Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 58185

Received: 13/12/2021

Respondent: Enterprise Property Group Limited

Agent: Carter Jonas

Representation Summary:

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting.

Full text:

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 58187

Received: 13/12/2021

Respondent: Enterprise Property Group Limited

Agent: Carter Jonas

Representation Summary:

Land at Meadow Drift, Elsworth (HELAA site 40154)

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.

Full text:

OBJECT

Enterprise Residential Development Ltd and Davison Group are promoting land at Meadow Drift, Elsworth for residential development and community facilities including a school car park and drop off area, new allotments and ecological enhancement area, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

The overall development strategy is very reliant on the delivery of extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum. The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided, at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The preferred development strategy for the rest of the rural area is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for some villages, including Elsworth, which contains some services, facilities and employment opportunities suitable to support some additional development. In addition, the preferred development strategy for the rest of the rural area provides no support for existing services and facilities, including schools, in villages and provides no strategy to meet current identified affordable housing needs of villages. Enterprise Residential Development and the Davison Group are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages to support services and ensure that identified affordable housing needs are met.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 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.

Elsworth contains some services and facilities, including a primary school, public houses, church and sport and social club. Cambourne and Papworth Everard provide additional services and facilities not provided within Elsworth. There is also a successful commercial area to the south of the village offering employment opportunities. The site promoted by Enterprise Residential Development Ltd and the Davison Group at Meadow Drift, Elsworth is in the heart of the village and is accessible to all of the services and facilities in the village by walking and cycling. The local transport services available are such that future residents would have a realistic choice of travel modes.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 12 affordable dwellings in Elsworth for those with a local connection to the village. This identified need would not be met without allocations in Elsworth. It is noted that there is no neighbourhood plan being prepared for the village, no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Enterprise Residential Development Ltd and the Davison Group at Meadow Drift, Elsworth would include housing and affordable housing to meet local needs of the village.

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

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Elsworth, 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.

As requested in Enterprise Residential Development Ltd and the Davison Group’s representations to Section 6.2: Rest of Rural Area, the land at Meadow Drift, Elsworth should be allocated in emerging GCLP for residential development.

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