocation S/RRA/BBP and an existing hotel, to the east by the sewage treatment works, and to the south by road infrastructure and services beyond. It is requested that the score be changed to “Amber”.
• Site Access: the site is immediately north of the de-trunked A1307 and Cambridgeshire County Council is in discussion with Highways England regarding access to the site from the A1307. Access would also be possible from Buckingway Business Park to the west, through land within the County Council’s ownership. Development would have little impact on landscape. It is requested that the score be changed to “Amber”.
• Transport and Roads: Whilst the site is remote from any settlements, the nature of the use proposed (namely, a highways depot) is unneighbourly and is required to be a certain distance from residential areas. Moreover, the site proposed has excellent access to the strategic road network. It is requested that the score be changed to “Amber”.

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

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

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

20 homes on 1.4 hectares - Mansel Farm, Oakington - near Beck Brook, water table concerns.
St Neots Road, Dry Drayton 4.6 hectares - Office, etc.- would this be at affordable rents? Landscaping should emphasise the rural location of this site.

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

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

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

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

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

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

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

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

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

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

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

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

How much development, and where – general comments

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

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

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

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

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

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

S/DS: Development strategy

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Land east of Long Road, Comberton

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

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

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

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

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

Hallam Land Management (HLM) support the Councils aims in respect of infrastructure, however it considers the Plan should allocate circa 8.6ha of land at Scotland Farm for the Scotland Farm Travel Hub. A site location plan and illustrative masterplan is appended to these representations. Information on this site has been submitted separately through the call for sites additional site information portal.

This policy proposes to allocate sites for homes or employment that support the overall development strategy within the rural area, excluding the rural southern cluster. The policy includes two new housing allocations proposed at Melbourn (Moor Lane and land to the west of Cambridge Road) together with allocations at Caldecote to the west of Cambridge and Oakington to the northwest of Cambridge.
As we have commented above in respect of Policies S/JH and S/DS, we consider that for the housing delivery strategy to be effective, it will be required to take into account all reasonable alternatives to deliver the right amount of rural housing, the right type of rural housing and in the right place for this part of Greater Cambridge to meet local needs, including much-needed affordable homes. The absence of additional housing allocations within the rural southwestern part of South Cambridgeshire (other than at Melbourn) means that Plan is unlikely to meet the specific housing needs of this part of Greater Cambridge.

Assessment of our client’s proposed housing site
Our client’s site and 725 other sites with potential for residential and economic development were assessed as part of the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) against a “RAG” scoring system. According to the HELLA, sites were deemed to be unsuitable if they were assessed as ‘Red’ against any of the criteria used, sites were deemed to be unavailable where there was no evidence that the site was available, or alternatively, there was evidence that the site was unavailable. Sites were deemed to be unachievable where it was considered there was no
reasonable prospect that the site could be developed.
Section 6 of the Development Strategy Topic Paper (p165) explains the detailed rationale followed in the assessment of proposed site allocations submitted through the Call for Sites process. The Topic Paper indicates that evidence suggests that housing in the rest of the rural area outside the southern cluster can help support delivery of a range of smaller sites within the area and support the vitality of villages. The Topic Paper states that the approach adopted to identify new rural locations for housing was consistent for both the rural southern cluster and the rest of the rural area and included the following key criteria:
• Locations with sustainable access: Rural Centres and Minor Rural Centres, but also Group villages with very good Public Transport Access.
• Sites with a green or amber rating in the Housing and Employment Land Availability Assessment.
The Strategy Topic Paper indicates that other relative factors were also considered (but not necessarily
defining a judgment) including account for parishes which already have lots of committed development with the aim for those sites to be built and the new community to bed-in before considering further development, informed by scale of village and committed development. A further factor was to consider the support for community aspirations for development, including responses to recent engagement with parishes regarding the Call for sites which provided awareness of those parishes with aspirations for development. The Topic Paper also explains that for sites meeting above criteria, officers used judgement, Housing and Employment Land Availability Assessment information on site constraints and assessment of suitability, and awareness of sites’ planning history to inform emerging proposed draft list of sites.
The assessment of our client’s site not taken forward into the First Proposals, forms part of HELAA Appendix 4 (Part C) under site reference 55082. A copy of the assessment proforma is included at Appendix 1 of this letter. The HELAA site assessment summary provides a red rating against ‘suitable’, with green ratings against both ‘available’ and ‘achievable’. Breaking this down further, the site assessment criteria under ‘suitable’ were all scored as amber or green, with the exception of a red rating against the landscape assessment criterion. Notwithstanding that this red rating against ‘suitable’ was
on the basis of impact of the site on rural countryside character, the assessment nevertheless concludes
that a reduced development “…may be acceptable subject to responding to the surrounding character
and with landscape mitigation”.
Although the proposed new housing allocations at Melbourn are both sites which were assessed with a green or amber rating in the HELAA, in terms of the key criteria applied, it is less clear how these sites fared better in sustainability terms than our client’s site. Meldreth is well placed to supply additional rural housing given it is a Group Village that benefits from a train station and has good sustainable transport links to London and Cambridge. This contrasts with Melbourn which, although defined as a Minor Rural Centre one tier higher in the settlement hierarchy than Meldreth, does not have a station.
We continue to be of the view that our client’s site represents a sustainable opportunity to deliver residential development with significant benefits and only very limited adverse impacts. The site is well located such that future occupants of dwellings would be able to walk to the village using the existing path through The Burtons, into West Way and then along the footpath of Kneesworth Road and Whitecroft Road into the centre of the village. A local bus stop is located on Kneesworth Road, just outside West Way and the train station is within 1,500 metres of the site and would therefore be in walking distance for future occupiers. Development of the site would therefore in an appropriate location to access the facilities of the village.
Our client continues to offer the entire site or, alternatively, part of the site for residential use including
a minimum of 50% affordable homes across the entire site or 100% affordable homes on the partial site. Our client remains willing to do all he can to assist the Council in ensuring a development fulfils this role. The site would support NPPF paragraph 79 which states that to promote sustainable development rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Allocation of the site for new housing would also adhere to NPPF paragraph 69 which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services. The site would also represent a small sized site capable of making an important contribution to meeting the housing requirements of the area, and would also be capable of being built-out quickly.
We consider that a potential impact on Landscape Character identified by the HELLA assessment could
reasonably be addressed in design and layout terms, particularly in the context that the assessment concludes that a reduced development may be acceptable subject to responding to the surrounding character and with landscape mitigation.
Against this background, we would request that our client’s site is included for consideration at the next plan-making stage.

I wish to comment on proposals for 20 houses at Mansel Farm in Oakington

I have tried commenting online and registered so I can make detailed comments but was unable to find the blue dialogue boxes you suggest I comment in, hence this email

I am (text redacted)

I have lived here nearly 20 years

The proposal is for 20 houses in the field alongside my bungalow

The view from my kitchen window of the guided bus stop in the distance is currently of a field often with sheep in it

Instead the view will be of this new housing estate

I am concerned about flooding issues for which Oakington is renowned

The field is large and only the part near Station Road is in the plan however the other part of the field regularly floods near Beck Brook when we have heavy rain

I’m concerned that this new development will exacerbate the flooding issues in this field as water run off from the site will add to the flooding as water will be prevented from going in to the ground as houses and roads and concrete will be there instead

If the 20 houses are to be built I would like to be told how it is planned that water run off from the site will not be allowed to flood my bungalow which is within 20 feet of part of the site

Will there be a good level of green separation between the site and Meadow Farm Close, and particularly my (text redacted) which (text redacted)

What measures will be in place to screen the new site from my kitchen window view which will look straight onto it?

Has any consideration been given to the extra levels of traffic which will be caused by this development to the village of Oakington?

Indeed, a road is planned into the new town of Northstowe from an area within 40 feet of this proposed site. This road together with the roads accessing this new site will put pressure on the road which is very busy already carrying traffic from Cottenham to the A14.

The Drift, Harston (HELAA site 40535)

Response has been provided through the call for sites form responding to the HELAA assessment.

We hope that the positive locational attributes of this site carry enough weight over rural locations which do not havethe adjoining transport connectivity advantages which results in a sustainable transport location.

Land Between New Road and Water Lane Melbourn (HELAA site 40500)

Additional information has been submitted through the call for sites proforma.

The assessment should be amended to reflect matters set out in submissions, and should result in the site scoring an overall green rating. The Councils have made allocations for two peripheral sites to the north of Melbourn and in our view site 40500 should also be allocated as a sustainable addition to assist with the early delivery of housing to meet local needs and teh planned growth target, especially in the shorter term.