Draft Greater Cambridge Local Plan for consultation

Policy I/ST: Sustainable Transport and Connectivity

Comment

The University of Cambridge, Corpus Christi, Downing, Jesus, and St Johns Colleges, collectively the North Barton Road Landowners Group (North BRLOG) has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension, which is referred to as South West Cambridge.

Policy I/ST of draft GCLP seeks to ensure that development promotes sustainable transport in order to reduce reliance on the car. Paragraph 110 of the NPPF expects the planning system to actively manage patterns of growth to support transport objectives. It is expected that significant development would be focused on locations which are or can be made sustainable, by limiting the need to travel and offering a genuine choice of transport modes. Paragraph 115 identifies factors that should be considered when assessing sites to be allocated for development, including that sustainable transport modes are prioritised, safe, and suitable access can be provided, and the impacts on the transport network and highway safety can be mitigated. Policy I/ST is broadly consistent with this national policy. It is noted that Paragraphs 110 and 115 of the NPPF are referred to in Paragraph 148 in terms of assessing sites to be released from the Green Belt.

North BRLOG have promoted land at South West Cambridge. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but additional land should be allocated in the more sustainable locations, including at the edge of Cambridge to implement this approach.

The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. It is well-related to the future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway. The Cambourne to Cambridge Busway is a dedicated bus route that includes a shared pedestrian/cycle path. The route for the proposed Cambourne to Cambridge Busway would be adjacent to the northern boundary of the site. The promoted development could include a bus stop for the Cambourne to Cambridge Busway route at the proposed local centre in the north eastern part of the site. The route for the Comberton Greenway would also be adjacent to the northern boundary of the site. As part of the Comberton Greenway project, work is currently taking place on Adams Road, which will give priority to cyclists and provide wider pavements for pedestrians. The route for the Barton Greenway would be adjacent to the southern boundary of the site. As part of the Barton Greenway project, shared cycle/pedestrian paths are currently being installed on Barton Road. The promoted development at South West Cambridge would include pedestrian and cycle connections with the Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway, which would enable residents to undertake journeys from the site by sustainable modes of transport.

The promoted development is well-related to the current and future employment opportunities at Cambridge West and North West Cambridge, and to other employment opportunities available in the City. It is accessible to those employment opportunities by walking, cycling and public transport.

In addition to the substantial benefits of a new sustainable community, the promoted development would enable the provision of a reliable, sustainable public transport route that can connect the Cambridge West Innovation District and the Cambridge Biomedical Campus. This can be achieved by having a north-south bus only access through the site from Cambridge West to Barton Road.

Linking these major employment centres with a reliable public transport route will unlock significant benefits for the local economy and the research activities of the University and partners.

It will further connect the emerging orbital transport routes around the city as well as the Cambourne to Cambridge busway through a travel hub, enabling interchange and access to active travel options.

It is considered that additional development at South West Cambridge would be consistent with Policy I/ST of draft GCLP and with national policy.

In addition, the promoted development at South West Cambridge would have all of the attributes of a 20-minute neighbourhood e.g. a complete, compact, and connected neighbourhood, where people can meet their everyday needs within a short walk or cycle.

As set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP to direct additional development to sustainable locations, including to South West Cambridge.

Policy S/DS: Development Strategy

Object

The University of Cambridge, Corpus Christi, Downing, Jesus, and St Johns Colleges, collectively the North Barton Road Landowners Group (North BRLOG) has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension, which is referred to as South West Cambridge.

Policy S/DS of draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm near Little Abington (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP. The land at North East Cambridge is carried forward as an allocation on the assumption that other funding may be found to enable the relocation of the Cambridge Waste Water Treatment Plant, which would enable the redevelopment of the site for mixed-use development.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm near Little Abington are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, based on more realistic annual delivery rates and taking into account the delivery timetable of necessary associated infrastructure.

Most of the existing new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm near Little Abington would also be reduced for the same reasons. The housing target and development strategy for draft GCLP should be amended so that more affordable housing is delivered during the plan period i.e. by increasing the housing target to meet more affordable housing needs, and by allocating more land for residential development at sites that deliver policy compliant levels of affordable housing. It is the strategic sites on the edge of Cambridge that have sufficient residual value to meet planning obligations and policy requirements including for affordable housing. An updated Economic Analysis of Development in Greater Cambridge Report is submitted with these representations, to compare the residual values for edge of Cambridge sites with strategic sites at new settlements. The promoted development at South West Cambridge would provide policy compliant levels of affordable housing, which for a Green Belt release site under the current NPPF would be 50% affordable housing.

It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. As set out in the representations to Policy S/JH, the housing target for draft GCLP should be subject to upward adjustments for economic growth and affordable housing reasons. Paragraph 145 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist.

Paragraph 147 of the NPPF requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not a straightforward option. The adopted Cambridge Local Plan and South Cambridgeshire Local Plan already identify previously developed land opportunities, and draft GCLP allocates land within the Cambridge urban area for redevelopment to provide for housing and employment uses. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge. The delivery of previously developed land opportunities for other uses can often be difficult, particularly when existing uses need to relocate and alternative sites in suitable locations are not available. The option of increasing densities within Cambridge may be inappropriate in some cases because of the potential impacts on heritage assets, and the potential relationship with neighbouring uses. The option of neighbouring areas accommodating housing needs of Greater Cambridge has been considered for draft GCLP but not pursued. It should be noted that the neighbouring areas also have their own development needs to meet, some of those areas include land within the Green Belt, and directing housing further from Cambridge where employment opportunities exist is not a sustainable option.

Paragraph 148 of the NPPF seeks to ensure that when land is released from the Green Belt the priority is for previously developed land, followed by grey belt, and then other Green Belt locations. The need to promote sustainable patterns of development should also be taken into account in decisions about sites to be released from the Green Belt, which is related to access by sustainable modes of transport, minimising the need to travel, reducing congestion, and improving air quality. The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. It is well-related to the future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway. It is well-related to the current and future employment opportunities at Cambridge West and North West Cambridge, and to other employment opportunities available in the City. It is considered that parts of the land at South West Cambridge would meet the definition for grey belt land i.e. it does not strongly contribute towards Green Belt purposes (a), (b), or (d). For all these reasons, the land at South West Cambridge should be released from the Green Belt.

As required by Paragraph 156 of the NPPF, land released from the Green Belt on the edge of Cambridge would be required to provide 50% affordable housing. The additional affordable housing to be provided from Green Belt sites is a significant benefit that should have been considered in the development strategy and the assessment of development options for draft GCLP. The delivery of higher proportion of affordable housing from Green Belt sites is a positive outcome, taking into account the need for affordable housing, and when compared with the lower amounts of affordable housing that is being delivered at the existing new settlements at Cambourne, Northstowe and Waterbeach.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations.

It is requested that the requirement for 50% affordable housing at Green Belt sites, and the benefits for the overall delivery of affordable housing, is reassessed in the development strategy

It is requested that additional allocations are made on the edge of Cambridge, including at South West Cambridge.

It is requested that land is released from the Green Belt to meet the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations.

It is requested that the requirement for 50% affordable housing at Green Belt sites, and the benefits for the overall delivery of affordable housing, is reassessed in the development strategy.

Policy S/DS: Development Strategy

Object

The University of Cambridge, Corpus Christi, Downing, Jesus, and St Johns Colleges, collectively the North Barton Road Landowners Group (North BRLOG) has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension, which is referred to as South West Cambridge.

Policy S/DS of draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm near Little Abington (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP. The land at North East Cambridge is carried forward as an allocation on the assumption that other funding may be found to enable the relocation of the Cambridge Waste Water Treatment Plant, which would enable the redevelopment of the site for mixed-use development.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm near Little Abington are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, based on more realistic annual delivery rates and taking into account the delivery timetable of necessary associated infrastructure.

Most of the existing new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm near Little Abington would also be reduced for the same reasons. The housing target and development strategy for draft GCLP should be amended so that more affordable housing is delivered during the plan period i.e. by increasing the housing target to meet more affordable housing needs, and by allocating more land for residential development at sites that deliver policy compliant levels of affordable housing. It is the strategic sites on the edge of Cambridge that have sufficient residual value to meet planning obligations and policy requirements including for affordable housing. An updated Economic Analysis of Development in Greater Cambridge Report is submitted with these representations, to compare the residual values for edge of Cambridge sites with strategic sites at new settlements. The promoted development at South West Cambridge would provide policy compliant levels of affordable housing, which for a Green Belt release site under the current NPPF would be 50% affordable housing.

It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. As set out in the representations to Policy S/JH, the housing target for draft GCLP should be subject to upward adjustments for economic growth and affordable housing reasons. Paragraph 145 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist.

Paragraph 147 of the NPPF requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not a straightforward option. The adopted Cambridge Local Plan and South Cambridgeshire Local Plan already identify previously developed land opportunities, and draft GCLP allocates land within the Cambridge urban area for redevelopment to provide for housing and employment uses. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge. The delivery of previously developed land opportunities for other uses can often be difficult, particularly when existing uses need to relocate and alternative sites in suitable locations are not available. The option of increasing densities within Cambridge may be inappropriate in some cases because of the potential impacts on heritage assets, and the potential relationship with neighbouring uses. The option of neighbouring areas accommodating housing needs of Greater Cambridge has been considered for draft GCLP but not pursued. It should be noted that the neighbouring areas also have their own development needs to meet, some of those areas include land within the Green Belt, and directing housing further from Cambridge where employment opportunities exist is not a sustainable option.

Paragraph 148 of the NPPF seeks to ensure that when land is released from the Green Belt the priority is for previously developed land, followed by grey belt, and then other Green Belt locations. The need to promote sustainable patterns of development should also be taken into account in decisions about sites to be released from the Green Belt, which is related to access by sustainable modes of transport, minimising the need to travel, reducing congestion, and improving air quality. The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. It is well-related to the future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway. It is well-related to the current and future employment opportunities at Cambridge West and North West Cambridge, and to other employment opportunities available in the City. It is considered that parts of the land at South West Cambridge would meet the definition for grey belt land i.e. it does not strongly contribute towards Green Belt purposes (a), (b), or (d). For all these reasons, the land at South West Cambridge should be released from the Green Belt.

As required by Paragraph 156 of the NPPF, land released from the Green Belt on the edge of Cambridge would be required to provide 50% affordable housing. The additional affordable housing to be provided from Green Belt sites is a significant benefit that should have been considered in the development strategy and the assessment of development options for draft GCLP. The delivery of higher proportion of affordable housing from Green Belt sites is a positive outcome, taking into account the need for affordable housing, and when compared with the lower amounts of affordable housing that is being delivered at the existing new settlements at Cambourne, Northstowe and Waterbeach.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations.

It is requested that the requirement for 50% affordable housing at Green Belt sites, and the benefits for the overall delivery of affordable housing, is reassessed in the development strategy

It is requested that additional allocations are made on the edge of Cambridge, including at South West Cambridge.

Release land at South West Cambridge (HELAA Ref. 52643) from the Green Belt and allocate the land for development.

Policy S/DS: Development Strategy

Object

The University of Cambridge, Corpus Christi, Downing, Jesus, and St Johns Colleges, collectively the North Barton Road Landowners Group (North BRLOG) has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension, which is referred to as South West Cambridge.

Policy S/DS of draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm near Little Abington (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP. The land at North East Cambridge is carried forward as an allocation on the assumption that other funding may be found to enable the relocation of the Cambridge Waste Water Treatment Plant, which would enable the redevelopment of the site for mixed-use development.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm near Little Abington are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, based on more realistic annual delivery rates and taking into account the delivery timetable of necessary associated infrastructure.

Most of the existing new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm near Little Abington would also be reduced for the same reasons. The housing target and development strategy for draft GCLP should be amended so that more affordable housing is delivered during the plan period i.e. by increasing the housing target to meet more affordable housing needs, and by allocating more land for residential development at sites that deliver policy compliant levels of affordable housing. It is the strategic sites on the edge of Cambridge that have sufficient residual value to meet planning obligations and policy requirements including for affordable housing. An updated Economic Analysis of Development in Greater Cambridge Report is submitted with these representations, to compare the residual values for edge of Cambridge sites with strategic sites at new settlements. The promoted development at South West Cambridge would provide policy compliant levels of affordable housing, which for a Green Belt release site under the current NPPF would be 50% affordable housing.

It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. As set out in the representations to Policy S/JH, the housing target for draft GCLP should be subject to upward adjustments for economic growth and affordable housing reasons. Paragraph 145 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist.

Paragraph 147 of the NPPF requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not a straightforward option. The adopted Cambridge Local Plan and South Cambridgeshire Local Plan already identify previously developed land opportunities, and draft GCLP allocates land within the Cambridge urban area for redevelopment to provide for housing and employment uses. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge. The delivery of previously developed land opportunities for other uses can often be difficult, particularly when existing uses need to relocate and alternative sites in suitable locations are not available. The option of increasing densities within Cambridge may be inappropriate in some cases because of the potential impacts on heritage assets, and the potential relationship with neighbouring uses. The option of neighbouring areas accommodating housing needs of Greater Cambridge has been considered for draft GCLP but not pursued. It should be noted that the neighbouring areas also have their own development needs to meet, some of those areas include land within the Green Belt, and directing housing further from Cambridge where employment opportunities exist is not a sustainable option.

Paragraph 148 of the NPPF seeks to ensure that when land is released from the Green Belt the priority is for previously developed land, followed by grey belt, and then other Green Belt locations. The need to promote sustainable patterns of development should also be taken into account in decisions about sites to be released from the Green Belt, which is related to access by sustainable modes of transport, minimising the need to travel, reducing congestion, and improving air quality. The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. It is well-related to the future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway. It is well-related to the current and future employment opportunities at Cambridge West and North West Cambridge, and to other employment opportunities available in the City. It is considered that parts of the land at South West Cambridge would meet the definition for grey belt land i.e. it does not strongly contribute towards Green Belt purposes (a), (b), or (d). For all these reasons, the land at South West Cambridge should be released from the Green Belt.

As required by Paragraph 156 of the NPPF, land released from the Green Belt on the edge of Cambridge would be required to provide 50% affordable housing. The additional affordable housing to be provided from Green Belt sites is a significant benefit that should have been considered in the development strategy and the assessment of development options for draft GCLP. The delivery of higher proportion of affordable housing from Green Belt sites is a positive outcome, taking into account the need for affordable housing, and when compared with the lower amounts of affordable housing that is being delivered at the existing new settlements at Cambourne, Northstowe and Waterbeach.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations.

It is requested that the requirement for 50% affordable housing at Green Belt sites, and the benefits for the overall delivery of affordable housing, is reassessed in the development strategy

It is requested that additional allocations are made on the edge of Cambridge, including at South West Cambridge.

Allocate South West Cambridge (HELAA Ref. 52643) for development as part of the Greater Cambridge Local Plan.

Policy S/DS: Development Strategy

Object

The University of Cambridge, Corpus Christi, Downing, Jesus, and St Johns Colleges, collectively the North Barton Road Landowners Group (North BRLOG) has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension, which is referred to as South West Cambridge.

Policy S/DS of draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm near Little Abington (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP. The land at North East Cambridge is carried forward as an allocation on the assumption that other funding may be found to enable the relocation of the Cambridge Waste Water Treatment Plant, which would enable the redevelopment of the site for mixed-use development.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm near Little Abington are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, based on more realistic annual delivery rates and taking into account the delivery timetable of necessary associated infrastructure.

Most of the existing new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm near Little Abington would also be reduced for the same reasons. The housing target and development strategy for draft GCLP should be amended so that more affordable housing is delivered during the plan period i.e. by increasing the housing target to meet more affordable housing needs, and by allocating more land for residential development at sites that deliver policy compliant levels of affordable housing. It is the strategic sites on the edge of Cambridge that have sufficient residual value to meet planning obligations and policy requirements including for affordable housing. An updated Economic Analysis of Development in Greater Cambridge Report is submitted with these representations, to compare the residual values for edge of Cambridge sites with strategic sites at new settlements. The promoted development at South West Cambridge would provide policy compliant levels of affordable housing, which for a Green Belt release site under the current NPPF would be 50% affordable housing.

It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. As set out in the representations to Policy S/JH, the housing target for draft GCLP should be subject to upward adjustments for economic growth and affordable housing reasons. Paragraph 145 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist.

Paragraph 147 of the NPPF requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not a straightforward option. The adopted Cambridge Local Plan and South Cambridgeshire Local Plan already identify previously developed land opportunities, and draft GCLP allocates land within the Cambridge urban area for redevelopment to provide for housing and employment uses. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge. The delivery of previously developed land opportunities for other uses can often be difficult, particularly when existing uses need to relocate and alternative sites in suitable locations are not available. The option of increasing densities within Cambridge may be inappropriate in some cases because of the potential impacts on heritage assets, and the potential relationship with neighbouring uses. The option of neighbouring areas accommodating housing needs of Greater Cambridge has been considered for draft GCLP but not pursued. It should be noted that the neighbouring areas also have their own development needs to meet, some of those areas include land within the Green Belt, and directing housing further from Cambridge where employment opportunities exist is not a sustainable option.

Paragraph 148 of the NPPF seeks to ensure that when land is released from the Green Belt the priority is for previously developed land, followed by grey belt, and then other Green Belt locations. The need to promote sustainable patterns of development should also be taken into account in decisions about sites to be released from the Green Belt, which is related to access by sustainable modes of transport, minimising the need to travel, reducing congestion, and improving air quality. The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. It is well-related to the future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway. It is well-related to the current and future employment opportunities at Cambridge West and North West Cambridge, and to other employment opportunities available in the City. It is considered that parts of the land at South West Cambridge would meet the definition for grey belt land i.e. it does not strongly contribute towards Green Belt purposes (a), (b), or (d). For all these reasons, the land at South West Cambridge should be released from the Green Belt.

As required by Paragraph 156 of the NPPF, land released from the Green Belt on the edge of Cambridge would be required to provide 50% affordable housing. The additional affordable housing to be provided from Green Belt sites is a significant benefit that should have been considered in the development strategy and the assessment of development options for draft GCLP. The delivery of higher proportion of affordable housing from Green Belt sites is a positive outcome, taking into account the need for affordable housing, and when compared with the lower amounts of affordable housing that is being delivered at the existing new settlements at Cambourne, Northstowe and Waterbeach.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations.

It is requested that the requirement for 50% affordable housing at Green Belt sites, and the benefits for the overall delivery of affordable housing, is reassessed in the development strategy

It is requested that additional allocations are made on the edge of Cambridge, including at South West Cambridge.