Greater Cambridge Local Plan: Proposed Submission

It is considered that the strategic priorities for draft GCLP would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Impington.

COMMENT

Wates Manor Oak has promoted a site in Impington. The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the proposed housing target, the development strategy and the selected allocations for draft GCLP are unlikely to fully deliver the strategic priorities. Wates Manor Oak commented on the strategic priorities at Reg.18 stage.

The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. This outcome would not meet the climate change strategic priority. The development strategy is too focussed on the delivery of large strategic sites, where the timetable for the delivery of necessary infrastructure is uncertain in some cases, the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. It is considered that housing and affordable housing needs would not be met by a development strategy based on this approach, and would not meet the homes strategic priority. The development strategy avoids directing development to the more sustainable villages, including Impington, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs. This approach does not support the residents or services and facilities in those villages, and would not meet the great places, homes, connectivity and infrastructure strategic priorities. It is noted that some green infrastructure opportunity areas identified in draft GCLP, including close to Impington, are unrelated to strategic development allocations that could support their delivery. In these circumstances those proposed green infrastructure opportunity areas are unlikely to be delivered, and this outcome would not meet the biodiversity and green spaces strategic priority. Wates Manor Oak made similar comments at Reg.18 stage, but no changes to policies have been made in draft GCLP.

It is considered that the strategic priorities for draft GCLP would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Impington.

Requested Change

The following changes to Policy S/JH are requested.

It is requested that the housing target is recalculated to include the previous commuting patterns adjustment, consistent with the adjustment made in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report.

It is requested that the housing target includes some upward adjustments for growth ambitions, that reflect the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal, the adopted Local Growth Plan of the Mayor for Peterborough & Cambridgeshire, and the Cambridge Growth Company.

It is requested that housing target include some upward adjustment to address affordable housing needs.

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/JH of draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,069 dwellings. The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,289 dwellings per annum. In summary, the housing target is not consistent with national policy because upward adjustments for growth and affordable housing have not been considered. Wates Manor Oak and others raised the same concerns about Policy S/JH at Reg.18 stage, but those concerns have been ignored.

It is noted that the job target is not aligned with the housing target. It is considered that a job target that is higher than the housing target would require potential employees to commute into Greater Cambridge to fill those jobs. This outcome would lead to an increase in in-commuting to Greater Cambridge. This outcome would be made worse by the proposed development strategy that avoids directing development to the larger villages that are accessible by sustainable modes of transport. It is anticipated that most of the in-commuting would be by car, particularly if public transport options are not available or the delivery of transport infrastructure projects are subject to unconfirmed funding decisions and associated development.

The housing target identified in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report was based on a Central Growth Scenario, the preferred 2011 Census commuting data, and included a 1:1 commuting patterns adjustment. This previous approach sought to better align the job and housing targets. The 2025 Greater Cambridge Employment and Housing Needs Update 2024-2045 Report does not include a similar commuting patterns adjustment, which is an inconsistent approach. It is requested that the housing target is recalculated to include the previous commuting patterns adjustment. Wates Manor Oak made the same comment at Reg.18 stage.

Paragraph 61 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 62 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 63 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need. Paragraph 69 states in part that “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. Paragraph 008 (ID. 67 - Housing needs of different groups) in the Planning Practice Guidance states in part that “An increase in the total housing requirement included in the plan may need to be considered where it could help deliver the required number of affordable homes”. The housing target in Policy S/JH is based on the standard method only, with no adjustments for growth linked to economic development and infrastructure investment or to meet affordable housing needs, all of which are relevant to Greater Cambridge.

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has had an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal included a commitment to deliver substantial economic growth and to double economic output during the next 25 years. The adopted Local Growth Plan of the Mayor for Peterborough & Cambridgeshire sets out two growth scenarios: a core scenario which doubles the economy by 2050; and an aspirational scenario which triples the economy by 2050. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership have previously acknowledged and supported the economic growth potential of the Greater Cambridge area, and concluded that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge. The housing target in Policy S/JH ignores the commitments made in the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal. It also ignores the findings of work undertaken by the National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership.

In 2024 the Government established a Cambridge Growth Company to maximise Cambridge’s full economic potential and to deliver nationally significant growth. The Growth Company will seek to unlock and accelerate development for Cambridge, and to deliver the homes, jobs and infrastructure needed for the long-term and sustainable growth of the City. It will seek to deliver more ambitious levels of growth than are proposed in the emerging Greater Cambridge Local Plan. In order to deliver more ambitious levels of growth, the Growth Company will need to tackle some of the barriers to growth including water and transport infrastructure, traffic congestion, and housing affordability. It is acknowledged that draft GCLP does not need to take into account the levels of growth to be addressed by the Cambridge Growth Company. However, it does indicate that there are growth ambitions for Greater Cambridge and there should be some upward adjustment to the housing target in Policy S/JH to reflect this future growth during the plan period for draft GCLP.

There are a number of proposed and planned infrastructure projects in Greater Cambridge that should have been taken into account in deciding whether adjustments should be made to the housing target in Policy S/JH. The list of infrastructure projects includes East West Rail, Cambourne to Cambridge Busway, Cambridge South East Transport project, Waterbeach to Cambridge Busway, Cambridge Eastern Access project, and Cambridge South Station. In addition, the Greater Cambridge Partnership is delivering greenways to connect surrounding villages to Cambridge by walking and cycling. The funding for some of these projects have not been confirmed, but it is anticipated that they will need to be supported by associated development.

The 2025 ‘Housing Needs of Specific Groups in Cambridge and South Cambridgeshire’ Report identifies the housing needs of different groups, including the need for affordable housing. Chapter 7 of the Report deals with affordable housing need. The Report identifies an acute need for affordable housing in Greater Cambridge. It estimates an annual need for 1,083 affordable homes for households unable to buy or rent housing across Greater Cambridge, excluding those that can rent but not buy – see Paragraph 7.62 in the Report. It includes an analysis of the affordable housing need if those households already living in accommodation are excluded, which would be an affordable need for 425 homes per annum in Cambridge and 318 dwellings per annum in South Cambridgeshire – see Paragraph 7.63 in the Report. A combined figure for Greater Cambridge would be 743 affordable homes per year. It is acknowledged that the affordable housing data is complex, households needs will change over time, and the annual affordable housing needs should not be multiplied to generate a figure for the whole plan period. The Report concludes that no adjustments are required to the housing target for draft GCLP to address affordable housing needs. This cannot be correct. The annual monitoring data shows that affordable housing delivery in Greater Cambridge does fluctuate each year, but does show that c.500 affordable dwellings are provided on average each year, which is less than the current need. In addition, some the existing strategic sites are not able to deliver policy compliant levels of affordable housing (e.g. Northstowe and Waterbeach new settlements) because of the need to provide significant amounts of new infrastructure, and it is anticipated that the outcome would be the same for the proposed strategic sites at North Cambourne and Grange Farm. If affordable housing needs are to be met then a higher housing target and additional allocations should be identified in draft GCLP to address the shortfall in the delivery of affordable housing from the existing and proposed strategic sites. It is considered that the housing target in Policy S/JH should include some upward adjustment to address affordable housing needs. It should be noted that Paragraph 008 (ID.67 in the PPG) relates to the delivery of affordable housing, and is distinct from housing affordability which is a separate factor included in the standard method calculations. Wates Manor Oak raised the same concerns about the delivery of affordable housing at Reg.18 stage.

It is considered that the housing target in Policy S/JH is not sound, in that the proposed approach is not justified as an appropriate strategy, and is not consistent with national policy in terms of not including upward adjustments for growth and affordable housing (NPPF Paragraph 69 and PPG Paragraph 008 in ID.67).

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 additional allocations are made in the more sustainable villages, including at the Rural Centres such as Histon and Impington.

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

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 (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP.

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, and in the case of Cambourne North does not take into account the close proximity of other strategic sites i.e. Cambourne West and Bourn Airfield. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm 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. Wates Manor Oak raised these same concerns at Reg.18 stage, but they have not been taken into account and no amendments have been made for draft GCLP.

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 would also be reduced for the same reasons, and particularly during the initial stages of those developments. A reduction in the delivery of affordable housing in the initial stages of Cambourne North and Grange would also affect the housing delivery rates overall because it would reduce the mix of available housing.

The Rural Centres, including Histon and Impington, are referred to as part of the development strategy but there are no new residential allocations in this category of settlement. It is considered that the growth of the more sustainable villages should be part of the development strategy for draft GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Histon and Impington falls within this category.

Wates Manor Oak has promoted land north of Impington Lane, Impington for residential development. The promoted development would deliver affordable housing to meet the identified needs for the village. It would support the existing services and facilities in the village. The site is accessible by sustainable modes of transport. It is medium sized site that could be delivered relatively quickly. It could contribute towards maintaining a sufficient housing land supply in the short term, and in advance of the delivery of the larger strategic site allocations.

It is considered that the development strategy in Policy S/DS is not sound, in that it is not justified as an appropriate strategy, and is not consistent with national policy in terms of not identifying sufficient housing land to meet housing needs (NPPF Paragraph 23).

Requested Change

It is requested that a review is undertaken of the capacity of the more sustainable settlements in South Cambridgeshire, including Rural Centres such as Impington, to determine whether additional development can be accommodated within the existing development framework boundary, and given that there are no restrictions in Impington regarding individual scheme sizes, additional allocations should be made on the edge of those villages.

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs, then additional allocations should be made on the edge of those villages.

COMMENT

Policy S/SH of draft GCLP defines the settlement hierarchy. Wates Manor Oak has promoted a site in Impington. Histon and Impington is defined as a Rural Centre in the settlement hierarchy. Rural Centres have no limit on individual scheme size and are considered the most sustainable location for new development within the defined development extents of those villages.

Impington contains an excellent range of services and facilities, including schools, foodstores, a variety of other convenience stores, a post office, library, doctor's surgery, pharmacy, public houses, restaurants, employment and sports facilities. The promoted development at land north of Impington Lane in Impington is accessible by walking, cycling and public transport and there are bus stops nearby, and the site is well-related to the Cambridge Guided Busway stop to the south of the village on Station Road. The Cambridgeshire Guided Busway, provides services to St Ives, Huntingdon, and Cambridge. Cambridge North Railway Station is easily accessible to the village by cycle, with Cambridge also within easy cycle distance. Impington is a highly sustainable location for new development and is correct categorised as a Rural Centre.

However, there has been no review of the capacity of settlements for draft GCLP, including at Impington, to determine whether land is available within the development framework boundary to accommodate additional development, or whether the development threshold limits remain relevant if no sites are available. There appears to be no major residential development opportunities within the development framework boundary of Impington. Any development opportunities that do exist would be small scale and would not deliver affordable housing or provide any meaningful support to existing services and facilities. The most recent developments at Impington have been located on land outside the development framework boundary within the Green Belt, which indicates that no suitable development sites are available within the boundary.

As set out in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the most sustainable villages including Impington to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

No changes are requested to Policy S/DE. However, as set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Impington which is critical to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

COMMENT

Policy S/DE of draft GCLP set out the approach to development within and outside the defined development extents of villages. Wates Manor Oak does not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire, including Impington, have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018. In Impington, heritage assets (listed buildings and conservation area) and protected village amenity area designations restrict development opportunities within the settlement boundary.

The currently defined development framework boundary for Impington means that limited development would take place in this village. The housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities.

No changes are requested to Policy S/DE. However, as set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Impington which is critical to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

Requested Change

It is requested that land north of Impington Lane in Impington (Site Ref. 40061) is allocated with the following policy requirements:

• Site Area of 2.34 Ha
• Capacity to be informed by findings of landscape assessment
• Residential development including affordable housing
• Provide a shared pedestrian and cycle connection with the adjoining Hunters Close development to the south.
• Provide strategic landscaping at northern, eastern and western boundaries
• Retain trees and hedgerows at site boundary
• Provide open space and green infrastructure

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct development to the more sustainable villages, and there are exceptional circumstances to release land from the Green Belt. All these factors indicate that additional allocations should be made in draft GCLP to meet development needs.

Wates Manor Oak has promoted land north of Impington Lane, Impington (Site Ref. 40061) for residential development. The site assessment in the updated HELAA has identified mostly ‘amber’ and some ‘green’ scores in terms of the suitability of the site to accommodate development. A ‘red’ score is identified for Flood Risk, Landscape and Townscape, Site Access and Strategic Highways Impact.

In response, previous Representations for the site were accompanied by a landscape capacity and Green Belt review and updated Masterplan. These demonstrated how the identified landscape concerns can be satisfactorily addressed; both in principle, by illustrating that the site is not as visible as previously assumed, and that latterly the effects could be resolved through a suitable landscape design strategy. An updated Flood Risk Review note has also been prepared and updated flood mapping confirms that the site falls within Flood Zone 1. Access to the site would be through Hunters Close immediately to the south and therefore a safe and direct access to the adopted Public Highway can be provided. There are also not considered to be any strategic highway issues that would preclude the development of the site, particularly given the number of units the site can accommodate.

It is concluded in the assessment of the site in the HELAA that development at the site, on the northern edge of the village, would be further encroachment into the countryside and would be difficult to develop without exposing extensive views of it from the north and north east. The site is not within a protected landscape, and there are no public footpaths in the vicinity of the site that provide public views of the site. The site is fairly well contained, and there are trees and hedgerows at the site boundary and in the surrounding area that limit views of the site. The existing trees and hedgerows at the site boundaries would mostly be retained and enhanced. The promoted development would include additional landscape screening and mitigation along the boundaries to mitigate the impact on landscape character and views of the site. The promoted development would include open space and green infrastructure within the site, which would contribute towards addressing the landscape and visual impacts. It is considered that these measures would make the proposed development acceptable in landscape terms. A detailed landscape and visual impact assessment and a landscape strategy would inform the design and layout of the promoted development.

The assessment of the site in the HELAA highlights the good accessibility of the site. The site is accessible by walking, cycling and public transport. There is a shared pedestrian/cycle path and bus stops in close proximity to the site, which provide connections from the site to the Cambridgeshire Guided Busway stop and to Cambridge. The site is within easy cycling distance of both Cambridge and Cambridge North Railway Station. Impington is one of the most sustainable settlements within South Cambridgeshire and additional development should be supported.

An agricultural land survey, flood risk assessment and drainage strategy, transport statement, landscape and visual impact assessment and landscape strategy, ecological assessment, and archaeological assessment would be prepared for the promoted development at planning application stage. Importantly the site is largely free form constraints, meaning that it is available, and can be readily delivered within 5 years. The site constitutes Phase 2 of the successful Hunters Close development that was delivered 8 years ago.

It is requested that this site is identified as an additional allocation in Policy S/RRA: Rest of Rural Area.