Greater Cambridge Local Plan Preferred Options

Health Impact Assessments should be a requirement for major developments only. For minor developments, this information should be optional or simplified, for example through the use of a short questionnaire (similar to the Cambridgeshire Biodiversity Checklist).

It is accepted that good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments, with a dominance of bland, monotonous “identikit” housing estates from major housebuilders.

Design Guides/Codes are acceptable on large scale, strategic developments, but should not be imposed on smaller scale developments where other mechanisms, including parameter plans, can adequately achieve similar and proportionate outcomes. Local community input will also be as stated, and a robust consultation process will be needed since the ‘devil will be in the detail’; these documents must go beyond broad requirements for new homes to be ‘in keeping’ with the character and appearance of the area.

However, it will take time for these design guides to be drafted and adopted. In the interim, developers could be signposted towards an alternative framework. For example, the National Design Guide, which includes 10 characteristics of a well-designed place: context, identity, built form, movement, nature, public spaces, uses, homes and buildings, resources, and lifespan. Schemes which can demonstrate a high standard of design should be fast-tracked through the application process.

Additional measures should be introduced for strategic scale development to avoid monotony. For example, the policy could introduce a minimum number of individual house types, appropriate to the scale of development.

The First Proposals plan sets a challenging target for affordable housing to reflect the acute and substantial need for affordable housing across Greater Cambridge. This places a great responsibility on all major developments to provide an element of affordable housing.

Policy H/AH will have a significant bearing on the viability of individual residential developments, so it is vital that the affordable housing requirement is achievable in practice. Although the First Proposals plan indicates that viability evidence will be reviewed as appropriate as part of the plan-making process, this is not sufficient. Planning Practice Guidance indicates that plans should set out circumstances where review mechanisms may be appropriate, as well as a clear process and terms of engagement regarding how and when viability will be reassessed over the lifetime of a development to ensure policy compliance and optimal public benefits through economic cycles. Draft Policy H/AH does not do this. For example, changes in affordable housing tenure models or continued increases in build costs may render the viability evidence which underpins the affordable housing requirement out-of-date relatively quickly.

In relation to the development of land south of Horseheath Road in Linton, a Housing Needs Survey carried out in June 2019 indicated a need for 81 affordable dwellings in the village. According to a recent appeal decision there was still an unfulfilled need for 64 affordable dwellings as of 16 February 2021. There are no allocations for residential development in the adopted Local Plan and no proposed allocations in the village as part of the emerging GCLP. It is understood that two permitted developments will deliver 39 affordable homes, leaving a presumed requirement for 25-42 affordable dwellings – a requirement which will likely increase across the life of the Greater Cambridge Local Plan. Dependence on the allocation of strategic sites with already high infrastructure burdens is unlikely to offer sustainable, long-term solutions to the chronic and worsening affordability issues being experienced across the Greater Cambridge area. Strategic sites alone do not deliver policy-compliant levels of affordable housing, so, if this is the target, more smaller sites that are far more likely to deliver a policy-compliant level of affordable homes at a faster rate need to be allocated.

Draft Policy H/AH of the First Proposals plan requires 40% affordable housing on sites of 10 or more dwellings. With a total of 100 dwellings proposed on site 40554, 40 dwellings – of which at least 10 will be allocated as ‘First Homes’ under the national First Homes initiative - would be sought for affordable housing under this policy. As well as helping to address the current shortage of affordable housing over the Greater Cambridge area, the delivery of up to 40 affordable dwellings would satisfy the full affordable housing need in Linton – a significant benefit for local residents.

The proposed policy approach will require continual updating of the self and custom build register(s) to reflect the permissions that have been granted with a self- or custom-build element. Close monitoring on sales and completions will also be necessary in case plots earmarked for self- or custom-build revert to market dwellings at the end of the prescribed 12-month marketing period.

It is also unclear if the current registers for Cambridge City and South Cambridgeshire are to be combined, with delivery of plots across the wider area. This would not be logical since many prospective self-builders will have preferred locations and few will have a search area as wide as Greater Cambridge. A more focused policy, perhaps split across the two administrative areas, would encourage the development of self-build plots in the right locations to meet local demand. For example, if all the need for plots was in and around Cambridge, it would not make sense to burden developers in other parts of the area.

The following is a summary of the of the overarching representations submitted on behalf of Endurance Estates by Barton Willmore. The full report is appended to these site-specific representations for completeness.

The First Proposals draft Plan sets out that the Greater Cambridge Partnership will seek to deliver an objectively assessed need of 58,500 jobs and 44,400 (48,800 inc. 10% buffer) homes during 2020-2041. This represents the Councils’ medium+ growth scenario, with the maximum growth scenario (78,700 jobs and 56,500 homes) being discounted on the basis that it does not reflect the most likely level of jobs growth when reflecting on long-term employment patterns.

Within paragraph 5.22 of the Councils’ Employment Land and Economic Development Evidence Study, it is in fact recommended that a preferred range for jobs growth would be ‘between a central and higher growth scenario’.

The ‘central’ growth scenario represents an annual average employment growth rate of 1.1%. This is significantly below other assessments of growth for the Districts. The CPIER report quotes ONS 2010-2016 average growth rates of 2.4% and 2.3% across the City and South Cambridgeshire respectively, whilst their own ‘blended rate’ shows rates of 2.4% (equal to ONS) and 4.2% (significantly more than ONS).

These figures suggest that the First Proposals are not planning for sufficient employment growth and therefore not enough housing to support it.

The employment and housing growth figures for the Local Plan through to 2041 should be revised upwards substantially, in order to accommodate the demonstrable growth potential of the Districts.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). While it is acknowledged that the principle of this growth is already established through adopted development plan documents, the additional dwellings at Cambourne is proposed through the emerging GCLP and associated East West Rail.

While it is acknowledged that the Council’s preferred development strategy is to utilise those edge of Cambridge sites which were previously developed, the redevelopment of both North-east Cambridge and Cambridge East poses significant challenges. North-east Cambridge requires the relocation of a sewage treatment works and existing businesses; Cambridge East requires the relocation of airport related uses and businesses. The development of these site is therefore very complex and highly likely to cause delays to delivery within the plan period and also highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The Councils’ preferred development strategy also refers to speeding up housing delivery rates at some new settlements. However, there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. The Councils have not evidenced if any site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings per year over the plan period.

In order to ensure that the overall plan is deliverable, there needs to be greater certainty that sites will come forward within the plan period to deliver the growth required and, in turn, to address the under-delivery of affordable housing within Greater Cambridge. This under-delivery is evidenced through the affordable housing contributions that have come forward on major strategic sites as follows:

• Northstowe (Phase 1 and 2) - 20%
• Waterbeach – 30%
• Cambridge East – (Wing) – 30%
• Cambourne West – 30%

The development strategy should allocate some sites that are capable of delivering policy-compliant levels of affordable housing. Land at Gazelle Way does not have infrastructure constraints and, as such, can provide policy-compliant levels of 40% affordable housing to help address the significant under-delivery in Greater Cambridge. The potential for sites like this to deliver policy compliant levels of affordable housing has been evidenced at Land north of Cherry Hinton.

It is acknowledged that the development of Land at Gazelle Way requires some release of land from the Green Belt, and that the Council have dismissed this as a preferred option as per the following conclusion:

“Whilst edge of Cambridge Green Belt sites performed in a similar way in many respects to Cambridge East, they would have significant Green Belt impacts and given the relatively good performance of Cambourne, which is not in the Green Belt and would benefit from there was considered to be no exceptional circumstances for releasing land on the edge of Cambridge to meet development needs as a matter of principle and that spatial option was not preferred.”

Greater Cambridge has significant affordability issues and addressing such affordable housing needs should be a priority for the Local Plan. Allocating the land east of Gazelle Way which will deliver the affordable housing required provides justification for the release of Green Belt land, especially since this land is located sustainably and is well served by public transport as required by paragraph 142 of the NPPF when reviewing Green Belt boundaries.

Land at Gazelle Way is located on the edge of Cambridge, only three miles from the City Centre. The site benefits from existing sustainable transport infrastructure, including access to existing cycle routes and bus service provision to access surrounding local amenities and facilities, as well as convenient access into the City Centre. The site will also benefit from being located along the proposed Fulbourn Greenway route and has potential to accommodate a new train station along the Cambridge-Ipswich line. The accessibility of the site is not reliant on expensive major new infrastructure.

The development strategy needs to fully embrace and reflect the strategy for the City of Cambridge to be net zero carbon by 2030. The allocation of highly sustainable sites where housing and jobs are located together, reducing the need to travel, will be instrumental in achieving this goal. The Land at Gazelle Way is within a highly accessible location which means that new residents would not be reliant on their cars to access jobs, shops or socialise either within the Site or within the City. The vision for this site is to provide a highly sustainable community which locates homes and jobs together.

In summary, Endurance Estates wish to object to the ‘high risk’ nature of the development strategy, which is dependent upon the delivery of some strategic, complex sites. The development of these is highly likely to cause delays to delivery within the plan period and highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The development strategy should allocate some additional sites such as Land east of Gazelle Way that are capable of delivering policy compliant levels of affordable housing. The allocation of the site would also contribute to the Council’s aspirations to become a zero-carbon authority by 2030 by offering an opportunity to be a truly sustainable community which locates homes and jobs together.

The review of the Green Belt is welcomed as there is a compelling need for Greater Cambridge to release some land from the Green Belt to provide the opportunity for sustainable development. However, the results from the ‘Greater Cambridge Green Belt Assessment 2021’ provide a significantly different assessment of a number of parcels of land compared to that of the Council’s previous evidence (2012 Inner Green Belt Boundary Study).

The parcels of land labelled within the assessment as CHI1, CHI2, CHI3, CHI4, FU1, FU19, TE6, TE7, TE8 TE9 have been assessed as either ‘Very High, High and Moderate High’ in terms of the level of impact that the release of these parcels for development would have.

This assessment conflicts with the Councils’ previous evidence (2012 Inner Green Belt Boundary Study) whereby ‘Plan 4 – Areas of Significance of Development on Green Belt’, assesses the same parcels of land as either ‘medium’ or ‘low significance’. This resulted in part of the site being the lowest significance of all the Green Belt around Cambridge. The five principles of the Green Belt as defined within the NPPF remain unchanged in the past 10 years therefore in the context of this site, it is unclear why the classification has changed, and with a much clearer and more robust justification for the change in classification needing to be provided. It is also noted that the vast majority of Green Belt parcels within the ‘inner green belt area’ around Cambridge have been identified as resulting in ‘High-Harm’. Such a blanket conclusion does not appear to reflect the differences in context around the city. Further clarification is needed.

In terms of residential and employment commitments, the new Local Plan should seek to meet the full, unconstrained objectively assessed needs for market and affordable housing, as well as the assessed needs for jobs.
Paragraph’s 60 – 62 of the National Planning Policy Framework (NPPF) outline that Local Plans should support the Government’s objective to significantly boost the supply of homes and at a minimum should be informed by a local housing need assessment using the standard method included in National Policy Guidance. The NPPF also notes that it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed.
The Plan has identified an objectively assessed need for 58,500 jobs and 44,400 homes across the Plan period from 2020-2041.
The total number of homes to be provided through the plan is 48,840 which includes a 10% buffer for flexibility and results in a requirement of 11,640 homes to be identified in this Plan.
Whilst an uplift has been applied to the Standard Method, in response to the Council’s evidence which considers the preferred forecasted employment levels, it is noted that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041.
The Councils have instead opted to pursue a ‘Medium’ growth option (2,111 dwellings per annum), but this falls short of maximising the economic potential of the ‘Plan Area’ and the provision of housing in accordance with higher forecasts for jobs growth (2,549 to 2,690 dwellings per annum). This is projected to continue existing trends, where levels of housing delivery have been out-paced by jobs growth, resulting in sustained affordability pressure, and increased in-commuting. This has addressed in more detail by the representations submitted by Barton Willmore in respect of our client’s wider interests in Greater Cambridgeshire.
The Council’s Housing Needs for Specific Groups Addendum (2021) models the demographic implications of various growth scenarios. This recognises that whilst needs increase as the housing numbers go up, the proportionate increases are fairly small due to uplifts primarily affecting younger working populations (Paragraphs 6.7-6.8). The material point, however, is that the higher growth scenarios provide a true reflection of the actual demand for housing. Even using the Council’s ‘medium’ scenario, without prejudice to the reservations in these representations, the Council’s Preferred Approach represents a significant increase in the requirements for development.
To address this, the Council is only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites as provided for in the existing strategy. In practice, the risks to delivery mean that the Council’s stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period utilising very limited additional sources of flexibility.
Whilst this policy recognises the overall number of homes to be provided for within the plan period, the First Proposals as a whole fail to set a figure or a range for the number of specialist housing for older people needed across the plan area. The issues identified mean that, together with considering full housing needs, and the requirement for an increased supply buffer, consideration must therefore be given to specifying the amount of homes to be provided for to meet the demand for Extra Care and other types of specialist accommodation, and then how these will be delivered.
While an increase to the overall buffer may be appropriate (to say 20%) the practical implications are that any risks to delivery of the strategy mean operators within the specialist older persons housing sector will face the most extreme pressures of competition in securing development opportunities.
This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
In these circumstances, greater certainty and flexibility would be achieved through the allocation of specific sites to meet the needs for specialist housing for older people alongside provisions for the overall buffer, including that relating to general housing needs. Addressing this issue is central to satisfying NPPF Paragraph 60 in terms of providing an appropriate strategy that will enable the needs of specific groups to be addressed without being entirely dependent on the wider identified risks.

In terms of residential and employment commitments, the new Local Plan should seek to meet the full, unconstrained objectively assessed needs for market and affordable housing, as well as the assessed needs for jobs.
Paragraph’s 60 – 62 of the National Planning Policy Framework (NPPF) outline that Local Plans should support the Government’s objective to significantly boost the supply of homes and at a minimum should be informed by a local housing need assessment using the standard method included in National Policy Guidance. The NPPF also notes that it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed.
The Plan has identified an objectively assessed need for 58,500 jobs and 44,400 homes across the Plan period from 2020-2041.
The total number of homes to be provided through the plan is 48,840 which includes a 10% buffer for flexibility and results in a requirement of 11,640 homes to be identified in this Plan.
Whilst an uplift has been applied to the Standard Method, in response to the Council’s evidence which considers the preferred forecasted employment levels, it is noted that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041.
The Councils have instead opted to pursue a ‘Medium’ growth option (2,111 dwellings per annum), but this falls short of maximising the economic potential of the ‘Plan Area’ and the provision of housing in accordance with higher forecasts for jobs growth (2,549 to 2,690 dwellings per annum). This is projected to continue existing trends, where levels of housing delivery have been out-paced by jobs growth, resulting in sustained affordability pressure, and increased in-commuting. This has addressed in more detail by the representations submitted by Barton Willmore in respect of our client’s wider interests in Greater Cambridgeshire.
The Council’s Housing Needs for Specific Groups Addendum (2021) models the demographic implications of various growth scenarios. This recognises that whilst needs increase as the housing numbers go up, the proportionate increases are fairly small due to uplifts primarily affecting younger working populations (Paragraphs 6.7-6.8). The material point, however, is that the higher growth scenarios provide a true reflection of the actual demand for housing. Even using the Council’s ‘medium’ scenario, without prejudice to the reservations in these representations, the Council’s Preferred Approach represents a significant increase in the requirements for development.
To address this, the Council is only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites as provided for in the existing strategy. In practice, the risks to delivery mean that the Council’s stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period utilising very limited additional sources of flexibility.
Whilst this policy recognises the overall number of homes to be provided for within the plan period, the First Proposals as a whole fail to set a figure or a range for the number of specialist housing for older people needed across the plan area. The issues identified mean that, together with considering full housing needs, and the requirement for an increased supply buffer, consideration must therefore be given to specifying the amount of homes to be provided for to meet the demand for Extra Care and other types of specialist accommodation, and then how these will be delivered.
While an increase to the overall buffer may be appropriate (to say 20%) the practical implications are that any risks to delivery of the strategy mean operators within the specialist older persons housing sector will face the most extreme pressures of competition in securing development opportunities.
This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
In these circumstances, greater certainty and flexibility would be achieved through the allocation of specific sites to meet the needs for specialist housing for older people alongside provisions for the overall buffer, including that relating to general housing needs. Addressing this issue is central to satisfying NPPF Paragraph 60 in terms of providing an appropriate strategy that will enable the needs of specific groups to be addressed without being entirely dependent on the wider identified risks.

The consultation document outlines the ‘preferred development strategy’ for Greater Cambridge and defines the intention to direct development 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.
The strategy notes that development will therefore make use of brownfield opportunities within the Cambridge Urban Area, urban extensions and new settlements, but only proposes a very limited amount of development in rural areas.
At this early stage in the Local Plan preparation process (Regulation 18), further consideration of sites suitable for, amongst other development typologies, specialist housing for older people (including Extra Care development) in sustainable locations should be undertaken. There are opportunities, such as the submission site, to deliver Integrated Retirement Communities which provides Extra Care housing in sustainable locations which will also serve to support rural services, improve the vitality and viability of villages, and their shops and facilities whilst also enhancing local amenities including healthcare.
The proposed development strategy focuses on a number of larger, strategic developments which will not support the existing villages and will not deliver the type of housing required to meet the housing needs of different groups (including older people) and needs of local communities in these locations.
The Plan needs to support conscious efforts to ensure the delivery of housing to meet the need for specialist housing for older people, which is described in government policy guidance (PPG) as critical. (Paragraph: 001 Reference ID: 63-001-20190626)
There is a significant amount of variability within the sector (as acknowledged within the PPG), which also recognised that the location of housing is a key consideration for older people who may be considering whether to move. It is not considered that the proposed development strategy takes into consideration the needs of the sector, including the allowance of choice, and the approach currently advocated a will not support the varying models available to provide Extra Care housing and retirement communities.
The PPG identifies the different typologies of specialist housing, each designed to meet the diverse needs of older people and identifies that specialist housing needs differ dependant on the level of care needed. The PPG makes it clear that diverse housing models will need to be considered and the provision of one type of specialist housing will not meet the care requirements of older people whose range of needs will differ greatly.
The characteristics of Extra Care accommodation, including the level of services provided and support available, materially affects the requirements of operators and the conclusions on those locations that are potentially suitable for development. The characteristics of Integrated Retirement Communities which provide Extra Care housing also enable consideration of where this can contribute towards mixed and balanced communities and sustainable growth in rural areas (in accordance with NPPF 2021 paragraph 79). There may be cases, such as at Comberton, where delivery alongside general needs housing would promote social interaction and the delivery of mixed and balanced communities.
This necessitates an objective assessment of alternatives to the Council’s proposed strategy to meet general housing needs where this would ensure a reasonable prospect of meeting needs for specialist housing in full.