Greater Cambridge Local Plan Preferred Options

Search representations

Results for RO Group Ltd search

New search New search

Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 57092

Received: 09/12/2021

Respondent: RO Group Ltd

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: 57094

Received: 09/12/2021

Respondent: RO Group Ltd

Agent: Carter Jonas

Representation Summary:

Summary: Land south of Hall Lane, Gt CHishill (HELAA site 47879)

Additional sites that are capable of providing policy compliant levels of affordable housing need to be 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.

Small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including Chishill, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

Land south of Hall Lane in Great Chishill should be allocated in emerging GCLP for residential development

Full text:

OBJECT

RO Group is promoting land south of Hall Lane in Great Chishill for a small infill residential development of approximately 21 dwellings including affordable housing, 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 an 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; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. 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.

It is considered that current predicted delivery rates at the existing and planned new settlements are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is considered that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East taking into account the complexity or these developments and the need for existing uses to be relocated. It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, and in order to address that under-delivery it is considered that 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 Great Chishill where rural bus services are due to be improved. The preferred development strategy for the rest of the rural area also provides no support for existing services and facilities in villages and provides no strategy to meet current identified affordable housing needs of villages. RO 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 some 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.

Great Chishill contains a public house, places of worship, a village hall, and sports and recreation grounds. It would be beneficial for additional development to support these services and facilities. There is a currently a limited bus service to Royston and Cambridge, but it noted that the Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service for Great Chishill in the future.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 9 affordable dwellings in Great Chishill and Little Chishill for those with a local connection to the villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without allocations in Great Chishill. 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 RO Group at land south of Hall Lane in Chishill 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 Chishill, because there are planned improvements to the rural bus service, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

As requested in the RO Group representations to Section 6.2: Rest of Rural Area, the land south of Hall Lane in Great Chishill should be allocated in emerging GCLP for residential development.

Comment

Greater Cambridge Local Plan Preferred Options

S/SH: Settlement hierarchy

Representation ID: 57096

Received: 09/12/2021

Respondent: RO Group Ltd

Agent: Carter Jonas

Representation Summary:

Land off Hall Lane, Great Chishill (HELAA site 47879)

A capacity assessment should be undertaken of all villages in South Cambridgeshire to determine which potential housing sites might be deliverable or developable during the plan period to 2041, and the number of dwellings that might be delivered from each of those sites.
It is requested that the site size limits for each category of village are deleted and replaced with a general policy that supports development within existing settlement boundaries, in conjunction with a revised development strategy that allocates suitable sites on the edge of existing villages to ensure affordable housing needs are met including at Great Chishill.

Full text:

OBJECT

RO Group is promoting land south of Hall Lane in Great Chishill for residential development, and in representations has requested that the site is allocated in emerging GCLP. Great Chishill is defined as an Infill Village in the settlement hierarchy for South Cambridgeshire which is appropriate based on the services and facilities available in the village.

As set out in the representations to Policy S/SB: Settlement Boundaries, it is considered that there is limited capacity within the settlement boundaries of most villages. There are few outstanding development opportunities for up to 2 dwellings within existing settlement boundaries in Infill Villages, and sites of this size are not required to provide affordable housing. It is considered that the site size thresholds for each category of village are largely irrelevant and ineffective because very few sites are actually available, and those that are available would fall below the threshold where affordable housing is required e.g. less than 10 dwellings. The site promoted by RO Group at land south of Hall Lane in Great Chishill represents an infill site located outside the settlement boundary that could accommodate approximately 21 dwellings including policy compliant levels of affordable housing.

Requested Change

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

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

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 57097

Received: 09/12/2021

Respondent: RO Group Ltd

Agent: Carter Jonas

Representation Summary:

Land off Hall Lane, Great Chishill (HELAA site 47879)

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

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs, it is requested that additional allocations are made on the edge of those villages to deliver sufficient housing to meet the affordable housing need.

Full text:

OBJECT

RO Group does not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018. It is very likely that most of the development opportunities within existing village boundaries would have been taken up by now. It is also likely that heritage assets within some villages, such as conservation areas and listed buildings, will constrain development opportunities.

The Councils have not undertaken an assessment of the capacity land within the existing settlement boundaries of villages to accommodate additional development. It is likely that such an assessment would demonstrate that the capacity is limited.

It is considered that the emerging GCLP should seek to allocate suitable sites on the edge of existing villages and to adjust the settlement boundary to accommodate those allocations. The site promoted by RO Group at land south of Hall Lane in Great Chishill is suitable and available for housing, and should be allocated for development. There is a need for additional housing sites in the Great Chishill to support the existing services and facilities and to meet identified affordable housing needs in the village.

Requested Change

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

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs it is requested that additional allocations are made on the edge of those villages to deliver sufficient housing to meet those affordable housing needs.

Comment

Greater Cambridge Local Plan Preferred Options

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

Representation ID: 57099

Received: 09/12/2021

Respondent: RO Group Ltd

Agent: Carter Jonas

Representation Summary:

Land south of Hall Lane Great Chishill (HELAA Site 47879)

It is considered that the growth of the villages must be part of the development strategy for emerging GCLP, and particularly those villages such as Great Chishill where there are planned improvements to the rural bus service and where there is an identified need for affordable housing for those with a local connection to the village. It should be noted that more people are working at home, at least for part of the week, and this trend is likely to continue which means people will commute less often for work. The phasing out of petrol and diesel vehicles and the requirement for new residential developments to include electric vehicle charging points should help to improve air quality.

It is requested that the development strategy for the rest of the rural area includes an additional allocation in Great Chishill at land south of Hall Lane.

Full text:

Section 2.6: Rest of Rural Area / Policy S/RRA: Allocations in the Rest of the Rural Area

OBJECT

It is considered that the growth of the villages must be part of the development strategy for emerging GCLP, and particularly those villages such as Great Chishill where there are planned improvements to the rural bus service and where there is an identified need for affordable housing for those with a local connection to the village. It should be noted that more people are working at home, at least for part of the week, and this trend is likely to continue which means people will commute less often for work. The phasing out of petrol and diesel vehicles and the requirement for new residential developments to include electric vehicle charging points should help to improve air quality.

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. The promoted development at land south of Hall Lane in Great Chishill would support the existing services and facilities in the village, including the public house and existing and future bus services. There is a currently a limited bus service from Great Chishill to Royston and Cambridge, but the Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service from the village to provide realistic alternatives to the car in the future.

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. It is requested that small/medium sized sites such as land south of Hall Lane in Great Chishill are allocated to meet the requirement for a mix of sites including those that are easily deliverable.

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 9 affordable dwellings in Great Chishill and Little Chishill for those with a local connection to the villages. This identified need would not be met without allocations in the village. The promoted development by RO Group at land south of Hall Lane in Great Chishill 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, including Great Chishill, because the village will have a better bus service in the future, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village which would not be met via other means.

The RO Group representations to the assessment of the land south of Hall Lane site in the HELAA (Site Ref. 47879) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed. The call for sites submission referred to three potential sites, but only the land south of Hall Lane is now promoted for residential development. In summary, the land south of Hall Lane represents and infill site between existing housing, there are no heritage, landscape or ecological constraints associated with this site and existing trees and hedgerows could be retained and enhanced, an access can be provided on to Hall Lane, and the bus service in the village is due to be improved in the future to improve accessibility by sustainable modes of transport.

Requested Change

It is requested that the development strategy for the rest of the rural area includes an additional allocation in Great Chishill at land south of Hall Lane.

It is requested that land south of Hall Lane in Great Chishill is allocated with the following policy requirements:

• Site Area of 0.69 Ha
• Capacity for approx. 21 dwellings, including affordable housing
• Retain and enhance existing trees and hedgerows
• Provide access from Hall Lane

Comment

Greater Cambridge Local Plan Preferred Options

Sustainability Appraisal

Representation ID: 57100

Received: 09/12/2021

Respondent: RO Group Ltd

Agent: Carter Jonas

Representation Summary:

It is considered that the Sustainability Appraisal has not sought to make the emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

Full text:

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by RO Group that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The housing related sustainability objective SA1: Housing is relevant to the RO Group representations. The representations and requested amendments to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the RO Group representations to Policy S/DS, there are no housing allocations made in most villages, including Great Chishill, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 9 affordable dwellings in Great Chishill and Little Chishill will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. RO Group has requested that land south of Hall Lane in Great Chishill is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in the CEMEX representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Great Chishill is an example where small infill development of up to 2 dwellings does not provide affordable housing and there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 9 affordable dwellings in Great Chishill and Little Chishill. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Great Chishill, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1 As set out above there is an identified need for 9 affordable dwellings in Great Chishill, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Great Chishill, will not be met by the development strategy or the strategy for rural areas.

It is requested that land south of Hall Lane in Great Chishill is allocated in emerging GCLP for housing and affordable housing, in order to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

For instructions on how to use the system and make comments, please see our help guide.