Greater Cambridge Local Plan Preferred Options

Great Shelford (Ten Acres) Ltd “GSTA” supports the identified requirement for 44,400 new homes in the period to 2041. This is above the figure recommended by Government using the standard methodology.

The spatial strategy is urban focused, relying on intensification of existing allocations (North West Cambridge) and accelerated delivery at the new settlements of Northstowe and Waterbeach. In total, this accelerated delivery and intensification is expected to deliver 2,500 new homes over the Plan period. It is unclear how this approach can significantly boost the supply of homes (as sought in Government policy). At this stage there is no evidence to support delivery rates can be sustained in these locations at this level.

As advised at para 73 (d) NPPF 2021, strategic policy-making authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites. Without further justification for the densification and acceleration of key schemes within the development strategy the housing delivery element of the Plan would be unsound.

The conclusion must be that further sites need to be allocated for housing to ensure the required annualised supply of housing of 2,326 homes can be achieved.

The strategy places little emphasis on existing villages to support the spatial strategy, particularly during the early years of the plan when these large sites are more likely to be prone to delays and slippage in the anticipated trajectory rates.

The plan should identify additional smaller sites that are capable of delivering homes over a 1-2 year period to help accelerate growth and provide greater certainty around housing supply over the plan period and beyond

This would also ensure that the plan allows choice and opportunities for smaller developers and housebuilders

Introducing further land supply at the most sustainable villages will not risk creating a dispersed strategy for growth, provided such sites are located in villages which already benefit form established supporting transport and social infrastructure and/or where other facilities outside but accessible to the village are readily available.

Great Shelford is one of those settlements where it is benefits from being one of the most sustainably located villages due to its relationship with Cambridge City. It has the clear advantage of having key infrastructure within the village but is also accessible to the wider facilities on offer in Cambridge.

Development at Great Shelford already forms part of the First Proposals Strategy. This principle is agreed and supported. It is appropriate to consider GB release in exceptional circumstances and the village is a strong candidate for accepting more growth. However, the choice of site is not substantiated by the evidence base. We comment on the proposed site allocation in the relevant section S/RRA.

Great Shelford is an appropriate location for growth and this should be maintained in the draft GCLP going forward. Should additional land be required, it remains a suitable place to accommodate more housing to 2041.

In summary, the draft development strategy does not currently reflect a robust spatial strategy that is capable of delivering the stated growth levels during the plan period. The evidence does not clearly show demonstrate that the trajectory assumptions are realistic. Some additional sites will be required to maintain flexibility and Great Shelford is better placed to accommodate additional growth without prejudicing the overall spatial objectives.

Settlement boundaries should be a positive planning tool. The inflexibility that this creates for smaller sites, including those in the Green Belt, to plug the gap to maintain supply targets in the event that delays are experienced at the larger sites. Villages in the green belt are generally relatively more sustainable, particularly at Gt Shelford. Without any safeguarded land being identified, there is still a valid concern that speculative applications could be pursued at less sustainable locations if the housing supply drops below five years during the plan period.

Great Shelford has one site identified for growth.

The supporting maps that form part of the evidence base are incorrect. Figure 43 indicates that the Mingle Lane site in great Shelford is an existing commitment to be carried forward in the GCLP. The site has not been allocated in any previous development plan and is proposed by the authority as a new site to be released from the Green Belt.

GSTA is concerned that the Council has incorrectly logged this site as an historic allocation to be brought forward. This should be rectified immediately. The consultation and evidence base that justifies identifying this site for allocation in the GCLP is misleading.

As a result, there is no express policy text to comment upon for a proposed new allocation at Mingle Lane, Great Shelford. The scale and policy criteria are not stated. Further consultation is required to enable any comments to be lodged against any specific policy proposal for Mingle Land, Great Shelford.

Setting these errors aside, clear evidence is required to show why this site should be identified for release from the Green Belt ahead of other sites at the village edge. The 2021 Green Belt review that has been undertaken for Great Shelford related growth does not support the overall conclusions that Mingle Lane is the most sustainable choice.

In the August 2021 Green Belt Study, release of the Mingle Lane site for development is concluded to cause Moderate/High harm to the GB. This mirrors the previous 2015 Inner Green belt study results. Mingle Lane has consistently been considered perform a strong GB function.

This is in stark contrast to the GSTA site at Cambridge Road (HELAA Site 40413) which has consistently been considered to a neutral/low performing GB role in the 2015 Inner GB study and in the August 2021 update. The latest study continues to support the principle that the release of Cambridge Road site for development would cause the least harm to the Cambridge Green Belt.

HELAA response: Site 40413
A key difference between land off Cambridge Road (ref 40413) and the proposed allocation at Mingle Lane (ref 45545) in the site assessment and selection criteria is the fact that the Cambridge Road Site Access criteria scored ‘red’.

“Site Access- ‘Red’ If over 100 dwellings two points of access are required to accord with the advice of the Cambridgeshire Fire and Rescue. If over 100 dwellings two points of access are required to accord with the advice of the Cambridgeshire Fire and Rescue.”

The HELAA concluded that development off Cambridge Road would have access concerns arising from the uncertainty for achieving a fire access/secondary access for the site. At the Call for Sites stage, copy emails were submitted to the Council to state that the fire officer had no concerns in this regard. This information has not been represented fully in the HELAA.

In many respects the two sites scored similarly. However, in relation to landscape and townscape and historic environment, the Cambridge Road Site scored better. Critically, the proposed Mingle Lane allocation has negative impacts on the conservation area and cemetery.

In relation to accessibility to services and facilities, Mingle Lane site was closer to the Primary School, closer to the village centre and closer to Rapid Public Transport. Whilst this is not disputed, the category only looks inwards to Great Shelford village and does not give any weight to what services are offered across the city border in relation to overall accessibility and connectivity.

The change for the Cambridge Road site to a maximum 100 units to overcome emergency vehicle access concerns will also positively respond to the other HELAA concern that a higher level of development would create a high-density development, unsympathetic to the settlement pattern. The previous density and form conveyed in the previously submitted indicative schemes has been reviewed and we agree that a scheme for up to 100 units would better reflect the site context whilst still constituting an efficient use of land.

HELAA updates: Site 40413
The proposed change to ‘up to 100 units’ for Cambridge Road negates any access concerns going forward and the RAG should be updated to ‘GREEN’. This change will also serve to allay any potential concerns the authority may have on density considerations at the same time. Similarly, this section should now have a RAG rating of GREEN.

We also note that in the HELAA, under the section Green Belt Study, Cambridge Road site states “Parcel ID: TR5; GS25
Very High; Low
This is also incorrect and Very High should be deleted. Site GS25 clearly scored Low in the study.

Having made these updates, the site would clearly score better than Mingle Lane in all aspects other than a narrow accessibility point – being proximity to village services. Whilst this is factually correct, the site submissions to date demonstrate clearly that the Cambridge Road site is locationally more sustainable overall, having regard to the wider context within which the village is located. This includes access to key employment sites and main centre uses. To ignore the immediate surrounding area has artificially skewed the assessment.

Proximity to jobs and main centre uses is a strong positive for Cambridge Road to provide a more sustainable strategy.

There is no clear site selection process contained within the evidence base to justify a Mingle Lane Site allocation rather than another site at Great Shelford and specifically Cambridge Road.

Key Worker Housing:
This is the First Proposals draft and is capable of change. A key consideration for Cambridge Road, is the option to consider specific housing tenure for the site including key worker housing. This type of development was put forward in the Call for Sites 2019 but no further assessment of sites to meet this demand is included within the plan.

Site 40413 is the most connected to the Addenbrookes hub and can offer a wider range of housing tenures.

The First Proposals does not openly address other housing requirements through the draft sites or policies, relying heavily on the lager strategic sites to provide a housing mix to cover key worker and specialist housing. The trajectory assumptions and delivery rates does not positively support the early delivery of key worker housing. As the bulk of the strategic growth is proposed to be located in the ‘towns’ being the former new settlements of Northstowe, Waterbeach and Cambourne, this is not locationally favourable to key workers, for example healthworkers operating shift patterns in the city.

Changes required:
The HELAA should be updated for Site 40413 to change the scale of development to “up to 100 units” as a maximum scale of residential development. The access and density considerations should be updated to reflect this change and shown as Green (which overcomes the negative issues raised).
The Green Belt section should delete ‘Very High; Low’ and just state ‘Low’.

With these changes implemented, the site selection for Great Shelford must be revisited to re-evaluate the alternatives on a fair basis. We consider this would demonstrate that the land at Cambridge Road is the most sustainable option for extending Gt Shelford. It categorically should produce a different outcome, acknowledging that the benefits of developing Mingle Lane should no longer outweigh the GB or heritage impacts when assessed against the alternative options on offer.

In summary, the updated evidence base and necessary re-assessment can only reasonably be considered to support land at Cambridge Road as the most sustainable option for locating additional growth at Great Shelford.

Please see supplementary comments lodged to the Green Belt Study under section GP/GB.

The First Proposals acknowledges that BtR schemes should not provide the full 40% affordable homes and the proposed 20% Affordable private rented dwellings in such schemes is generally supported. The policy should include the option to submit and agree viability assessments where schemes cannot sustain the full policy target.

The categorisation of sites at Great Shelford are supported. Specifically, the continued acknowledgement that the release of HELAA site 40413 at Cambridge Road, Great Shelford would have a negligible/low impact on the function of the Cambridge Green Belt.

It is important that the results of the GB assessment 2021 (as further evidenced by the 2015 Inner Green Belt Study) are fully acknowledged through the HELAA. Where sites have been concluded to cause medium to high levels of harm to the Green Belt if released, these should be protected from development. Exceptional circumstances to release a specific site should not exist in situations where an alternative site at the same settlement has a lower level of harm harm is suitable and available for development.