Draft Greater Cambridge Local Plan for consultation

The Local Plan should be amended to provide explicit and unambiguous recognition of CSETS Phase 2 and the Busway Extensions as essential infrastructure underpinning the spatial strategy for both the edge of Cambridge and South Cambridgeshire. This should include clear commitments on delivery, timing and phasing, aligned with planned housing and employment growth. The Plan should also reassess site selection to ensure consistency with its stated objectives, particularly by reconsidering the exclusion of accessible and well serviced sites such as Site 40509 on Babraham Road. A more evidence led and infrastructure informed approach would improve certainty, support timely delivery, and make more effective use of sustainable locations.

The edge of Cambridge - The section references the infrastructure needed to support development on the edge of Cambridge, but it lacks clarity on what is required. In practice, delivery of schemes such as Grange Farm and the Cambridge Biomedical Campus expansion depends on CSET, yet this is not explicitly referenced. As identified within the Infrastructure Delivery Plan that informs the emerging Local Plan, both CSETS Phase 2 and the Busway Extensions are categorised as critical infrastructure. The delivery of CSETS is therefore fundamental to the effective implementation and overall success of the Local Plan.

It is reasonable to conclude that the delivery of CSETS is a key intention underpinning the spatial strategy of the Plan. However, this intention is not explicitly reflected within the Local Plan or its summary. The absence of a clear and specific reference to CSETS creates a risk that this infrastructure will not be delivered in a timely or coordinated manner. In turn, this would undermine the delivery of the housing and employment growth that the area urgently requires and which the Local Plan seeks to facilitate.

Greater certainty on the timing and delivery of such infrastructure would help bring forward suitable sites, such as Site 40509 on Babraham Road, currently excluded from housing due to Green Belt impact. Once CSET is operational, this site would become infill, with housing on two sides and CSET the third.

Rural South Cambridgeshire – While the principle of supporting villages with good services and transport links is sensible, the plan’s allocations do not reflect this objective. Excluding Site 40509 on Babraham Road solely due to Green Belt designation is inconsistent, as the site benefits from significantly better local services and accessibility than some of the group villages where allocations are proposed. Car travel is easier from 40509, yet it is not supported for development. The current approach undermines the stated goal of sustaining thriving rural communities while making efficient use of accessible sites.

Policy J/NE should be amended to explicitly recognise specialist rural and land based businesses, including equine and equestrian enterprises falling within sui generis use, as a distinct and important component of the rural economy. The policy should support the development, expansion and modernisation of such businesses in countryside locations where a functional need for extensive land holdings can be demonstrated, acknowledging that the built footprint may be limited relative to the site area.

The policy should also make clear that proposals which are necessary to secure the viability of established rural businesses, including stud farms, training yards and associated facilities, will be supported where landscape, environmental and amenity impacts can be satisfactorily mitigated. Greater weight should be given to economic benefits, including employment generation and contribution to the rural economy, particularly in areas with functional links to the wider equestrian and racing industry. This would ensure the policy is consistent with national guidance on supporting a prosperous rural economy.

Policy J/NE (New Employment Development Proposals) does not adequately recognise or support rural businesses with specialist operational requirements, such as equine stud farms, which typically fall within sui generis use. These enterprises require access to extensive areas of land and are therefore, by their nature, located in the countryside, although the built form often occupies only a small proportion of the overall site. The Local Plan fails to acknowledge the presence and importance of such specialist rural industries within the district, particularly in areas such as Brinkley, where there is a clear functional relationship with East Cambridgeshire and the wider horse racing and equestrian economy.

The current policy wording provides insufficient support for the facilities required to enable these businesses to operate viably. This is a significant omission given that equestrian businesses make a substantial contribution to the rural economy in Cambridgeshire, with the non-racing equestrian sector alone contributing in excess of £115 million per annum. Nationally, the equestrian industry is the second largest rural employer, yet this role is not adequately reflected or supported within the Local Plan’s employment policies.

Policy J/RE should be revised to explicitly recognise and support equestrian and other specialist rural enterprises as a key component of the rural economy. The amendments should include the following:

1. Acknowledgement of Operational Needs: Recognise that equestrian businesses require access to large areas of land, while the built footprint is often limited, and that development may need to be separated for health and safety or operational reasons.

2. Support for New and Expanding Businesses: Make clear that proposals necessary to establish or maintain the viability of rural businesses will be supported where landscape, environmental, and amenity impacts can be mitigated.

3. Flexibility in Site Location: Clarify that development can occur in countryside and Green Belt locations where justified by operational need, in line with NPPF guidance.

4. Economic Contribution: Reflect the significant contribution of rural businesses, including equestrian enterprises, to employment, tourism, and the wider rural economy.

5. Practical Design Requirements: Avoid overly prescriptive requirements that are impractical for specialist rural uses, such as restricting car parking to within clusters of buildings.

6. New Buildings: Recognise that some businesses may require new buildings in the countryside and that the rural economy has the right to thrive with access to necessary facilities and amenities (even if new build) in the same way as urban economies.

These changes would ensure the policy aligns with national guidance, supports sustainable rural business growth, and better reflects the economic and social value of the rural economy in Cambridgeshire.

The equestrian sector contributes over £4 billion annually to the UK economy and supports substantial rural employment, tourism and small businesses. Despite this, the Local Plan makes no meaningful allowance for new equestrian development. By their nature, equestrian enterprises require access to extensive areas of land and are therefore appropriately located within the countryside. National policy, including Green Belt and countryside policies within the NPPF, does not prohibit such development, yet the Local Plan adopts an unduly restrictive approach that fails to reflect the operational needs of rural businesses.

The countryside should positively support sporting and recreational activities, including equestrian uses, but the current policy framework does not achieve this. Requirements such as locating car parking within a tight group of buildings are impractical for a well designed equestrian yard, where separation from equestrian activities is often necessary for health and safety reasons. In addition, the strong demand for brownfield land for housing makes it extremely difficult for rural businesses to acquire suitable previously developed sites.

Overall, the Local Plan is overly restrictive and risks discouraging new rural enterprises from establishing in Cambridgeshire. Rural policy support is largely framed around agricultural operations, with insufficient recognition of other land based rural businesses that are essential to the local economy, including equestrian enterprises. In Cambridgeshire alone, the non racing equestrian industry contributes over £115 million per annum, and nationally the equestrian sector is the second largest rural employer.

To align Policy H/GL with national guidance and promote sustainable housing delivery, the following changes should be recommended:

1. Broaden the Scope: Remove the restriction limiting garden and backland development only to areas where such development already exists. Allow proposals on appropriate garden and backland sites across settlements, subject to detailed assessment.

2. Design-Led Approach: Introduce wording that supports development where proposals are of high-quality design and respect the character, scale, and appearance of the surrounding area.

3. Amenity and Access Safeguards: Require that proposals maintain acceptable levels of residential amenity for neighbouring properties and provide safe and suitable access.

4. Efficient Use of Land: Explicitly reference the optimisation of site capacity in line with national planning policy, recognising the contribution of small sites to housing delivery.

A suggested wording could be:
"Proposals for garden or backland development will be supported where they are well designed, respect the character and appearance of the surrounding area, maintain residential amenity, provide safe and suitable access, and make efficient use of land, in line with national planning guidance."

This approach ensures the policy is flexible, evidence-based, and promotes sustainable housing growth without being unnecessarily constrained by historic development patterns.

Policy H/GL is overly restrictive and not aligned with emerging national planning policy, which promotes efficient use of land, optimisation of site capacity and the role of small sites, including garden and backland development, in housing delivery. Limiting such development only to areas where backland development already exists is particularly restrictive and risks constraining sustainable, well-designed housing opportunities. This approach places undue weight on historic patterns rather than planning merits. The policy should instead support garden land development where proposals are well designed and acceptable in terms of character, amenity and access.

To ensure Policy J/PB is consistent with national policy, reflects post-Covid changes in office demand, and supports effective reuse of underutilised brownfield sites, the following changes are recommended:

1. Remove the 12-Month Vacancy/Marketing Requirement: Delete any requirement for offices to be vacant or marketed for 12 months before the site secures change of use to office, aligning the policy with Class MA permitted development rights.

2. Allow Flexible Use: Introduce wording that supports office-to-residential conversions where proposals comply with relevant design, amenity, and environmental standards, without unnecessary restrictions.

3. Encourage Brownfield Reuse: Explicitly recognise the contribution of such conversions to housing delivery and the efficient use of land.

Suggested wording could be:
"Proposals for the conversion of office buildings to residential use will be supported where they comply with relevant design, amenity, and environmental requirements. The prior vacancy or marketing of the office building for 12 months will not be required where Class MA or other permitted development rights apply."

This revision ensures consistency with national guidance, promotes housing delivery, and allows for the effective reuse of underutilised office stock.

Policy J/PB is overly restrictive and does not reflect post-Covid changes in office use or national policy. Demand for traditional office space has reduced, and permitted development rights under Class MA allow office-to-residential conversion without the need to demonstrate 12 months’ vacancy. Requiring this test in policy creates an inconsistency with national permitted development rights and risks preventing the effective reuse of underutilised brownfield sites for much-needed housing. The policy should adopt a more flexible approach and align with Class MA by removing the 12-month marketing or vacancy requirement where office-to-residential conversion is proposed.

1. Flexibility for Economic Development: Allow development on agricultural land where there is demonstrable wider economic benefit, including rural business expansion, job creation, or community facilities.

2. Assessment of Land Use: Require consideration of whether the land is actively or viably farmed as part of any proposal.

3. Balanced Approach: Ensure the policy promotes sustainable development, balancing protection of agricultural value with economic and rural benefits.

Suggested wording:
"Development proposals on land designated as the best and most versatile agricultural land will be supported where they demonstrate that:
(a) the land is not actively or viably farmed; and/or
(b) the proposed development delivers clear economic, employment, or wider rural benefits; and
(c) any impacts on soil quality, landscape character, and the wider rural environment can be appropriately mitigated."

This approach ensures the policy is consistent with the NPPF, encourages sustainable rural economic growth, and avoids unnecessarily restricting development opportunities on underutilised or low-productivity agricultural land.

Policy J/AL is not consistent with national planning policy and is overly restrictive. The 2024 NPPF no longer seeks blanket protection of best and most versatile agricultural land, instead requiring recognition of its economic value (paragraph 187). This allows for economic redevelopment where there is wider economic benefit arising from its loss. The policy also fails to acknowledge that land within agricultural designations may not be actively or viably farmed. As drafted, Policy J/AL conflicts with the NPPF and should be revised to allow greater flexibility where alternative development delivers clear economic and rural benefits.

The Local Plan should be amended to provide explicit and unambiguous recognition of CSETS Phase 2 and the Busway Extensions as essential infrastructure underpinning the spatial strategy for both the edge of Cambridge and South Cambridgeshire. This should include clear commitments on delivery, timing and phasing, aligned with planned housing and employment growth. The Plan should also reassess site selection to ensure consistency with its stated objectives, particularly by reconsidering the exclusion of accessible and well serviced sites such as Site 40509 on Babraham Road. A more evidence led and infrastructure informed approach would improve certainty, support timely delivery, and make more effective use of sustainable locations.

The edge of Cambridge - The section references the infrastructure needed to support development on the edge of Cambridge, but it lacks clarity on what is required. In practice, delivery of schemes such as Grange Farm and the Cambridge Biomedical Campus expansion depends on CSET, yet this is not explicitly referenced. As identified within the Infrastructure Delivery Plan that informs the emerging Local Plan, both CSETS Phase 2 and the Busway Extensions are categorised as critical infrastructure. The delivery of CSETS is therefore fundamental to the effective implementation and overall success of the Local Plan.

It is reasonable to conclude that the delivery of CSETS is a key intention underpinning the spatial strategy of the Plan. However, this intention is not explicitly reflected within the Local Plan or its summary. The absence of a clear and specific reference to CSETS creates a risk that this infrastructure will not be delivered in a timely or coordinated manner. In turn, this would undermine the delivery of the housing and employment growth that the area urgently requires and which the Local Plan seeks to facilitate.

Greater certainty on the timing and delivery of such infrastructure would help bring forward suitable sites, such as Site 40509 on Babraham Road, currently excluded from housing due to Green Belt impact. Once CSET is operational, this site would become infill, with housing on two sides and CSET the third.

Rural South Cambridgeshire – While the principle of supporting villages with good services and transport links is sensible, the plan’s allocations do not reflect this objective. Excluding Site 40509 on Babraham Road solely due to Green Belt designation is inconsistent, as the site benefits from significantly better local services and accessibility than some of the group villages where allocations are proposed. Car travel is easier from 40509, yet it is not supported for development. The current approach undermines the stated goal of sustaining thriving rural communities while making efficient use of accessible sites.

We are extremely disappointed to see that site 40509 remains unallocated within the emerging Local Plan and strongly believe that this is unreasonable, unjustified and fails to be in accordance with the aims of your own Local Plan.

We have undertaken a review of the HELAA in the document library which confirms that there are clear and identifiable discrepancies between some of the allocated sites and the assessment undertaken for 40509. These are shown in our summary table and set out in more detail below.

These discrepancies clearly demonstrate that Site 40509’s RAG assessment, sustainability credentials (both current and projected) and its capacity to mitigate landscape impact, as confirmed by the LPA, establish it as one of the most sustainable sites for housing delivery in the district.

While we maintain that the site should be allocated, particularly given that other Green Belt sites with significantly lower performance have been approved, we have addressed the LPA’s concerns regarding Green Belt impact by reducing the red line boundary. The revised site area now aligns with the build lines of Site H/1:B (opposite) and Site H/1:C (adjacent), with the built form abutting the CSET transport hub to the east. This configuration effectively renders the site infill, surrounded by development on three sides. We consider that this adjustment resolves the LPA’s outstanding concerns and allows this highly sustainable site to be released from the Green Belt for the delivery of up to 24 dwellings.