Greater Cambridge Local Plan Preferred Options

Our client supports broad principles which underpin the stated ‘vision’ and ‘aims’ of the GCLP. Indeed, reducing climate change and minimising carbon emissions are key considerations for the planning system and the wider world. Notwithstanding this in principle support, there is still a need for the GCLP to strike a sustainable balance between focussing on reducing climate change and safeguarding the vitality and vibrancy of existing sustainable villages in South Cambridgeshire.

The ‘vision’ and ‘aims’ of the GCLP are silent on supporting the long-term vitality and vibrancy of rural communities; of which there are many in South Cambridgeshire. The GCLP should encourage proportionate housing growth supported by investment in local infrastructure at established rural sustainable settlements. The ability to strike a balance through the GCLP is entirely possible and appropriate given that a number of established sustainable settlements are served by high quality existing infrastructure which reduces reliance on the private car (bus services, railway stations, Guided Busway and Park & Ride facilities) and could benefit from investment in new sustainable transport infrastructure such as East West Rail and proposals falling out of the Oxford-Cambridge Arc.

The ‘vision’ and ‘aims’ should be amended to make reference to the GCLP “Supporting rural communities to ensure that they thrive, and existing key services are safeguarded by encouraging sustainable and proportionate growth in hand with further investment with community infrastructure”.

The Context for Growth and Innovation

1 Paragraph 16b) of the National Planning Policy Framework (NPPF) states that Local Plans will be found sound if they are ‘positively prepared’. In respect of a Plan’s housing requirement, this means that a Plan must ‘as a minimum’ seek to meet the area’s objectively housing need. Paragraph 61 of the NPPF states that the calculation of an area’s minimum housing need should be informed by a local housing need assessment based on the Government’s standard method for calculating housing need. The same paragraph also goes on to confirms that a local planning authority can pursue an alternative minimum figure which “reflects current and future demographic trends and market signals”.

2 Paragraph 81 of the NPPF seeks that planning policies create conditions businesses can “invest expand and adapt”. Significant weight is placed upon the need to support economic growth, both local business needs and wider opportunities. Particular emphasis and importance is placed upon capitalising on opportunities where “Britain can be a global leader in driving innovation”.

3 In considering the jobs and housing requirement it is of vital importance to place great emphasis on the unique role and characteristics of Cambridge and its surroundings in terms of its international role in innovation and key role in the economy not only for the region, but also the wider UK.

4 The ‘Fast Growth Cities – 2021 and beyond’ (March 2021) evidence base document, prepared by Centres for Cities, identifies Cambridge as part of the ‘The Fast Growth Cities Group’ which encompasses some of ‘the most successful and innovative places in the UK”. The document also goes on to state that “Cambridge is one of the most important research and innovation-led employment hubs in the UK” and that Cambridge has “mature innovation systems in place with different strengths and capacity to benefit the entire UK”.

5 As was the case with the existing Local Plans for South Cambridgeshire and Cambridge City, there is a devolution deal in place between the seven local authorities in Cambridge and Peterborough, with the Cambridgeshire and Peterborough Combined Authority created in 2017. The Council’s ‘Development Strategy Topic Paper’ confirms that the aim is to double economic output within 25 years, with an uplift in GVA from £22bn to over £40bn. The Greater Cambridge City Deal also remains a relevant driver for growth in the area with its ambitions to speed up housing delivering, create 45,000 new jobs and provide £1bn of local and national public sector investment. The City Deal document reminds us that “Greater Cambridge competes on a global stage and is a gateway for high-tech investment into the UK. It is also the innovation capital of the country, with more patents per 100,000 population than the next six cities combined”.

6 Since the previous Local Plans were prepared Cambridge has now become an anchor of the national economic priority area known as the Oxford-Cambridge Arc which encompasses the entirety of the Cambridge City and South Cambridgeshire districts. The National Infrastructure Commission’s 2017 report “Partnering for Prosperity: a new deal for the Cambridge-Milton Keynes-Oxford Arc” confirmed that the Arc is home to some of the most productive and fast-growing cities and “has significant potential for transformative growth”. The Ministerial Foreword to ‘The Oxford-Cambridge Arc: Government ambition and joint declaration between Government and local partners’ (March 2019) cites that the Arc is an economic asset of “international standing” and is a place that provides the best of British business and innovation for the benefit of local communities and the wider country.

7 Central to the Arc realising its full potential and Cambridge fulfilling its role as a key anchor of the Arc is the delivering of new housing and infrastructure to complement and support economic growth. Indeed, significant investment has already been made in improving transport infrastructure with the completion of the A14 improvements between Huntingdon and Cambridge and in planning for the East West Rail route between Bedford and Cambridge. There is significant momentum behind planning for the economic prosperity of Cambridge and the surrounding area.

8 The July 2021, ‘Creating a vision for the Oxford-Cambridge Arc’ consultation document published by the Government states the following regarding housing supply in the Arc,

“We are concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.”

9 The consultation document confirms that a Spatial Framework will be developed to provide national planning policy for the Arc area. However, it is clear that Development Plans and local planning authorities will still have an important responsibility to bring forward Local Plans which deliver enough housing to support the four overarching policy pillars of the Spatial Framework: “the environment, the economy, connectivity and infrastructure and place-making”.

Employment Forecasting and Housing Growth

10 In the preparation of the GCLP there is great responsibility on the Councils to prepare a Plan which supports and complements Cambridge’s and the Arc’s national and international role in innovation and business. In addition, the GCLP can also plan positively to achieve economic growth whilst taking advantage of its excellent public transport links and the future benefits of East West Rail. The GCLP should embrace this opportunity of international importance and plan positively for housing to support significant levels economic growth, with residents in the area standing to benefit increased high quality employment opportunities and the committed investment in major transport infrastructure projects.

11 The Council’s Development Strategy Topic Paper (DSTP) summaries the approach the Councils have adopted to define the proposed GCLP housing requirement, drawing upon evidence base studies produced by GL Hearn. The GCLP evidence base indicates that standard method requirement figure for the GCLP area, without accounting for employment forecasting, is 36,600 dwellings. This housing requirement would support the creation of 45,800 jobs. Given the economic growth and investment in the area, and the provisions of the NPPF the Councils have undertaken further economic forecasting to establish potential jobs growth figures and the level of new housing needed to support this growth. The principle of this approach is supported by our client.

12 The Councils are choosing to support the central jobs forecast scenario in the preparation of the GCLP as set out in the Housing and Employment Relationship Report (November 2020) (HERR). This forecast results in a need to plan for 58,500 new jobs in the area over the plan period 2020-2041 and is based on long term patterns of employment continuing, with the year-on-year growth in jobs comparable to that experienced between 2001-2017 and 1991-2017. To support the central level of employment, the GCLP puts forward a medium housing requirement of 44,400 dwellings over the plan period.

13 The HERR also provides an alternative higher jobs forecast which has not been taken forward by the GCLP. The higher forecast could deliver 78,700 jobs over the plan period, this equates to an additional 20,200 jobs when compared to the medium jobs forecast pursed by the GCLP First Proposals. This forecast places greater weight on the fast growth experienced in the recent past, with the year on year growth in jobs higher than that seen between 2001-17 and 1991-17, but lower than the ‘fast growth’ period of 2010-17. To support 78,700 new jobs the GCLP would need to propose a housing target of 56,500 dwellings, 12,100 more dwellings than currently proposed in the GCLP First Proposals. Given the level of investment and momentum behind growth initiatives and funding in Cambridge we consider more likely that the faster growth in recent past will continue, rather than defaulting back to long term employment patterns continuing. Cambridge and its immediate environs has entered a new era of investment and growth.

14 Paragraph 5.22 of the HERR recommends a preferred range “between a central and higher growth scenario” to plan for employment change in Greater Cambridge. Notwithstanding this recommendation, the higher growth option is dismissed by the Council’s in the DSTP, with this option considered as “possible but not the most likely”. This conclusion is based on the “implication from wording in the Employment Land Review regarding the central scenario”. This wording is assumed to be that set out at paragraph 5.22 of the HERR which states that “all economies experience peaks and troughs, with the position at 2017 considered to be a peak or near peak. As a result the most realistic position by 2041 is one which sees outcomes fall back towards the longer term historic year on year absolute change”.

15 It is noted that ONS figures show that between 2000 and 2019 jobs in Cambridge city increased from 93,000 to 123,000, this equates to an average job increase of 1,000 per year. For the period 2014-2016 the job creation growth is reported at exactly 1,000 jobs per year. In the period 2017-2019 job creation increased by 5,000 which equates to an average of 1,666 jobs per annum. Accordingly, since the year considered above to be the ‘peak or near peak’ job creation in the city has not only increased, but it has also increased at a greater average rate than the proceeding period.

16 Job density (total jobs to population) in 2019 was at 1.41, a significant increase on the 1.33 ratio in 2017. Clearly there is a great need to rapidly and significantly increase housing supply in Greater Cambridge to support the current number of jobs in the city. To demonstrate the strong and unique nature of the Cambridge city economy, by comparison in 2019, job density was at a rate of 0.86 in the Eastern region and 0.87 in Great Britain.

17 In light of the recommendations of the HERR, the unique characteristics of Cambridge and the NPPF’s focus on planning policies supporting economic growth and driving innovation it is contended that the GCLP should be seeking to ensure that it is capable of supporting greater economic growth than currently proposed. The HERR recommends pursing a jobs target of between 58,500-78,700 a range of some 20,200 jobs – equivalent to 12,100 additional homes. This range is vast given the importance of the issue and the need for planning policies to be flexible and respond to changing circumstances (NPPF paragraph 33). The higher jobs growth should be planned for or as a minimum further work is required by the Councils to identify an appropriate point within this range for the GCLP to positively plan for. There is significant political, planning and investment momentum behind the economic growth of Greater Cambridge with this momentum set to continue in the 2020-41 plan period. This momentum should be supported by a GCLP which fully embraces the opportunity to deliver economic growth of national importance to support the innovation and science employment sectors which are of acknowledged international significance.

Neighbourhood Planning

18 Paragraph 66 of the NPPF makes it clear that strategic planning policies should identify the housing requirement for a designated Neighbourhood Plan Area. The First Proposals document confirms that the GCLP intends to include a policy which would see Neighbourhood Plans contributing towards meeting windfall housing numbers, with the Councils identifying an indicative housing requirement on an informal basis as when a Neighbourhood Plan Area is designated (or assumed when an existing Neighbourhood Plan is reviewed).

19 This approach in part aligns paragraph 67 of the NPPF which seeks a local planning authority to provide an indicative housing figure. However, as explained in Footnote 33 of the NPPF this approach is only needed when strategic housing policies are out of date or a Neighbourhood Plan Area comes forward after strategic policies have been adopted.

20 The GCLP should be allocating a proportionate housing requirement to established sustainable settlements, particularly those which have a Neighbourhood Plan or are a designated Neighbourhood Plan Area. It should also make it clear that the adoption of the GCLP will trigger the need to review adopted Neighbourhood Plans to assist in meeting housing need at sustainable settlements. This will allow rural communities to thrive and plan proactively and positively for their futures. As set out in our representations on Policy S/DS: Development Strategy it is vital that GCLP pursues a balanced spatial strategy which provides housing choice and benefits all sustainable communities.

21 The proposed approach to Neighbourhood Planning does not comply with the policies of the NPPF (paragraphs 66 and 67) and shines a light on a significant flaw in the proposed spatial strategy in respect of supporting established rural communities and the rural economy (paragraph 84 of the NPPF).

Spatial Strategy

1 Paragraph 20 of the National Planning Policy Framework (NPPF) requires strategic policies to set out an overall strategy for the pattern, scale and design quality of places to deliver housing (including affordable housing).

2 Page 29 of the First Proposals document that development strategy for the GCLP “is to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.”

3 In the context of the above statement, it is important to note that Greater Cambridge possesses a network of established sustainable settlements, such as Histon & Impington, which are well served by a wide range of shops and services, significant employment and education opportunities and highly sustainable transport links to the city and beyond. Histon & Impington is unquestionably a sustainable settlement capable of accommodating proportionate growth whilst reducing the impact on climate change. Histon and Impington is to continue its position in the settlement hierarchy as “Rural Centre” a Tier 2 (out of 5) settlement.

4 As set out at page 43 of the First Proposals document Greater Cambridge possess an excellent range of existing public transport connections, with new investment and projects coming on stream now and throughout the Plan period. The existing Guided Busway, bus network, rail network and numerous Park & Ride facilities allow the Councils the opportunity to identify new housing allocations at established rural settlements which benefit from convenient access to these sustainable travel measures. Indeed, the Councils confidence in making sustainable allocations in rural areas should be further enhanced through the investment in other proposed public transport initiatives such as East West Rail, Travel Hubs, further Park & Ride facilities and the new multi modal link to Cambourne. Page 44 of the First Proposals document contends that the proposed development strategy is “heavily informed by the location of existing and committed public transport schemes”.

5 The development strategy pursued by the GCLP is described as a “blended strategy” taken from the development strategy in the adopted Local Plans and four new strategy choices. The blended strategy covers the following: Cambridge urban area, edge of Cambridge, new settlements, villages, public transport corridors, providing homes close to jobs in research parks to the south of Cambridge, integrating development with infrastructure improvements to the west of Cambridge and a further hybrid option which involves Green Belt release.

6 The GCLP contends that this blended strategy will make “best use of existing and committed key sustainable transport infrastructure” and support “rural communities to thrive and sustain services”. In respect of specifically planning for the rural area of Greater Cambridge the development strategy proposes a “a very limited amount of development” at small sites at villages which have “very good public transport access”. The First Proposals document does not define “very good public transport access”. In terms of making specific new allocations in the rural area the GCLP makes a “limited number of new sites for housing at our more sustainable villages”. In this regard, we wish to highlight that Histon & Impington is only separated from the urban area of Cambridge by the A14 and thus has excellent physical and public transport links to the city.

7 To meet the housing need target proposed by GCLP (44,400 dwellings + 10% buffer) the First Proposals document states that there are 37,200 dwellings in the current supply comprising planning permissions, existing allocations and windfall allowance. This leaves a need to identify sites to deliver 11,640 new dwellings. A total of 224 dwellings are proposed for allocation in the rest of rural area, across sites in Melbourn (x2), Caldecote and Oakington. Melbourn is a “Minor Rural Centre”, with Caldecote and Oakington being “Group Villages”, tiers 3 and 4 of the Settlement Hierarchy. Of the new dwelling allocations proposed by the GCLP only 1.9% are directed towards the rest of rural area. This figure rises to 3.2% if the housing delivery associated with supporting jobs at research parks to the south of Cambridge is included.

8 Figure 10 of the First Proposals documents states that 18% of the total housing growth (including existing allocations, planning permissions and windfall allowance) will be directed to the rural area through the GCLP. The 18% is a 5% reduction on growth afforded to rural areas through the current adopted Plans and a 12% drop on the old Structure Plan.

9 It is contended that the blended development strategy and approach to making new allocations will not facilitate the delivery of thriving rural communities or sustain key services over the plan period, supposed aims of the strategy and the GCLP. The blended strategy results in a rather confused and contrived approach to making new housing allocations heavily reliant on strategic sites and New Settlements. The approach taken to allocating new sites for housing in rural settlements appears to be led by the availability of the Councils preferred available sites, rather than one which focuses allocations on the most sustainable settlements and capitalising on the sustainability and climate change benefits provided by existing and proposed public transport infrastructure. Rural Centres such as Histon and Impington are not afforded any new housing growth, with the GCLP instead identifying allocations at lower ranking settlements in the hierarchy. There is no clear rationale provided as to why the development strategy focuses on these lower ranking settlements and seemingly dismissing the prospect of making new allocations at more sustainable settlements. In addition, there is no clear rationale provided as to why growth has been directed to the selected Minor Rural Centre and Group Villages, and not other settlements in the same classification.

10 As stated above, the GCLP will deliver only 3.2% of housing at new allocations in the rural area. Evidently this is not a balanced and flexible strategy which supports established sustainable rural communities. The proposed strategy also stifles the role of Neighbourhood Planning in Greater Cambridge by not allocating specific levels of growth to guide the review of or preparation of Plans in designated Neighbourhood Plan Areas which possess an established sustainable settlement. The approach to guide Neighbourhood Plans by identifying indicative levels of growth from Windfall numbers is not a sound or robust way to proceed.

11 The First Proposals document and accompanying evidence base aims to support rural communities and sustain their existing service provision, but its current approach to making new housing allocations and Neighbourhood Planning will clearly not deliver on this aim. The approach taken to allocating the limited growth in rural areas is site led, disregards the settlement hierarchy, sustainable transport connections and the aim of GCLP which is to locate development in the most sustainable locations to reduce the impact of climate change. Over the plan period the blended development strategy will see the stagnation of sustainable settlements in the rural area through the failure to deliver housing choice (market and affordable) which in turns supports rural businesses and services and the vitality of key rural infrastructure such as bus routes, GPs and schools. The proposed development strategy is not robust and thus unsound in its approach to delivering proportionate and sustainable growth in rural areas.


Housing Supply

12 The NPPF requires local planning authorities to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to their objectively assessed housing need. Paragraphs 60 and 68 of the NPPF make specific reference to the need for a mix and variety of land to be identified for housing.

13 The First Proposals document sets out that 96.5% of new dwelling allocations are proposed at sites which have a capacity of 750 dwellings or more. New Settlements are proposed to provide 38% of the total housing growth over the plan period (existing and new allocations), this is a 15% rise on the current adopted Plans and a 20% rise on the old Structure Plan.

14 The Development Strategy Topic Paper provides the current Housing Trajectory as of April 2021. The existing Northstowe new settlement allocation delivers new housing at a range of 204-365 dwellings per annum between 2020/21 and 2025/26, before dropping to 250 dwellings per annum for the rest of the plan period. The existing Waterbeach new settlement allocation is scheduled to commence housing delivery in 2022/23 at 80 dwellings per annum before rising to 250 dwelling per annum for the rest of the plan period. The GCLP carries forward these existing new settlement allocations and seeks to increase housing delivery at both sites by an additional 50 dwellings per annum from 2026/27 all the way through to 2040/41. Accordingly, both new settlements will be required to deliver dwellings at 300 dwelling per annum for a 15-year period. This increased delivery accounts for 13% of new housing growth proposed to be allocated by the GCLP (1,500/11,596),

15 The four proposed new allocations in Cambridge urban area and the edge of Cambridge account for 67% (7,762/11,596 dwellings) of the new allocated growth through the GCLP.

16 It is acknowledged that the allocation of new settlements and large-scale strategic sites can form a key part of a balanced spatial strategy to bring forward sustainable growth in a district. However, the approach put forward by the Councils does not represent a flexible and balanced approach capable of responding to changing circumstances (NPPF paragraph 33) or providing a mix and variety of sites. Furthermore, the per annum housing delivery targets for the new settlements are very high, particularly at Waterbeach which is yet to deliver dwellings. Bringing forward new settlements and large strategic sites is a complex process which often requires the delivery of significant up-front infrastructure which can sometimes be subject to different funding mechanism and complex land ownership constraints. These issues often impact and delay the delivery of strategic sites, accordingly, the GCLP needs to allocate a variety of different types of sites. The delays in delivery of new settlements in the Greater Cambridge area, along with the necessary strategic infrastructure are well documented and there continues to be a significant lag in the delivery of new homes required at these locations. There is nothing within the proposed plan that provides comfort that these issues will be satisfactorily resolved.

17 Over the current plan period and historically in Greater Cambridge there has been significant pressure placed upon the five-year housing land supply. This in part is due to the current over reliance on strategic sites and failure to allocate proportionate growth at established rural settlements which have fewer delivery constraints. Accordingly, promoting a more balanced development strategy will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP and Neighbourhood Plans should take the lead by positively planning for new housing at established sustainable rural settlements rather than being subject to future speculative development proposals at sites not allocated in a Local Plan when there is a deficit in supply across the plan area.

Windfall Sites

18 To deliver the Councils current proposed objectively assessed needs figure the First Proposals document states that 5,345 of this need will be met by Windfall Sites. This is an increase on 1,125 dwellings on the current adopted Plans. Accordingly, 11% of the total housing need (44,400 – plus a 10% buffer) over the plan period will be met by Windfall Sites and 9.7% (1,125/11,596) of the new housing growth proposed by the GCLP is accounted for by Windfall Site.

19 The Development Strategy Topic Paper explains that the increase in Windfall rates is because the Windfall figures associated with adopted Plans has proven to be an underestimate. It is contended that the new Windfall figure is very high and that an increase is not necessary. Windfall levels in Greater Cambridge are artificially high because of the extended period in the previous decade where a large number of speculative development proposals were approved in a period when the Councils were unable to demonstrate a five-year housing land supply. The significant number of permissions granted in this period are now being delivered and has led to the inflation in Windfall numbers. Many of these permissions, some delivered at appeal, recognised the important role other sustainable settlements can play in delivering housing need and supporting vital local services. This is not recognised in the emerging plan and settlements close to Cambridge and with excellent connectivity are well placed to support the plans wider growth aspirations.

20 The GCLP can plan positively and sustainably by re-allocating windfall numbers to make allocations at established rural settlements or by assigning an overarching housing target to designated Neighbourhood Plan Areas (which contain a sustainable settlement). This approach will assist in guarding against future drops in five-year supply and allow the Council and Neighbourhood Plan Groups to take the lead in planning positively for new housing whilst being mindful of the challenges of climate change.

21 The 10% buffer to be applied to the proposed objectively assessed housing need amounts to 4,400 dwellings. This buffer is largely accounted for by the total Windfall allowance of 5,345 dwellings. Accordingly, it is contended that the 10% is not a true buffer as it is largely accounted for by dwelling numbers which aren’t allocated at specific sites or settlements.

Water Supply Infrastructure

22 The First Proposals document and associated evidence base outline that there is a need for new strategic water supply infrastructure to support growth proposals and to protect the integrity of the chalk aquifer south of Cambridge. It is understood that Water Resource East will publish its Water Management Plan for the region (covering the period to 2050) in 2022. This Plan will likely include significant new infrastructure in the form of a new Fenland reservoir which will be available to supply water from the mid 2030’s.

23 It is noted that the ‘GCLP Integrated Water Management Study) (November 2020) (IWMS) states that higher growth option is not compatible with the planned delivery of new water supply infrastructure. The central growth scenario is considered achievable from a water supply perspective subject to regional scale water supply solution being operational by the 2030s. In this regard the DSTP states that “evidence in November 2020 had indicated that there may be potential for interim measures to support the medium growth level and potentially more, but that the maximum growth level was not possible”. These conclusions further heighten the need for the Councils to undertake further employment forecasting work to identify an appropriate point with the central and higher growth ranges set out by the HERR.

24 The IWMS and DSTP refers to interim measures being available to support growth in the short to medium term of the plan period, however, it is unclear from the published evidence as to what extent these interim measures are being examined and scrutinised as options to assist in the delivery of growth over the short to medium term of the plan period.

25 Whilst continuing to pursue this key matter with Government and the relevant authorities significant work needs to be undertaken to further identify and programme practical interim solutions to overcome this potential constraint to growth in the area. The need to programme interim measures to a specific timescale will become vital in the eventuality that a stepped approach to housing delivery is required to overcome this constraint.

1. Paragraph 140 of the NPPF confirms that Green Belt boundaries should only be altered where exceptional circumstances can be demonstrated as part of the preparation of a Local Plan. The preparation of the GCLP provides the opportunity for the Councils to consider undertaking a review of the Cambridge Green Belt in the context of the challenges and opportunities facing the area in respect of delivering housing and employment growth, whilst also reducing climate change.

2. Over the plan period and beyond, significant investment and growth will come forward in Greater Cambridge. The HERR recommends pursing a jobs target of between 58,500-78,700 a range of some 20,200 jobs – equivalent to a potential 12,100 additional homes on what is proposed in the First Proposals document. The growth of Greater Cambridge is driven by the following initiatives:
• The Greater Cambridge City Deal seeks to speed up housing delivering, create 45,000 new jobs and provide £1bn of local and national public sector investment.
• The Cambridge and Peterborough Combined Authority (CPCA) have confirmed that due the high levels of growth and ‘exceptional’ housing market conditions in Greater Cambridge, the Government will provide £100m housing and infrastructure fund to help deliver infrastructure for housing and growth and at least 2,000 affordable homes.
• The CPCA have confirmed that Central Government are to provide an additional £70m ring fenced for Cambridge to help meet the ‘exceptional’ housing needs of the city.
• The CPCA anticipate that economic output will increase by 100% over the next 25 years. The GVA of the area is estimated to increase from £22bn to over £40bn.
• Cambridge City and South Cambridgeshire anchors the eastern end of the Oxford-Cambridge Arc as defined by Central Government in March 2019. The Government have stated that the Arc area is an economic asset of international standing and can be influential to the performance of the national economy. The National Infrastructure Committee (NIC) found the Arc area to be home to UK’s most productive and fast-growing cities and has significant potential for transformative Growth. However, the growth and opportunity in this area is currently constrained by poor east-west infrastructure and a lack suitable housing. The Arc initiative aims to realise the full economic potential of the area by delivering significant new infrastructure and building up to 1 million new homes by 2050.

3. To accompany and support economic growth in Greater Cambridge the following major infrastructure improvements are either being planned or have started:
• The A14 road improvements between Huntingdon and Cambridge - Completed
• A new railway station close to Addenbrookes Hospital to the south of the city centre - Expected completion date 2025
• The duelling of the A428 between Black Cat Roundabout and Caxton Gibbet - Expected completion date 2026
• The delivery of East-West rail, which includes a Phase 3 link running between Bedford and Cambridge - Expected completion date 2030. As with the Black Cat to Caxton Gibbet A428 road improvements, the delivery of East-West forms key elements of Oxford-Cambridge Arc.

4. In light of all of the above Martin Grant Homes consider that there is a set of exceptional circumstances which clearly justifies Green Belt release as a spatial strategy. The Cambridgeshire Green Belt was defined many years ago and the opportunity can now be taken through the preparation of the GCLP to refresh those existing Green Belt boundaries. A strategy to release appropriate sites from the Green Belt, is supported by:
• The immediate need to deliver housing growth in order to support the aims and objectives of the Greater Cambridge City Deal and the Oxford-Cambridge Arc.
• The need to deliver economic growth in Greater Cambridgeshire, which is of national importance to the UK economy and international importance to the innovation and education sector
• The requirement for the planning system to deliver all three dimensions of sustainable development (Paragraph 8 of the NPPF);
• The need for Plans and decisions to take into account local circumstances in order to achieve sustainable development (Paragraph 9 of the NPPF);
• The need for the planning system to be genuinely plan led (Paragraph 15 of the NPPF); and
• The need to ensure that planning proactively drives and supports sustainable economic development to deliver the homes, employment opportunities and thriving local places that the country needs (paragraph 82 of the NPPF)

5. The scale of economic and housing growth required in Greater Cambridge, as recommended by the HERR, is unlikely to be delivered in a sustainable manner without the suitable and evidenced release of Green Belt land. Accordingly, MGH welcomes and endorses the Councils decision to undertake a review of Green Belt boundaries as part of preparing the GCLP.

6. Page 39 of the First Proposals document states that the Councils do not consider that housing need alone provides exceptional circumstances to justify removing land from the Green Belt. MGH agrees with this conclusion as there is a broader and compelling case for exceptional circumstances in this case relating to economic growth and the unique circumstances and opportunity that Greater Cambridge is presented with.

7. The First Proposals documents seeks to make only one limited Green Belt release to support the development and growth of the Cambridge Biomedical Campus. MGH contend that the opportunity and indeed need to make further limited and specific Green Belt release extends beyond this one site.

8. Paragraph 142 of the NPPF confirms that when reviewing Green Belt boundaries local planning authorities need to promote sustainable patterns of development. The NPPF goes on to states that “where it is has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously development and or is well-served by public transport”.

9. Paragraph 143 advises that the definition of Green Belt boundaries should ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development and not include land which it is unnecessary to keep permanently open. The GCLP is shaped by the requirement to meet housing needs, which we contend should be higher and align with the recommendations of the HERR. It is also contended that the current Development Strategy is not sound or robust in its approach to promoting a balanced and flexible housing supply and ensuring rural communities will thrive and sustain their existing service provision over the plan period.

10. To remedy the above-described flaws it is contended that housing growth should be distributed to established sustainable rural settlements which possess excellent public transport links. Having established that there is a compelling case for exceptional circumstances in Greater Cambridge there is a clear case to support small and focused Green Belt releases. Green Belt sites in combination with delivering other non-Green Belt sites will make a material contribution to meeting objectively assessed housing need, accommodating economic growth and delivering a flexible and balanced Development Strategy.

11. MGH are promoting ‘land at Ambrose Way, Impington’ for release from the Green Belt and subsequent allocation for residential development through the GCLP preparation process. Having set out our case that there is a need for further limited and specific Green Belt release it is now necessary to establish how the site itself meets the five purposes of Green Belt as set out at paragraph 138 of the NPPF. To this end MGH have commissioned consultant EDP to review findings of the Council’s Green Belt Study prepared by consultants LUC. In addition, EDP have also undertaken their own review of the site in the context of paragraph 138.

12. The EDP Green Belt Appraisal (GBA), is appended to these representations and evidences the following conclusions in respect of the Ambrose Way site’s contribution to the Green Belt purposes:
- Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/Moderate.
- Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/No contribution
- Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate.
- Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as No Contribution.
- Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a.

13. The detail underpinning the above listed conclusions is evidenced in the submitted GBA document. In light of the specific assessment against each Green Belt purpose the GBA provides an overarching conclusion which confirms that the Ambrose Way site provides a low contribution to the NPPF Green Belt purposes. In respect of bringing forward development at the site the Appraisal concludes that,
“development can occur in this location without compromising the fundamental aims of the NPPF to keep land permanently open and while continuing to serve the five of Green Belt at this northern edge of Histon and Impington; primarily to check the unrestricted sprawl, prevent merging of settlements and safeguard the countryside from encroachment.”

14. Paragraph 140 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional circumstances. Martin Grant Homes believe that exceptional circumstances exist to justify making limited and site-specific modifications to the Green Belt in order to deliver housing and employment sites needed to meet the needs of Greater Cambridge. Indeed, such modifications will allow a sustainable Development Strategy to come forward which will deliver a varied, flexible and robust housing supply and spread the benefits arising from sustainable development to rural areas, which in the main are not currently supported by the GCLP First Proposals.

15. The proposed distribution of new growth and allocations via the GCLP is a fundamentally flawed and will not deliver a varied, flexible and robust housing supply or spread the benefits arising from sustainable development to rural areas.

16. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for development. It is strongly contested that this is the case for the Land at Ambrose Way, Impington. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out at paragraph 8 of the NPPF and assist in supporting economic growth which is of regional and national importance.

1. The settlement of Impington and Histon is located immediately to the north of Cambridge and lies within South Cambridgeshire. Its proximity to the city has the consequence of it functioning as part of the wider city urban area. Policy S/8 of the adopted Local Plan (2018) identifies Histon and Impington as a Rural Centre, this designation is to be carried forward through the GCLP. Rural Centres are classed as the largest, most sustainable villages in Greater Cambridge and are only behind Cambridge and New Settlements in the proposed GCLP Settlement Hierarchy. Indeed, as set out in the submitted Site Promotion Document (SUBMITTED WITH UPDATED CALL FOR SITES FORMS) , the settlement possesses a wide range of shops, services, infrastructure, employment opportunities and public transport links. Our client supports and endorses Histon & Impington’s status as a Rural Centre and this designation should be continued in GCLP.

2. Whilst adopted and proposed policy approach resists development outside of the settlement boundary at Rural Centres, there is no development limit (in terms of no. of dwellings) for sites within the settlement boundary. This policy reflects the positive sustainability credentials of Rural Centres such as Histon & Impington.

3. As set out in our representations on the Development Strategy, sustainable settlements in rural areas have an important role to play in accommodating growth to allow for a flexible and varied supply to be development and to ensure established settlements continue to grow incrementally and thus support the long-term vitality of local services upon which residents rely. The level of growth afforded to each sustainable settlement should be based on:
- Size of the current settlement;
- Service provision and any planned improvements to local community infrastructure such as schools;
- Access to Cambridge Bus Way and rail links;
- Access to high quality local bus services;
- Access to employment opportunities
- Proximity to Cambridge
- Proximity to key public transport corridors

4. As set out in our submitted Site Promotion Document Histon and Impington performs exceptionally well in respect of these key criteria. It is of vital importance that the Councils adopt a highly flexible approach to directing growth to the edge of sustainable villages in the emerging GCLP; especially the Rural Centres, such as Histon & Impington, which have sound and robust sustainability credentials.

1. Section 2.6 of the First Proposals document states the Councils “want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services”

2. As set out in detail in our representations on Development Strategy, the approach put forward in the First Proposals document will not deliver the above stated aim. The proposed distribution of new growth and allocations via the GCLP is fundamentally flawed and will not deliver a varied, flexible and robust housing supply or see the benefits arising from sustainable development reaching established and sustainable rural settlements.

3. MGH objects to the use of the terminology, “where car travel is the easiest or only way to get around”. The use of the word “easiest” in this context is inappropriate and does not represent an objective or robust approach to determining the distribution of growth. The easiest or most convenient travel option available to a person will depend on the specific circumstances of that individual. In terms of promoting sustainable travel patterns, the distribution of development should be based on the quality and frequency of public transport connections serving a settlement; and the settlement’s proximity to larger hubs or urban areas.

4. MGH are promoting ‘Land at Ambrose Way, Impington’ (HELAA Ref: 40392) for removal from the Green Belt and subsequent allocation for residential development. MGH welcomes the publication of the HELAA review which appraises the development potential of the site. However, MGH has noted a number of specific technical flaws in the published appraisal which should be remedied as the GCLP preparation continues.

5. To aid the preparation of these representations a Masterplan for the site has been prepared, along with a number of supporting Technical Notes. The Masterplan and the Technical Notes are summarised and provided in the Site Promotion Document appended to these representations.

6. In light of our review of the HELAA appraisal and the Technical Notes we attach as a separate sheet a schedule of the HELAA inaccuracies and recommended amendments.

(SEE ATTACHED SHEET)

7. Updated Call for Sites Forms have also been submitted to explain and evidence the latest technical work completed by MGH.

8. Providing that a rural settlement has strong sustainability credentials in terms of public transport links, employment opportunities, social infrastructure, shops and services it is abundantly possible to bring forward proportionate levels of new sustainable development. It is contended that bringing forward development at Rural Centres such as Histon & Impington is as sustainable as bringing forward growth at New Settlements which have a similar service provision / planned service provision. The service provision at Histon & Impington is set out in the submitted Site Promotion Document.

9. This set of representations has also demonstrated that the proposed GCLP Development Strategy is flawed in its approach to supporting economic/jobs growth, providing a flexible and varied housing supply and supporting the long-term vitality of established sustainable rural settlement. The representations have also confirmed that there is a compelling package of exceptional circumstances which justifies the focused release of land from the Green Belt.

10. In reviewing and amending the GLCP’s overall housing need requirement, development strategy and the need for additional focused Green Belt releases it is strongly recommended that our client’s site is allocated for residential development and the Green Belt boundary modified to facilitate this. The ‘Land at Ambrose Way’ is a suitable and deliverable site with very limited development constraints (which can be overcome through planning conditions and careful design) and is located at a settlement which is a designated Rural Centre and is an inherently sustainable location for new proportionate growth.

5.1 The GCLP First Proposals Sustainability Appraisal (SA) was published in August 2021. The purpose of the SA is to promote sustainable development through integrating sustainability considerations into the preparation of plans. It is an integral part of good plan making and an ongoing process, involving continuing iterations to identify and report on the potential social, economic and environmental effects of the Local Plan.
The SA contains an assessment of the potential impact that site allocation options could have on a range of predefined social, economic and environmental objectives, set out during the SA scoping process. For the GCLP, the following objectives have been defined:
SA 1: Housing - To ensure that everyone has the opportunity to live in a decent, well-designed, sustainably constructed and affordable home.
SA 2: Access to services and facilities - To maintain and improve access to centres of services and facilities including health centres and education.
SA 3: Social inclusion and Equalities - To encourage social inclusion, strengthen community cohesion, and advance equality between those who share a protected characteristic (Equality Act 2010) and those who do not.
SA 4: Health - To improve public health, safety and wellbeing and reduce health inequalities.
SA 5: Biodiversity and geodiversity - To conserve, enhance, restore and connect wildlife, habitats, species and/or sites of biodiversity or geological interest.
SA 6: Landscape and townscape - To conserve and enhance the character and distinctiveness of Greater Cambridge’s landscapes and townscapes, maintaining and strengthening local distinctiveness and sense of place.
SA 7: Historic environment - To conserve and/or enhance the qualities, fabric, setting and accessibility of Greater Cambridge’s historic environment.
SA 8: Efficient use of land - To make efficient use of Greater Cambridge’s land resources through the re-use of previously developed land and conserve its soils.
SA 9: Minerals - To conserve mineral resources in Greater Cambridge
SA 10: Water - To achieve sustainable water resource management and enhance the quality of Greater Cambridge’s waters.
SA 11: Adaptation to climate change - To adapt to climate change including minimising flood risk.
SA 12: Climate change mitigation - To minimise Greater Cambridge’s contribution to climate change
SA 13: Air quality - To limit air pollution in Greater Cambridge and ensure lasting improvements in air quality.
SA 14: Economy - To facilitate a sustainable and growing economy.
SA 15: Employment - To deliver, maintain and enhance access to diverse employment opportunities, to meet both current and future needs in Greater Cambridge.

5.2 The SA contains an appraisal of the various spatial options proposed for the Local Plan, with detailed analysis provided at the Strategic Spatial Options level and at a site level.
5.3 The Land north of Cambourne is included within the ‘Growth around transport nodes’ Strategic Spatial Option (Option 8), and the SA finds that this option performs at least as well as, if not better than, the other Strategic Spatial Options for the listed SA objectives.
Table 5.1 : SA Non-Technical Summary Table 3: Summary of SA effects for Strategic Spatial Options 2020-2041

5.4 Key issues here relate to SA 14 (Economy) and SA 15 (Employment). As discussed above, the provision of extensive employment space and supporting community facilities will provide benefits for both these objectives, as well as linking residents of Cambourne with employment opportunities elsewhere in the district following the implementation of EWR and C2C.
5.5 Adaptation to climate change (SA 11)., specifically flood risk, is also highlighted as an issue with a negative impact. However, as stated above, the Land north of Cambourne is within Flood Zone 1, and is therefore at a low risk of flooding. Although some isolated pockets of surface water flood risk exist on site, which can be mitigated effectively through SuDS interventions incorporated within the public open spaces.
5.6 At a more detailed level, the comparison of the SA objectives is provided for each site within the Strategic Spatial Option. The table below is reproduced from the SA:
Table 5.2: Table 4.22: Summary of SA findings for the Growth around transport nodes: Cambourne Area site options
5.7 A comparison of the sites presented above, indicates that the Land north of Cambourne performs better than any of the other sites, when SA objectives are combined, with the Site performing at the highest level in relation to other sites for:
SA 2 (Access to services and facilities)
SA 12 (Climate change mitigation)
SA 15 (Employment)

5.8 The objectives for which the Site is marked with a negative impact compared with other sites include
SA 5 (Biodiversity and geodiversity)
SA 6 (Landscape and townscape)
SA 7 (Historic environment)

5.9 Following the publication of the SA, a number of additional studies have been carried out to demonstrate that the impacts referred to above can be mitigated through good design and urban planning. The illustrative masterplan for the Site has therefore been updated to account for this most recent information as well as relevant mitigation measures.
5.10 A summary of the relevant impact and mitigation studies is provided below, with additional information provided in accompanying technical reports.
Biodiversity and geodiversity
5.11 North Cambourne contains the Elsworth Wood SSSI, the Knapwell Wood ancient woodland, and is adjacent to the Brockley End Meadow County Wildlife Site. It also contains areas of deciduous woodland which have been classed as priority woodland, along with ditches, watercourses, grasslands, hedges and wooded boundaries that are also likely to have ecological value.
5.12 The illustrative masterplan contained in the vision document shows how the features identified as being of greatest ecological value will be retained. These features will be protected and enhanced during the construction and operation of phases of the proposal, with suitable measures employed to ensure relevant species and habitats are protected in accordance with relevant Natural England guidance pertaining to SSSIs.
5.13 The guidance for the Elsworth Wood SSSI and the associated Impact Risk Zone states that, ‘New housing developments will require an assessment of recreational pressure on relevant SSSIs and measures to mitigate adverse impacts.’
5.14 As shown in the illustrative masterplan, considerable areas of North Cambourne will be dedicated to recreational open space, with approximately two-thirds of the site area retained as open space. This level of provision will ensure that there will be no additional recreational pressure placed on the SSSI. In addition, no built development is proposed within 250m of the SSSI, providing ample buffer space to mitigate potential impacts during construction and operation.
5.15 To ensure the protection of the most sensitive habitats, the illustrative masterplan shows considerable buffer zones around other ecological sites of interest. The Forestry Commission and Natural England recommend a 15m buffer zone around woodlands to avoid root damage during development. The masterplan has been developed to provide a 25m buffer zone around the woodland, exceeding recommended distances and further mitigating impacts.
5.16 In addition, the scale of the site is such that there is sufficient land available to accommodate significant new planting and thereby enhance woodland coverage. Furthermore, the masterplan shows an integrated green infrastructure network that will link key areas of woodland habitat, including Elsworth Wood, Knapwell Wood, Honeyhill Wood and New Wood.
5.17 In addition to providing added amenity, habitat and biodiversity value, the extent of tree planting will also deliver carbon sequestration benefits. Furthermore, any hedgerow loss or alteration to existing hedgerows will be compensated for by new hedgerow planting.
5.18 In addition to Green Infrastructure, significant areas of North Cambourne will be dedicated to enhance the provision of blue infrastructure. The addition of extensive water bodies will increase the diversity and ecological capacity of the area as well as provide for the management of surface water as part of a site-wide SuDS strategy.
Landscape and Townscape

5.19 Additional analysis has been undertaken to assess the landscape effects of development on the land at North Cambourne (a full Landscape Assessment report, prepared by Cooper Landscape Planning is provided as an accompanying technical report). The report updates a previous study undertaken in 2020 with the revised illustrative layout provided as an Appendix. The extent of potential development shown in previous proposals has been reduced in response to this landscape-led approach to design. This approach makes use of the screening effect afforded by:
woodland areas within and on the edge of the site;
the extensive local hedgerow network; and
the plateau effect of the landform and the gentle north- south valleys.

5.20 A series of photomontages have been developed to demonstrate that the proposed illustrative masterplan will not have a significant detrimental impact on the landscape, and particularly that the area of development will not produce unacceptable visual effects when seen from local villages including Elsworth and Knapwell.
5.21 Other key conclusions from this analysis are consistent with the findings of the 2020 study and demonstrate that North Cambourne is largely inconspicuous in views from the surrounding landscape. This is in part due to the flat nature of the topography adjoining the northern boundary of the Site, such that visibility is readily curtailed by intervening features such as hedgerows, woodland and trees. Another factor contributing to the lack of views is the scarcity of publicly accessible viewpoints from roads and other public rights of way within the surrounding landscape and with very few elevated viewpoints in the area.
5.22 Importantly, the scale of the site provides for the creation of a distinctive sense of place for new development, which respects the existing landscape characteristics as well as accommodating new woodland and hedgerows.
5.23 The creation of green corridors along a series of small-scale valleys and associated watercourses enhance the existing landscape character of the Western Claylands is in keeping with the Cambridgeshire Landscape Guidelines.
5.24 The landscape and visual appraisal demonstrates that there are potential effects that would be caused by new development at North Cambourne, but that these potential effects can be successfully addressed by a landscape-led approach to design, which respects key landscape characteristics and views.
5.25 The illustrative masterplan demonstrates how a design approach based on strong green corridors, open spaces, retention and enhancement of woodland and respect for views can high quality new community.
Historic Environment

5.26 As stated above in Section 3, the presence of a listed building and existence of archaeological crop marks give rise to potential for adverse effects on historic assets. In order to assess this impact and set out potential mitigation measures in more detail, an additional assessment of heritage features on the site has been carried out by Savills Heritage, included as an accompanying technical report.
5.27 The summary provided in Section 3 states that the known heritage assets sensitive to any development within the site includes the two Grade II listed structures at New Inn Farm, and potentially non-designated heritage assets at other historic farmsteads within, and immediately adjacent to, the site.
5.28 In light of the presence of these historic features, a series of measures is proposed to mitigate any adverse effects, including
locating certain types of development/open space appropriately to preserve archaeology in situ;
undertaking a staged programme of archaeological fieldwork, including a Desk-Based Assessment and / or geophysical surveying to focused evaluation trenching by way of an agreed Written Scheme of Investigation. The results of this additional assessment could further inform the level of significance of these remains and any further mitigation that may be necessary; and
a sensitively designed layout, which includes off-setting development and/or the appropriate use of intervening landscaping to help mitigate potentially adverse harm to the setting of the designated and non-designated heritage assets within or adjacent to the site. Notably, this includes there is no built development adjacent to the listed New Inn Farmhouse and barns in order to preserve their setting and minimise impact.

These measures reduce the risk of adverse impact on the historic environment. It should, however, be noted that none of the sites under consideration for the Cambourne Area are considered to be free of risk to the historic environment, and that all would require mitigation in some form, similar to that described above.
Summary
5.29 As a result of the additional design assessment and mitigation analysis set out above and in the accompanying technical reports, a comprehensive mitigation strategy has been devised to avoid negative impacts on the key characteristics of the site highlighted in the SA, including biodiversity and geodiversity, landscape and townscape, and the historic environment.
5.30 Additional documentation has also been provided as part of the SA evidence base, including the supplement to Appendix E of the SA, ‘Councils’ justification for selecting sites to take forward for allocation and discounting alternatives’. Within this part of the SA, a summary is provided of why sites subject to appraisal were included in the First Proposals as preferred options, and why other sites were not included.
5.31 The land at North Cambourne is included in this report, with the following narrative, ‘The preferred development strategy identifies Cambourne as a broad location for future development, in association with the opportunities provided by East West Rail and in particular the proposed new railway station. The location of the station has not yet been established and will be key to understanding where and how additional development should be planned, including considering the individual site constraints identified when testing these land parcels which were put forward through the call for sites process. The allocation of a specific area or quantity of growth has therefore been rejected.’
5.32 The SA and resulting narrative does not include any reference to the SA objectives referred to above, choosing to focus on the uncertain delivery of the North Cambourne station as part of East West Rail. Nevertheless, the site scores positively in relation to criterion SA 12 (Climate change mitigation) in the SA scoring matrix (as shown above). The reasoning in the SA and the consequent rejection of the site is therefore at odds with other elements in the SA findings.
5.33 Notwithstanding the SA, greater certainty has more recently been provided on the location of the new railway station for East West Rail with the publication of ‘Making Meaningful Connections’ Consultation Document published in March 2021. This consultation document shows the preferred option for a station at Cambourne to the north of the A428. This recent commitment further underpins the suitability of the North Cambourne proposal as a highly sustainable location for a new mixed-use community and overrides the reason for rejection of the site in the site-specific SA process.
5.34 MGH therefore request that the North Cambourne proposal is confirmed in future drafts of the GCLP and that the information submitted with these representations is taken into account to amend the evidence base for the GCLP in support of the allocation.

POLICY S/JH: NEW JOBS AND HOMES
4.1 The emerging plan shows a requirement to provide 44,400 dwellings over the plan period of 2020-2041, which represents development at 2,114 dwellings per annum.

4.2 It is noted that the proposed housing number exceeds what would usually be required as a minimum figure through the standard methodology calculation. Using the December 2020 formula, this would result in 1,743 dwellings per annum. This stance taken by the Greater Cambridge Planning Service will assist in addressing concerns regarding affordability and will also cater for increased demand for dwellings for skilled workers given employment growth in the area.

4.3 However, it is not considered that the housing numbers go far enough to cater for growth in the area. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) Report September 2018 confirms that growth in the employment sector has not been matched by proportionate house building. The result has been large increases in house prices.

4.4 Whilst it is acknowledged the CPIER report was published pre-Covid, the concepts and ideas remain pertinent as the economy recovers. Greater Cambridge is located within the key economic corridors of the Oxford – Cambridge arc, the London – Stansted - Cambridge corridor and the Cambridge – Norwich tech corridor. The Oxford – Cambridge arc seeks to create a strategic vision corridor between the University cities. It seeks to provide the infrastructure projects of East-West Rail and the Cambridge to Milton Keynes Expressway. At the eastern end of the arc, the driver is the City of Cambridge and its need for residential development to complement its skilled workforce.

4.5 The CPIER report provides a number of Key Recommendations to assist with growth in the area. Key Recommendation #5 of the CPIER Final Report September 2018 states: “There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast by the EEFM. This review should take into account the continuing dialogue between ONS and the Centre for Business Research on employment numbers as well as the impact of the Cambridge-Milton KeynesOxford Arc. This should be used to set new targets which Policy S/JH: New Jobs and Homes are likely to be higher than those already set – at the very least adding on accumulated backlog.”

4.6 The CPIER concludes that a target of 66,700 dwellings should be planned for in order to make the best of the opportunities available. It is therefore considered that the emerging Local Plan should increase its housing targets accordingly. Not only will this assist in combating affordability, it will also provide much needed affordable housing.

4.7 Martin Grant Homes reserves the right to further assess provision of housing need through the next stages of the Local Plan production.

5.0 POLICY S/DS: DEVELOPMENT STRATEGY

5.1 In line with the above, policy S/DS seeks the plan to provide 44,400 dwellings with a 10% buffer added for flexibility, totalling a need for 48,840 dwellings within the plan period. Page 32 of the First Proposals document shows that 37,200 are commitments, windfall etc, leaving a further 11,640 to be planned for. Curiously, when totalled together, the proposed allocations only total 11,596 leaving a shortfall of 44 dwellings.

5.2 In order to make up this shortfall, the Coton site could come forward. Whilst it has a capacity for 77 dwellings, the additional 33 dwellings would assist the Council should any other site provide delayed delivery. However, concern is raised below about delivery potential within the Strategy, which would significantly increase shortfall within the Plan period. These representations show why the Coton site is considered appropriate, although this can be summarised as: • The Green Belt assessment for a wider plot shows a ‘moderate’ harm, whereby an assessment by EDP shows the Site itself provides a ‘Low’ contribution to Green Belt objectives; • Coton is within 2 miles of West Cambridge and the village has seen limited growth in recent years, not allowing the village to evolve; • The Comberton Greenway is improving access to West Cambridge for cyclists and pedestrians, with Grange Road, Cambridge a 17 minute cycle ride form the village; • Coton is situated on the proposed Cambourne to Cambridge Busway (as shown on Figure 11 of the First Proposals document) and a station at Coton will provide further transport alternatives to the car; • Delivery of 40% affordable housing; • Development would benefit services and facilities within the village including the public house, post office and garden centre.

5.3 When assessing the Development Strategy, it is important to look at past delivery rates. Unfortunately, there are no formal figures available beyond 2019/20. However, this does provide useful context when looking at ‘current’ delivery rates. The table below summarises housing delivery in the past four years. The ‘total’ figure shows a fluctuating delivery rate that falls well below emerging Local Plan target of 2,114 dwellings per annum. It highlights that a robust strategy is necessary to increase delivery rates beyond this level. Area 2016/17 2017/18 2018/19 2019/20 Cambridge 1,183 1,112 868 460 South Cambridgeshire 551 737 1,152 1,107 Total 1,734 1,849 2,020 1,567

5.4 It is well known that larger sites have significant constraints to delivery compared to smaller sites. They have larger lead-in times, and therefore any delay will significantly impact delivery figures. A good example of this is Bourn Airfield. It is an allocated site in the current plan, yet it still does not benefit from a formal outline planning permission. The application (ref S/3440/18/OL) has now been with the Council for over 3 years without formal determination.

5.5 Given the need to then submit reserved matters applications, prepare necessary infrastructure and clarify the route of the Cambourne to Cambridge Busway, the ability for the site to commence delivery in 2023/24 seems very optimistic. Given the delays to the development already, the proposed delivery rates at Bourn Airfield does not appear reliable or robust.

5.6 The Development Strategy appears to have two key directions, those being development on the edge of Cambridge and increased delivery rates at the new settlements.

5.7 A key site at Cambridge is the North East Cambridge site. The proposed policy shows that the site will provide 3,900 dwellings between 2020 and 2041. The area has not been subject to a planning application as yet given the reliance upon the production of an Area Action Plan.

5.8 The Area Action Plan has been subject to a recent public consultation, and a report to the Joint Local Planning Advisory Group on 30 November 2021 sets out proposed changes to the Area Action Plan as a result of an assessment of the public responses. Of note, the proposed changes include a reduction in densities of development, a reduction in building heights and an increase in proposed open space provision by 17 hectares. However, despite these significant changes, the total housing numbers within the Local Plan remains the same. However, the nature of the changes to the Area Action Plan must impact upon delivery by its very nature. Proposed delivery rates at North East Cambridge must therefore be revised in line with the recommendations to the Joint Local Planning Advisory Group.

5.9 In addition to this, North East Cambridge is reliant upon the relocation of the existing sewage treatment works on the site. This is highly contentious locally and will no doubt be subject to legal challenge ahead of any relocation. The process has the potential to delay development and delivery at North East Cambridge. The ability of the area to provide 3,900 dwellings by 2041 therefore appears overly-ambitious, with any delay to the treatment works seriously impacting upon the Council’s delivery ambitions.

5.10 With regards the increase in delivery rates at new settlements, the emerging policy specifies this will relate to the new settlements of Northstowe and Waterbeach. This raises an immediate concern regarding how this is to be achieved. The ‘Housing Delivery Study for Greater Cambridge’ October 2021 document provides a justification for Northstowe given the quicker delivery methods of Urban Splash within phase 2A. As per Waterbeach, the development is expected to deliver an additional 50 dwellings per annum from 2026/27 onwards, resulting in 750 additional dwellings by the end of the proposed plan period.

5.11 However, unlike Northstowe, there is no justification as to how Waterbeach will achieve this increase in housing delivery. It is assumed the figures factor in another ‘peak outlet’ to deliver the additional 50 dwellings per annum. However, if the scheme was capable of having 7 developers on site at the same time, why was that part of the original build out rates from the current iteration of the Local Plan? The proposals seem overly generous and lack any clear justification that the increased delivery rates are achievable.

5.12 Historically, South Cambridgeshire District Council has relied upon new settlements and urban extensions to deliver the majority of its housing need. Martin Grant Homes has previously argued that this is to the detriment of villages, which as a result become dormant and suffer from a lack of inward investment.

5.13 The above information confirms there is significant doubt regarding the spatial strategy and the associated housing trajectory. There are serious concerns regarding delivery rates at Bourn Airfield, Waterbeach and North East Cambridge, which will impact upon Greater Cambridge’s ability to provide a five year housing land supply.

5.14 The solution therefore would be to add further small and medium sized sites within the trajectory. This would cover off any delays in delivery. Smaller sites benefit from limited infrastructure improvements, and take significantly less time in the planning system. These advantages are set out in paragraph 69 of the National Planning Policy Framework 2021.

5.15 The emerging Local Plan is reliant upon some Green Belt release to meet the housing delivery targets. This includes release of land around the edge of Cambridge, as well as two sites within Green Belt villages.

5.16 Martin Grant Homes support the release of Green Belt land in order to meet some of this housing need. By their location, Green Belt villages such as Coton are situated in close proximity to Cambridge and as such can play an important role in supporting the City. These representations justify why Green Belt release in Coton would promote sustainable development opportunities. The Local Plan however does not fully capitalise on appropriate Green Belt release, instead shifting development to more unsustainable locations (such as Melbourn and Duxford) where there will be more reliance upon the car.

5.17 Martin Grant Homes reserve the right to further assess delivery rates through the further phases of Local Plan preparation.

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.