Greater Cambridge Local Plan: Proposed Submission

The policy and supporting text should be amended to recognise that sports and leisure provision includes, where appropriate, privately provided recreational facilities which contribute to health, wellbeing and active lifestyles, including land-based recreational activities such as equestrianism.

The policy should also recognise that such facilities may appropriately be privately operated and located in rural areas where their functional requirements necessitate a countryside location, subject to consideration of landscape, environmental, highway and amenity impacts.

As equestrianism often includes change of use of land, it can quite quickly become a major application despite the built form being very minor. The policy should be amended to remove the requirement for all major applications to facilitate community access through a community use agreement, unless it s not feasible ‘or relevant’.

KWA Architects considers that the Plan does not adequately recognise the contribution that privately provided recreational facilities can make to health, wellbeing and active lifestyles, particularly in relation to equestrian activities.

Policy WS/CF is primarily framed around community, sports and leisure facilities which serve a defined catchment and are accessible to the wider community. While this is appropriate for many conventional leisure facilities, it does not reflect the full range of recreational activities undertaken by residents, particularly land-based activities such as equestrianism.

Private equestrian yards can provide an important leisure and wellbeing facility for individuals and families, enabling riding, exercise, participation in equestrian sport, interaction with horses and access to the countryside. These benefits do not depend upon the facility being open to the wider community. Indeed, the nature of private equestrian use means that facilities will often appropriately be privately owned and managed.
The current policy provides no clear recognition of such facilities or their contribution to health and wellbeing. Given that Policy WS/HD seeks to ensure that development provides opportunities for residents and workers to adopt healthy lifestyles, private recreational facilities should also be accommodated within the plan’s policies. The Plan should take a more comprehensive approach to leisure provision by recognising that recreational needs are not met solely through publicly accessible or community facilities.

Given the rural context of Greater Cambridge, equestrian activities are inherently land-based and private equestrian yards may need to be located in the countryside because of the land required for grazing, turnout, exercise and riding. A policy approach which considers leisure provision principally through the lens of accessible community facilities risks failing to recognise legitimate rural recreational needs.

The policy is therefore not fully justified or effective because it does not reflect the diversity of leisure and recreational activities undertaken by residents and provides no clear policy framework for considering the wellbeing benefits of privately provided sports and leisure facilities.

The policy and supporting text should be amended to recognise that opportunities for healthy lifestyles can be provided through both public and privately provided recreational facilities, including appropriate land-based activities such as equestrianism.

The policy should also recognise that such facilities may appropriately be privately operated and, where their functional requirements necessitate it, located in rural areas, subject to consideration of landscape, environmental, highway and amenity impacts.

KWA Architects considers that Policy WS/HD does not fully recognise the range of activities and facilities that can contribute to health and wellbeing, particularly privately provided recreational facilities such as equestrian yards.
The policy states that development will be supported where it provides opportunities for residents and workers to adopt healthy lifestyles. However, its approach to healthy development is principally considered through the provision of community facilities, accessible green infrastructure, active travel and other facilities serving the wider community. This does not recognise that important recreational activities can take place through privately provided facilities which are not publicly accessible.

Equestrianism is an established rural recreational activity in Greater Cambridge. The non-racing equestrian sector is estimated to contribute over £115 million per annum to the Cambridgeshire rural economy, demonstrating the scale and established nature of the sector. Private equestrian yards can provide opportunities for physical activity, outdoor recreation, participation in sport, interaction with horses and engagement with the countryside, with associated physical and mental wellbeing benefits. Such facilities are often necessarily private and land-based and therefore do not fit readily within a conventional model of community or publicly accessible leisure provision.
The Plan should recognise that healthy lifestyles and recreational needs are not met solely through publicly accessible facilities and should provide an appropriate policy framework for considering proposals which provide private recreational opportunities.

The omission is also inconsistent with the broader objective of Policy WS/HD, which seeks to ensure that development contributes to healthier communities. A policy framework which recognises the health benefits of recreation should not be limited to facilities that are publicly accessible where other forms of recreation can make a genuine contribution to health and wellbeing.

Policy WS/HD is therefore not fully justified or effective because it does not adequately reflect the diversity of recreational activities which contribute to healthy lifestyles, particularly in rural areas such as South Cambridgeshire.

The ‘Enhancing connectivity’ section should be amended to expressly recognise equestrian access and require development to protect and, provide or enhance connections for equestrians not just those walking, wheeling and cycling, taking account of both recorded rights of way and established informal routes.

KWA Architects considers that the ‘Enhancing connectivity’ section of Policy GP/QP does not adequately recognise equestrianism as a legitimate form of rural connectivity and recreation.

Although criterion f(ii) refers to access to public footpaths and public bridleways for equestrians, the wider connectivity requirements make no reference to equestrian access and focus principally on walking, wheeling and cycling. This is a significant omission given the rural character of much of Greater Cambridge and the established role of equestrianism in the local rural economy.

New development in rural areas can affect existing formal and informal off-road riding routes, including field-edge routes, farm tracks and permissive routes which may form part of a wider functional network even where they are not recorded public rights of way. Development should therefore identify and protect existing equestrian connections and provide appropriate new or improved routes for equestrians as well as pedestrians, cyclists and wheelers.

The non-racing equestrian sector contributes over £115 million per annum to the Cambridgeshire rural economy and represents an established rural recreational activity. Equestrian connectivity should therefore be considered alongside other forms of active travel and recreation when planning new development.

Policy J/AL should be amended to:

• require the agricultural value of land to be balanced against the economic, environmental and wider rural benefits of the proposed development without the need for demonstrating that the development cannot be located on areas of poorer quality land;

• remove the requirement that development must be incapable of being located on poorer quality land where a clear functional or operational need for the proposed location can be demonstrated;

• recognise that not all land within Grades 1, 2 or 3a is actively or viably farmed; and

• allow appropriate alternative and reversible rural uses, including equestrian uses, where the agricultural resource can be retained or reasonably restored in the future without requiring an onerous condition for it to be returned to agricultural land;

• ensure that uses involving limited or reversible changes to agricultural land are not automatically treated as permanent.

KWA Architects previously objected to Policy J/AL because it takes an overly restrictive approach to development affecting the best and most versatile agricultural land and does not adequately recognise alternative, reversible land uses, including equestrian uses. KWA specifically requested that where land is not being used to its full agricultural potential, appropriate alternative uses which can readily revert to agriculture should be supported.

The Regulation 19 Plan has not addressed this concern. The policy continues to state that planning permission will not be granted for development resulting in the irreversible loss of Grades 1, 2 or 3a agricultural land unless the land is allocated, or the need for development and sustainability considerations clearly outweigh the loss and the development cannot be located on poorer quality land.

This creates an unnecessarily restrictive policy framework. The December 2024 NPPF does not seek blanket protection of the best and most versatile agricultural land. Paragraph 187(b) requires the economic and other benefits of BMV agricultural land to be recognised, alongside protection of soils and the wider natural environment. The policy should therefore provide for a balanced assessment of agricultural value against the economic, social and environmental benefits of the proposed use.

This is particularly important for equestrian development. Equestrian enterprises require substantial areas of land, but much of that land can continue to provide agricultural or environmental functions through grazing, grassland management and other uses. The presence of an equestrian use on land intended for grazing does not necessarily result in the permanent loss of the agricultural resource.

The policy's treatment of uses which do not involve substantial built development is also unnecessarily restrictive. It states that such uses will be regarded as permanent unless specifically conditioned to require reinstatement. This could capture legitimate rural and equestrian uses of land which are capable of being temporary or reversible and which do not materially prejudice the future agricultural use of the land.

The policy also fails to recognise that the agricultural classification of land does not, in itself, demonstrate that land is actively or viably farmed. A blanket approach based on ALC grade risks preventing alternative rural enterprises from making productive use of land where there is limited agricultural benefit or where a proposed use would deliver wider economic and rural benefits.

This is particularly relevant given the importance of the equestrian and racing sector to the Cambridgeshire rural economy. The non-racing equestrian sector alone is estimated to contribute over £115 million per annum to the Cambridgeshire rural economy. The policy should not unnecessarily prevent investment in such land-based businesses simply because land falls within Grades 1, 2 or 3a.

Policy J/AL is therefore not justified or effective because it does not provide an appropriately balanced or flexible framework for assessing alternative rural land uses. It is not positively prepared because it fails to recognise the role that appropriate land-based businesses can play in supporting the rural economy. It is also not consistent with national planning policy because its approach goes beyond the balanced approach to the economic benefits of BMV agricultural land required by paragraph 187 of the December 2024 NPPF.

J/NE should explicitly recognise specialist rural and land-based businesses, including equestrian and equine enterprises. Where the operational requirements of such a business demonstrate a genuine functional need for a countryside location and access to substantial areas of land:

• the absence of a suitable previously developed site should be assessed having regard to the actual operational and landholding requirements of the business;

• the proposal should not be required to be well related to the built form of a settlement or easily accessible on foot or cycle where this would conflict with those requirements;

• appropriately located new buildings and facilities for new businesses should be supported where landscape, environmental, highway and amenity impacts are acceptable and necessary to support the business, and;

• demands for s106’s securing occupancy and business plans demonstrating viability should either be removed for rural commercial developments or be applied equitably to both urban and rural commercial development sites, to ensure that rural development sites are not disadvantaged by unreasonably and unjustified onerous policy requirements which may have the unintended consequences of curbing new rural economic growth in the district.

KWA Architects previously objected to Policy J/NE because it does not adequately recognise specialist rural employment, including equestrian and equine enterprises. These businesses are typically sui generis, require substantial areas of land for grazing, turnout, exercise and training, and therefore have a genuine functional requirement for countryside locations.

The Regulation 19 version of the Greater Cambridge Local Plan has not addressed this concern. Indeed, the locational requirements in J/NE are particularly problematic for such businesses. New employment development is expected to demonstrate that no suitable existing building or site, or previously developed land, is available, while also being well related to the built form of a settlement and easily accessible on foot or cycle. These are appropriate considerations for conventional employment uses but are not a realistic basis for locating land-based rural businesses.

The requirement to demonstrate that no suitable previously developed site is available is particularly problematic. The policy does not explain how this is to be demonstrated for a business requiring a substantial landholding, nor does it recognise that an existing building or previously developed site may be unsuitable because it lacks the land required for the operation. A building capable of accommodating employment is not an alternative to a site capable of accommodating the operational requirements of a stud farm, training yard or equestrian centre for instance.
Similarly, proximity to the built form of a settlement and accessibility by foot or cycle are not meaningful substitutions for the locational suitability of businesses whose primary requirement is access to suitable land. Applying these criteria without provision for genuine countryside-dependent businesses risks excluding them from the Plan altogether.

This is particularly significant given the economic importance of the equestrian sector in this part of the country. Evidence submitted to the Local Plan process identifies the non-racing equestrian industry as contributing over £115 million per annum to the Cambridgeshire rural economy. The Newmarket racing and breeding cluster also makes a substantial contribution to the wider economy, with the SQW 2022 study identifying £256.2 million in annual economic contribution and more than 3,200 direct jobs within its 25-mile economic area which includes part of the Greater Cambridge Plan area. Recent investment in new specialist facilities around Newmarket, including the approximately 400-acre Willingham House Stud proposal which lies in part in South Cambridgeshire, further demonstrates the demand for substantial countryside sites capable of accommodating modern equine businesses.
Importantly, the policies as currently written are unduly onerous for rural businesses, with an expectation that a business plan demonstrating viability and a costly and time-consuming s106 confirming occupation will be required to secure planning permission where such similar requirements are not demanded for urban commercial development. This policy as written is unreasonably onerous for businesses who rural location is a genuine need such as stud farms and racehorse training yards.

Importantly, as written the policy only provides for new rural business ‘on the edges of South Cambridgeshire town and villages’ and within the countryside, the policy provision is only for ‘expansion of existing businesses in the countryside’. This currently specifically excludes any new rural businesses which rely on a countryside location (such as a new stud farm) from being located within the Greater Cambridge district. Adjoining Newmarket, such a policy will be extremely damaging for the expansion of the racing industry.

The current policy approach is not consistent with the December 2024 NPPF. Paragraph 88 requires policies to enable the sustainable growth and expansion of all types of business in rural areas, including other land-based rural businesses. Paragraph 89 expressly recognises that rural business needs may require sites adjacent to or beyond existing settlements and in locations not well served by public transport. It encourages previously developed land and sites well related to settlements where suitable opportunities exist. J/NE does not provide sufficient flexibility where intended locations for rural business development are not suitable for the operational requirements of the business and provides no support for new businesses to invest in facilities in the district’s countryside. The Plan fails to recognise the importance of the rural economy as written.

The policy is therefore not justified or effective because it applies a settlement-based employment model to businesses which are inherently land-dependent and countryside-based. It is not positively prepared because it fails to provide an appropriate framework for the growth of an economically significant rural sector within the district.

J/RE should be amended to explicitly recognise specialist rural and land-based businesses, including equestrian and equine enterprises, and to provide a clear route for new development where required to establish new business or expand and/or maintain an existing viable rural business where this would involve new greenfield development.
Existing buildings should be reused where they are suitable and reasonably capable of accommodating the proposed use, rather than as an overriding requirement. The requirement for new development to form part of an existing group of buildings should be removed or qualified where the operational requirements of the business demonstrate a genuine need for a different site arrangement or countryside location. For example, good design principles dictates that vehicles and horses should be entirely separated on yards, so it would be entirely impractical and unsafe to required vehicles to be parked within the yard itself.

The requirement for significant employment or visitor-generating development to be located near larger settlements or accessible by public transport, cycling or walking should similarly recognise that such a requirement should not be necessary in circumstances where the functional requirements of a land-based business require a countryside location i.e. a major stud farm which requires access to hundreds of acres of land.

New buildings should not be omitted from the policy text, but instead new buildings and associated facilities should be supported where the scale, design, landscape, environmental, highway and amenity impacts are acceptable.

KWA Architects previously objected to Policy J/RE because it places undue reliance on the reuse or replacement of existing buildings and does not recognise the particular operational requirements of equestrian and other specialist land-based businesses. KWA specifically requested that the policy should not be limited to reuse and replacement of buildings where new development is necessary to support rural businesses.

The Regulation 19 version has not addressed this concern. Although the supporting text states that the policy seeks to support the sustainable growth and expansion of all types of business in rural areas, the actual policy wording provides no route for new rural employment development whatsoever. Development is limited to only re-use of buildings, replacement buildings or diversification schemes where any new development forms part of an existing group of buildings. The policy therefore only supports rural economic development where it uses or is based around existing built form, which by its nature is already limited within the countryside. This is wholly unacceptable. Allowing no new development on greenfield sites within the district fails to achieve the policy’s stated purpose of ‘supporting the rural economy’.

This policy is particularly problematic for equestrian businesses. Existing agricultural or rural buildings may be unsuitable for modern equine operations because of their location, configuration, surrounding land, horse welfare, biosecurity, safety and operational requirements. A suitable building alone is not an alternative to a site capable of accommodating grazing, turnout, exercise and training facilities. A large-scale stud farm will require multiple yards across hundreds of acres to ensure biosecurity and welfare requirements are met. Furthermore, permitted development opportunities for residential and commercial uses, including Classes Q and R, create increasing competition for the finite stock of suitable rural buildings and can make them commercially unavailable to rural businesses further limiting the scope of rural businesses to thrive under this Local Plan.

Even more worryingly, this policy also requires developments generating significant numbers of employees or visitors to be located near larger settlements or be accessible by public transport, cycling or walking. This is an unrealistic requirement for larger equestrian and land-based enterprises, where the primary locational requirement is access to substantial areas of suitable land. Applying a settlement-based model to these businesses risks preventing significant new rural investment from locating in Greater Cambridge.

This matters to the local economy. The non-racing equestrian industry contributes over £115 million per annum to the Cambridgeshire rural economy and is an important source of rural employment and diversification. The wider Newmarket racing and breeding cluster which extends into parts of Greater Cambridge is also of major economic significance and relies on specialist businesses and investment extending into the surrounding countryside to continue growing. Supporting the continued growth of the Home of Horseracing therefore requires provision for new investment and bespoke facilities in greenfield countryside locations, as well as the reuse of existing buildings.

The approach is not consistent with the December 2024 NPPF. Paragraph 88 requires policies to enable the sustainable growth and expansion of all types of business in rural areas through both existing and well-designed new buildings, and to support the development and diversification of agricultural and other land-based rural businesses. Paragraph 89 recognises that rural business needs may require sites adjacent to or beyond existing settlements and in locations not well served by public transport. Previously developed land and sites well-related to settlements are to be encouraged where suitable opportunities exist. J/RE does not provide any policy support for new rural economic development where the operational requirements of the business dictate a countryside location is necessary which is extremely worrying and a particular concern for the equestrian industry, in particular the racing industry which underpins parts of the rural economy in the area.

As written, the policy fails in its duty to support ALL rural businesses.

The policy is therefore not justified or effective because it does not reflect the operational and locational requirements of the rural businesses it seeks to support. It is not positively prepared because it fails to provide a realistic framework for new investment and the expansion of an economically significant rural sector.