Greater Cambridge Local Plan Preferred Options

1. Paragraph 61 of the NPPF identifies that the minimum number of homes needed within a plan period should be assessed using the Standard Method. An alternative approach should only be used where there are exceptional circumstances to reflect current and future demographic trends and market signals. Based on the Governments’ Standard Methodology, the Council's housing need figure is 36,600 dwellings over the plan period (2020-2041). The Development Strategy Topic Paper (DSTP) outlines that this scale of housing provision would support the creation of 45,800 jobs in Greater Cambridge over the plan period.

2. When assessing Cambridge's future employment and housing needs, it is important to recognise the city's unique regional, national and international standing as a research and innovation employment centre. The Centre for Cities March 2021, ‘Fast Growth Cities – 2021 and beyond’ identifies Cambridge as one of the fastest growing cities in the UK, with more than 60 per cent of its workers coming from outside Cambridge.

3. The significance of the city is further strengthened through its various strategic alliances, including the Greater Cambridge City Deal, the Oxford-Cambridge Arc, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Local Plan (GCLP). In the context of the GCLP, the Councils have completed work assessing the potential economic growth scenarios and the quantity of new houses needed to support this growth in Greater Cambridge over the plan period. The Housing and Employment Relationship Report (November 2020) (HERR) provides two scenarios for housing needs over the plan period (2020-2041), which are in excess of the Government's Standard Method. Scenario 1 forecasts 58,500 new jobs and a housing need of 44,400 dwellings, while the Scenario 2 forecasts 78,700 new jobs and a housing need of 56,500 dwellings.

4. The HERR states that the GCLP should plan for economic growth within the range of the two scenarios. The Councils should plan positively through the GCLP to meet the challenges and opportunities presented by the growth initiatives and funding which is focused on Greater Cambridge. However, the GCLP First Proposals document is aligned with the lower employment and housing figures forecasted by Scenario 1. Our client welcomes the principle of exceeding the Standard Method figures, nevertheless, given the significant growth expected in Greater Cambridge during the plan period, it is considered that the GCLP should take a more positive and proactive approach to support the economic growth of the area. Failure to do so is likely to result in an unnecessary and unsustainable increase in in-commuting, exacerbating unsustainable travel patterns. The Councils should undertake further work to establish a housing requirement within the range stated in the HERR or plan for the higher figure.

Neighbourhood Planning

5. Paragraph 66 of the NPPF outlines that strategic policies should identify the housing requirement for a Neighbourhood Plan Area. However, the First Proposals document states that Neighbourhood Plans housing requirements would be met using the Local Plan windfall housing numbers. R2 Development objects to this approach, which is contrary to Paragraph 66 of the Framework.

6. The GCLP should proactively allocate a proportionate amount of housing growth to sustainable rural settlements, such as Group Villages. Such an approach will be consistent with NPPF with regards to identifying housing requirements, and Paragraph 79 of the NPPF which outlines that planning policies should identify opportunities for villages to grow and thrive, particularly where this will support local services. The adoption of the GCLP should trigger the formal review of an adopted Neighbourhood Plan to ensure that distributed growth to sustainable settlements is allocated at sustainable sites within the Neighbourhood Plan Area.

1 The GCLP Development Strategy Topic Paper (October 2021) outlines that a strategy "focused on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure." Consequently, villages are not the primary focus for growth within the development strategy.

2 The First Proposal identifies that 11,640 additional dwellings are needed to meet the housing need target within the plan period, after considering the committed housing supply. The proposed development strategy identifies four new sites in rural Greater Cambridgeshire to accommodate the additional housing need, which includes two sites in the "Group Villages” of Caldecote and Oakington. In total, the four sites can deliver 224 dwellings, which equates to only 1.9% of the new housing supply being met within rural areas. In contrast, 62% of the total supply is focused on the delivery of new settlements and strategic sites.

3 During the current plan period there has been significant scrutiny and pressure on the five-year housing land supply of the Greater Cambridge authorities. This is in part due to the current over reliance on new settlements and strategic sites to deliver housing numbers and the failure to allocate proportionate growth at sites on the edge of established rural settlements which have fewer delivery constraints. Delivering new settlements and large strategic sites often requires investment in significant up-front infrastructure. The funding and delivery of such infrastructure can significantly increase lead in times before dwellings are delivered and occupied. A Local Plan which establishes a balanced approach to the distribution and allocation of new housing sites will safeguard against the potential for shortfalls in five-year land supply upon the Plan’s adoption and during the plan period. Like the current adopted Local Plans, the GCLP will again deliver an imbalanced and ridged housing supply which exposes the Greater Cambridge authorities and their residents to considerable risk in terms of potentially facilitating the opportunity for speculative planning applications for housing development to come forward as and when there is a shortfall in supply. A more flexible and varied supply is required to boost sustainable rural communities and small and medium sized house builders; and to ensure a robust supply of housing is maintained in Greater Cambridge.

4 The Council’s development strategy approach for rural areas appears to be one which largely restricts development, and where allocations are proposed, the process of making allocations has been site-led rather than being led by an objective process which compares the sustainability credentials of sustainable rural settlements. To provide a more flexible and balanced housing supply, and to deliver the variety of sites the market demands the Councils should identify additional available and deliverable small and medium sized sites from a range of locations capable of accommodating housing growth within the plan period. The content of the Housing Economic Land Availability Assessment (HELAA) demonstrates that there are a number of suitable and available sites, located at sustainable settlements such as Group Villages, capable of being allocated for residential and mixed use development. This includes the Village of Foxton, which is a highly accessible location with its connectivity to the national rail network. Thereby the village is potentially more sustainable than some of the other rural area locations on the proposed Settlement Hierarchy.

1. In accordance with the NPPF, Green Belt boundaries should only be altered in exceptional circumstances through the preparation or updating of plans. Given the significant investment and planned growth in Cambridge and South Cambridgeshire, R2 Developments support the case that exceptional circumstances exist to warrant such a review and consider that a modification to the Green Belt is required to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance.

2. Our client has commissioned a Landscape and Visual Appraisal (LVA) to assess the contribution of their sites (Land the north and east of Barrington Road, Foxton, HELAA Ref: 40412 and Land to the south-east of Cambridge Road, Foxton, HELAA Ref: 40408) to the five purposes of the Green Belt as established by the NPPF. The submitted table extract from the LVA assesses both of the promoted sites’ contributions to the five purposes of the Green Belt.

(SEE SEPERATE SHEET FOR TABLE 1)

3. The content of Table 1 indicates that Land to the north and east of Barrington Road, Foxton (Ref: 40412) does not significantly contribute to Green Belt purposes. Accordingly, the land should be considered for release from the Green Belt and allocation for residential development as part of revised GCLP development strategy which delivers a higher housing requirement to support increased levels of economic growth and development at sustainable rural settlements such as Foxton and other Group Villages.

(SEE SEPERATE SHEET FOR TABLE 2)

4. The content of Table 2 indicates that Land to the south-east of Cambridge Road, Foxton (Ref: 40408) does not significantly contribute to Green Belt purposes. Accordingly, the land should be considered for release from the Green Belt and allocation for mixed use development as part of revised GCLP development strategy which delivers a higher housing requirement to support increased levels of economic growth and development at sustainable rural settlements such as Foxton and other Group Villages.

5. Tables 1 and 2 provide a site specific review of the land’s contribution to Green Belt purposes. The published ‘Greater Cambridge Green Belt Assessment’ prepared by LUC (August 2021) identifies both sites as being within the same parcel reference no. FX2. Our client objects to this approach as the two sites are being promoted separately and are capable of being delivered independently.

6. We note that the Assessment concludes that the release of Parcel FX2 would give rise to ‘moderate high’ harm. The ‘moderate high’ harm conclusion is drawn from the following assessments.

• To preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre – Assessment: No contribution

• To maintain and enhance the quality of Cambridge’s setting – Assessment: Relatively Limited Contribution

• To prevent communities in the environs of Cambridge from merging into one another and with the city – Assessment: Moderate

• Release of land as an expansion of Foxton: Assessment: Minor-moderate

7. The individual strands of assessment do not support the overall ‘moderate high’ harm conclusion. The Green Belt Assessment should be reviewed and amended so that the two sites are assessed individually and to ensure that the conclusion reflects the different strands of the assessment. Tables 1 and 2 should also be reflected in any new assessment.

8. Our client strongly advocates that deliverable and sustainable sites found not to contribute to the five purposes of the Green Belt should be released and allocated for development. This includes Land to the north and east of Barrington Road, Foxton, (HELAA Ref: 40412) and Land to the south-east of Cambridge Road, Foxton (HELAA Ref: 40408). The release of these sites from the Green Belt will allow developments to come forward which will assist in delivering a varied and balanced housing supply and meeting the rising housing needs of Greater Cambridge.

1. Foxton is identified as a 'Group Village' in the South Cambridgeshire Local Plan (2018) Settlement Hierarchy. Group Villages, such as Foxton, are the tier of settlement below Minor Rural Centres in the settlement hierarchy.

2. There have been a considerable number of recent appeal decisions that have confirmed that that Group Villages are capable of accommodating housing growth due to their service provision and settlement hierarchy status.

3. Foxton possesses a range of amenities capable of supporting the day to day needs of residents. These amenities include a pub, a village shop, a post office, a vehicle repair garage, a car sales dealership, a village hall, primary school, a church and a recreation ground (with a children's playground, tennis courts, a bowling green, a football pitch and cricket pitches). The Village also offers various employment opportunities (industrial and office), including at Burlington Park and the A10 Triangle.

4. The attached Table 3 provides a schedule of key local services and their approximate distance to our client's promoted sites.

(SEE SEPERATE SHEET FOR TABLE 3)

5. The submitted Table 3 provides a clear indication that future occupiers of our client's promoted two sites would have convenient access to a range of services, facilities and sustainable modes of transport.

6. The proposed mixed-used development at 'Land to the south-east of Cambridge Road' (HELAA Ref 40408) will continue to strengthen the village's employment offerings and support the wider rural economy. The scale of residential development proposed at 'Land to the north and east of Barrington Road' (HELAA Ref: 40412) is appropriate to the size of the village and would support the long term vitality of the village and provide the local community with housing choice.

1. R2 Developments are promoting two Green Belt sites in Foxton, which are 'Land to the north and east of Barrington Road' (HELAA Ref: 40412) and 'Land to the south-east of Cambridge Road (HELAA Ref: 40408) for removal from Green Belt and subsequent allocation for residential and mixed-use development respectively. The publication of the HELAA review which appraises the development potential of the sites is welcomed by our client. However, there are a number of specific technical flaws in the published appraisal which should be remedied as the GCLP preparation continues.

2. Given that the proposed site allocations involve the release of Green Belt land, a Landscape Appraisal has been prepared by our client.

3. Separate Tables have been submitted to identify inaccuracies within the HELAA schedules and recommend amendments.

(SEE SEPERATE SHEET FOR TABLES 4 & 5)

4. Our client considers that the Councils should identify additional available and deliverable sites from a range of sustainable rural locations. There are a number of sustainable rural sites capable of accommodating proportionate housing growth within the plan period. The disproportionately low level of growth assigned to sustainable rural settlements will compromise the vitality of the settlement, contrary to paragraph 79 of the NPPF. Our client also considers that there are a compelling package of exceptional circumstances which justifies the release of the sites from the Green Belt.

5. In order to provide greater certainty for the plan period, it will be necessary to increase the amount of housing and employment space in Group Villages, such as Foxton. This provides the opportunity to allocate both 'Land to the north and east of Barrington Road' (HELAA Ref: 40412) and 'Land to the south-east of Cambridge Road (HELAA Ref: 40408) for residential and mixed-use development (office and research development), respectively.