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

Land South of St.Neots Road Hardwick (HELAA site 40273)

Additional information submitted through the call for sites proforma.

Based on information submitted it is our view that the site should be rated overall green for suitability and not red as currently shown. It remains available and achievable and should therefore be considered for inclusion as an additional allocation to assist with early delivery of housing that is not reliant on major infrastructure or planning for delivery of strategic scale development.

Land at Brook Road, Bassingbourn
Gladman are promoting Land at Brook Road, Bassingbourn. The 6.46ha site is suitably and sustainably located adjacent to Bassingbourn, near to key facilities such as the Primary School, Village College and Sports Centre. The site would provide for a high-quality design led scheme of up to 80 homes, of which up to 32 would be affordable, within a green network of ecological enhancements.
The site offers a unique opportunity to create a naturalistic green corridor, improve biodiversity on site through wetland creation, hedgerow planting, native planting and provision of new bird nesting opportunities. Landscaping will be provided on site to ensure local character is retained and enhanced, whilst providing much needed market and affordable housing in Bassingbourn.

Land at Whitecroft Road, Meldreth
Gladman are promoting 3.77ha of land at Whitecroft Road, Meldreth. The site is capable of delivering 90 homes, up to 36 of which will be affordable. Development at this location offers significant opportunities for community benefits through CIL-compliant financial contributions and increased local spending through new residents.
The site is in a highly sustainable location, well contained by residential dwellings to the east and Whitecroft Road to the west. The settlement is served by excellent transport links, including a train station with regular services to Cambridge and London. The site presents no harm to heritage assets and is not at risk of flooding, as demonstrated in the Modelling Report attached to Gladman’s submission. Details of the modelling results are included in the ArcGIS StoryMap for this settlement.

Land at New Road, Melbourn
Gladman are promoting 5.88ha of land for residential development at New Road, Melbourn. The site is capable of delivering 140 new homes, up to which 56 will be affordable whilst maintaining and enhancing existing vegetation, allowing the new development to integrate into the wider existing landscape.
The site is within Flood Zone 1, presents no harm to heritage assets and compliments the recent developments to the north and northwest of the site. The site can also provide ecological enhancements through recreational green space, biodiversity net gain and new habitats created through the provision of a sustainable drainage system.

Land at Station Road, Over
Gladman are promoting 3.46ha of land for residential development comprising 65 new homes, of which 16 will be affordable. The site is well contained by Station Road and New Road and is sustainably located adjacent to existing development. Over is a sustainable settlement benefitting from the Cambridgeshire Guided Busway.
The development retains open space to create a sensitive transition to the existing recreation ground and offers several benefits for Over. CIL compliant financial contributions will allow the Council to reinvest in Over, potentially providing improvements for the local community centre and sports facility and an extension to the existing recreation ground.

Land at Willingham Road, Willingham
Gladman are promoting land at Willingham Road, Willingham. The site presents the opportunity to provide up to 100 new homes, including 40 affordable homes, biodiversity and ecological enhancement opportunities, publicly accessible open space, and CIL compliant contributions towards local community benefits.

This representation has been prepared by Strutt & Parker on behalf of NIAB Trust to support the promotion of Land north-east of Villa Road, Impington as part of the Greater Cambridge First Proposals Consultation 2021.
The site covers an area of approximately 2.19 hectares and is capable of delivering 4,100sqm of light industrial/research and development units including ancillary provisions such as car parking and landscaping. The site allocation would attract hightech firms to the area to compliment the established firms that are located within Vision Park and also NIAB’s crop research facilities at Park Farm. This would help to boost the local economy by attracting high-tech firms to the area and create job opportunities. It is also noted that this site could provide opportunities for lab space, which is in short supply in Cambridge.
In September 2021 Greater Cambridge Shared Planning Service (GCSPS) published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.
This representation provides a response to the ‘First Proposals’ Consultations. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.
The HELAA excludes the Villa Road site from allocation primarily on the basis of concerns relating to the impact on flood risk, landscape and townscape; site access; and strategic highway impact.
In response to the areas of concern, a feasibility study has been prepared which considers the potential development opportunities including scale, access, connectivity, flood relief and biodiversity improvements. A technical note on flood management has also been produced to respond to the concerns raised regarding flood risk. Further analysis of this is set out within section 7 of this report.
In support of this report, the following document have been prepared;
• Prospective Site Feasibility Study by pHp architects;
• Flood risk management note by Cannon Consulting Engineers

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 north-east of Villa Road, Impington should be allocated for employment development and would represent a sound allocation as part of the emerging Local Plan as it complements the objectives of the Greater Cambridge economic growth strategy. The land off Villa Road site was promoted originally at Call for Sites and Issues & Options stages.
We acknowledge that the focus of the economic strategy is to support the development of the Biomedical Campus, however, the crop science and food production research sectors are an equally important and rapidly expanding part of the Greater Cambridge economy and should be supported as well.

This representation has been prepared by Strutt & Parker on behalf of NIAB Trust to support the promotion of Land West of South Road, Impington as part of the Greater Cambridge First Proposals Consultation 2021.
In September 2021 Greater Cambridge Shared Planning Service (GCSPS) published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.
Since the Call for Sites and Issues and Options consultations feedback received has been considered and changes have been made to the Land West of South Road site. Previously the site covered an area of approximately 20.62 hectares and was considered to be suitable to deliver a development including 450 dwellings. However, following feedback received at the First Proposals the decision has been taken to greatly reduce the area of the site and quantum of potential development. The revised site is approximately 5.2 hectares in area, and can accommodate 78 dwellings.
It is noted that the NIAB Trust has also put forward two other sites at Park Farm (Villa Road and Redgate Road).
This representation provides a response to the ‘First Proposals’ Consultations. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.
The HELAA excludes the Land West of South Road from allocation for 3 main reasons: a) In relation to Landscape and Townscape: “The site is isolated from the main part of the village and is outside the village framework. Any development of the site would have a negative landscape impact because of the extensive views from the north west and south”. b) In relation to Site Access: “The proposed site does not to have a direct link to the adopted public highway” and there is “No possibility of creating a safe access”. c) In relation to Strategic Highway Impact: “Within Highways England Zone 3 - A14 CNB. No capacity for growth. Sites would need to ensure no net increase in vehicles trips on the Strategic Road Network”.
A Prospective Site Feasibility Study, prepared by pHp architects has been produced to support this representation (Appendix B). As set out in the study, in relation to Landscape and Townscape, the site would be smaller, and would be read as part of the existing village. The smaller site would also have less of a negative landscape impact as it would be well aligned with the existing western edge of Impington. Additionally, the density of the dwellings has been greatly reduced, increasing the openness of the site, and reducing landscape harm. In relation to Site Access, as shown on page 7 of the study, a safe site access could easily be provided to South Road/Mill Road where there is an existing field access to the north of the existing Green Space. A large additional area of green space could be provided directly to the south of the South Road Green Space to compensate for land required for the widening of the access link. In relation to Strategic Highway Impact, the number of dwellings proposed has been greatly reduced, minimising any potential harm. 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 considered that the revised site addresses many of the issues previously raised, and that several of the assessment criterions used to assess the site 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 on the landscape or road network, and as such that the site should be put forward for allocation. Further analysis of this is set out within section 7 of this report.
In support of this report, the following document has been prepared;
• Prospective Site Feasibility Study, produced by pHp architects.

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 west of South Road, Impington should be allocated for development and would be a sound allocation as part of the emerging Local Plan. The land west of South Road, Impington 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 or the road network.

The following sites have been promoted through previous iterations of the plan and through the Call for Sites process and should be allocated for development:

Land at Bannold Road Waterbeach (ref 40466)

Land off Kingfisher Way, Cottenham (ref 40472)(additional information submitted through call for sites proforma)

Land to the north of Cottenham (new site)

Land at Boxworth End Swavesey (ref 40506) (additional information submitted through call for sites proforma)

Land at Priest Lane, Willingham (ref 40468) (additional information submitted through call for sites proforma)

The following sites have been promoted through previous iterations of the plan and through the Call for Sites process and should be allocated for development:

Land at Bannold Road Waterbeach (ref 40466)

Land off Kingfisher Way, Cottenham (ref 40472)(additional information submitted through call for sites proforma)

Land to the north of Cottenham (new site)

Land at Boxworth End Swavesey (ref 40506) (additional information submitted through call for sites proforma)

Land at Priest Lane, Willingham (ref 40468) (additional information submitted through call for sites proforma)

The following sites have been promoted through previous iterations of the plan and through the Call for Sites process and should be allocated for development:

Land at Bannold Road Waterbeach (ref 40466)

Land off Kingfisher Way, Cottenham (ref 40472)(additional information submitted through call for sites proforma)

Land to the north of Cottenham (new site)

Land at Boxworth End Swavesey (ref 40506) (additional information submitted through call for sites proforma)

Land at Priest Lane, Willingham (ref 40468) (additional information submitted through call for sites proforma)

The following sites have been promoted through previous iterations of the plan and through the Call for Sites process and should be allocated for development:

Land at Bannold Road Waterbeach (ref 40466)

Land off Kingfisher Way, Cottenham (ref 40472)(additional information submitted through call for sites proforma)

Land to the north of Cottenham (new site)

Land at Boxworth End Swavesey (ref 40506) (additional information submitted through call for sites proforma)

Land at Priest Lane, Willingham (ref 40468) (additional information submitted through call for sites proforma)

The evidence base for the GCLP First Proposals document includes the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) (September 2021). Within the HELAA the site is assessed under two separate parcels: east of Horningsea Road (site reference 47647) and west of Ditton Lane (site reference 40516). The document provides a site assessment through a ‘traffic light’ colour coding, with both parcels receiving a ‘red’ outcome for suitability and ‘green’ for both availability and achievability.
The suitability assessment contains a number of issues that the Council have considered. These are set out within the table below, with comments provided in response to this on behalf of Countryside together with our revised assessment of the site when considered as a whole.
It is therefore considered that the issues identified by the Council as being ‘red’ or ‘amber’ would not prohibit the allocation and eventual development of the site. All of these issues can be dealt with through the provision of additional information to a planning application or through mitigation as part of the development of the site. As such, the site is considered to be suitable for the development proposed, and the Council are therefore urged to reconsider the site for allocation as part of the Greater Cambridge Local Plan.

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

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

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

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

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

We submit that it is clear in paragraph 69 of the NPPF that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly’ and that local planning authorities should ‘promote the development of a good mix of sites’. It is considered that the Council 's strategy focuses on very large sites to deliver their housing requirement with virtually no small or medium allocations.

Furthermore, paragraph 79 of the NPPF is clear that in order to ‘promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.’ By delivering more housing in settlements such as Steeple Morden, development will continue to support local services and facilities, supporting their retention and growth. The need for additional housing in Steeple Morden was demonstrated by a formal 'Housing Need Survey' undertaken for the project by Cambridgeshire Acre in September and October 2020.

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

HELAA site ref no. 51599 Land east of Highfields rd, Highfields Caldecote for Vistry Group. S/JS and S/DS - please see attached document titled: Land at Highfields, Caldecote Representations / Summary.

This policy defines that settlement boundaries will be identified around existing settlements and planned new development outlined in the Plan. It is proposed that boundaries would take into account the existing built-up areas but will not normally include buildings associated with countryside uses, such as farm buildings nor development which is detached from the main concentration of buildings in an existing area.
It is also proposed that outside defined settlement boundaries that no development would be permitted except for:
• allocations within Neighbourhood Plans that have come into force;
• Rural Exception Sites which help meet local needs for affordable housing;
• development for agriculture, horticulture, forestry, outdoor recreation and other uses that need to locate in the countryside; or
• development supported by other policies in the plan.
This policy limits the opportunity for suitable sites on the edge of settlements to come forward that can meet the needs of Extra Care development where it is required, and which can effectively tackle the known affordability crisis in the district. This policy needs to ensure that affordable housing is delivered quickly and in areas in which it will support the local community. PPG notes that ‘A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.’ (Paragraph: 009 Reference ID: 67-009-2019072)
As outlined above, there is a defined current and future substantial unmet need for specialist housing. The current need of specialist housing is rising, and it is unlikely that this need will be met at urban extension or within new settlements, which are likely to come forward in the later parts of the plan period. Given the overall demand for housing in Greater Cambridge and the inflexibility of the Councils’ overall strategy the nature and extent of supply in these locations is such that operators within the specialist older persons housing sector face extreme pressures of competition in securing development opportunities. This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
Consideration should therefore be given to the release of such sites for development beyond sustainable settlement envelopes such as land at Branch Road and Long Lane, Comberton.

Cheffins has been instructed by Mr Stephen Graves and Mrs Jane Graves to promote their interests in Land to the southwest of St Michael's, Longstanton (HELAA Site Reference: 40521). We propose a development that will deliver approximately 98 dwellings of mixed type and tenure in a sustainable location proximal to major employment centres, and create attractive open spaces for the village.

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

(Table of proposed allocations included in attached document)

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

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

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

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

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

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.

Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the 'open countryside'. But it is not logical to treat all sites equally in policy terms. The sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Land West of Elizabeth Way, Gamlingay). Such a pragmatic approach is often taken at appeal; rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping that would soften an existing harsh area of built form can be acceptable in certain locations.

Furthermore, for Minor Rural Centres such as Gamlingay the current strategy to restrict developments to an indicative maximum of 30 dwellings within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes as there are few opportunities for the development of sites within the existing settlement. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much-needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable villages such as Gamlingay.

Overall, a carefully worded criteria-based policy which is supportive of organic growth adjacent to existing built-up areas would allow rural areas to thrive and is in accordance with the aims of NPPF paragraph 79 which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

Lancashire Industrial and Commercial Services Limited is the freehold owner of the above Site ref 40345 at Milton.

The Site was submitted for development and allocation in the Greater Cambridge Local Plan by Turley, my retained planning consultants.

I attach a Representation of Transport Matters prepared by TPA Transport Planning Associates. This deals with all transport issues in relation to your site assessment (reference 40345).

In particular the Representation shows there are no transport impediments. It assesses acceptable access, accessibility to services and facilities, and minimal strategic highway impact. The Site should be identified as green in respect of all transport related topics.

Please also note that planning permission still exists for the construction of an additional Club House building on the Site which will result in increased traffic flow in any event.

Therefore would you please amend your assessment summary to identify all transport related issues as green.

It is noted that the Council intends to redraw the settlement boundaries under Policy S/SB. The settlement boundary of Cottenham should be redrawn to reflect the changes that are currently taking place to the west of the settlement following the permissions under references S/2413/17/OL and S/1606/16/OL. These residential developments are both under construction and therefore should be included as part of the settlement boundary.

Once the settlement boundary is redrawn, there is one remaining parcel of undeveloped land which would be incorporated into the settlement boundary. The land to the rear of 89 Rampton Road, Cottenham (as shown on the attached plan reference SK-1-101). This leftover parcel should be allowed to come forward for residential development and could provide for a need which is currently unmet in terms of self-build plots. Although at early design stages, it is anticipated that the site could accommodate 7 self-build plots (see attached indicative site plan reference SK-1-101).

The site is suitable for development, located within an existing residential area in walking distance from the services and facilities within Cottenham. Safe and suitable access to the site is available (as shown on Site Plan SK-1-101) through the Persimmon development adjacent to the site which is currently under construction. The site is available for development now with support from both landowners as evidenced through the attached letters of support and land registry documents demonstrating ownership. The site is also achievable, as there are no foreseen abnormal costs associated with this land. The site therefore meets the tests of deliverability as set out within the NPPF.

As part of this consultation, the site has been put forward as per the Council’s request for potential sites under reference NNZRHQVR which provides further details regarding the site.

Policy makes it clear that the purpose of Green Belt identified around Cambridge is to:
• Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre;
• Maintain and enhance the quality of its setting;
• Prevent communities in the environs of Cambridge from merging into one another and with the city.

A Green Belt Review of Land off Beach Road has been undertaken. Having specific regard to the above purposes of the Cambridge Green Belt it is considered that this parcel of land only partial contributes to maintaining and enhancing the quality of its setting. On this basis it is concluded therefore that there would only be limited effect therefore from releasing the land from Green Belt for development.

Land South Bramley Ave, Melbourn (new site 59396)

New site submitted through call for sites proforma.