Greater Cambridge Local Plan: Proposed Submission

Increase the housing delivery to a minimum of 61,000 new homes which is more akin with the likely housing needs given the planned employment growth.

The current ratio of jobs to new homes is inadequate, with 73,300 jobs and only 48,069 new homes, potentially leading to excessive commuting from outside Greater Cambridgeshire.
There is a need for additional housing development to optimise the use of sustainable transport options, especially given the significant infrastructure investments in the area, including a further guided bus, East West Rail and the A428.

Table 5 would benefit from clarification that all figures are percentages.

Amend Figure 7 to adjust the assumed delivery in 2029/30 (or provide compelling justification).

The allocation at Cambourne should be expanded to include the land between the existing A428 road and the allocated land - this would include land owned by Abbey.
Amend to the method for housing land supply throughout the plan to the Sedgefield approach and adjust the draft plan accordingly.

Identify and allocate smaller sites in accordance with paragraphs 73 and 75 of the 2024 NPPF.

Figure 7 includes a spike in housing delivery in 2029/30 which requires justification from the Council as the the delivery appears to be over 1,000 additional dwellings in a single year when compared with other monitoring years. This equates to 20 additional homes per week coming on to the market. The market is unlikely to be able to accommodate that spike in delivery given historic delivery rates. This approach is not justified.
The allocation at Cambourne should be expanded to include the land between the existing A428 road and the allocated land - this would include land owned by Abbey including the Caxton Gibbet retail park and associated land.
The Liverpool method is not considered to be appropriate for calculating housing land supply. Planning Practice Guidance Paragraph: 022 Reference ID: 68-031-20190722 confirms that the Sedgefield approach to housing land calculation is to be the preferred approach but that the Council can seek to justify an alternative approach. In order to deliver urgently needed housing early within the plan period the Sedgefield approach must be used. This approach is not justified and the plan is not positively prepared.
The Council's apparent justification for not adhering to the 10% requirement on small sites is not justified and the plan is not positively prepared as a result. It is also inconsistent with paragraphs 73 and 75 of the 2024 NPPF. This is particularly important in South Cambridgeshire given that the district comprises a high number of villages which will require some growth in order to sustain them.

Girton to be confirmed as a Rural Centre.

Over and Oakington to be confirmed as Minor Rural Centres.

Allocate new small housing sites within Rural Centres and Minor Rural Centres. Consider doing so in Group Villages.

Girton should be confirmed as a Rural Centre given the range of services within the village.
Over and Oakington should be confirmed as Minor Rural Centres given the range of services within the village.
It is noted that these policies in respect of the amount of new housing which can be permitted in such locations are identical to South Cambs Local Plan Policies S/8 to S/10. It is questionable how many dwellings these policies will be able to deliver in the plan period given the lack of available land within those settlements. This confirms further that new smaller sites for housing should be allocated through the Local Plan (consistent with 2024 NPPF paragraphs 63 and 65) in order to deliver new housing in these locations to help to sustain the services and facilities within such villages and to broaden the housing stock. These should be proposed within all Rural Centres and Minor Rural Centres and consideration should be given to allocating new sites in Group Villages. We have proposed housing allocations in Girton, Over and Oakington previously: these would be examples of suitable locations for new housing. It is noted that Appendix C of the draft Local Plan includes targets for Neighbourhood Plans which may deliver such housing - however Neighbourhood Plans are not compulsory.

Expand the allocation at Cambourne to include land owned by Abbey including the Caxton Gibbet retail park and associated land.

Figure 7 includes a spike in housing delivery in 2029/30 which requires justification from the Council as the the delivery appears to be over 1,000 additional dwellings in a single year when compared with other monitoring years. This equates to 20 additional homes per week coming on to the market. The market is unlikely to be able to accommodate that spike in delivery given historic delivery rates. This approach is not justified.
The allocation at Cambourne should be expanded to include the land between the existing A428 road and the allocated land - this would include land owned by Abbey including the Caxton Gibbet retail park and associated land.
The Liverpool method is not considered to be appropriate for calculating housing land supply. Planning Practice Guidance Paragraph: 022 Reference ID: 68-031-20190722 confirms that the Sedgefield approach to housing land calculation is to be the preferred approach but that the Council can seek to justify an alternative approach. In order to deliver urgently needed housing early within the plan period the Sedgefield approach must be used. This approach is not justified and the plan is not positively prepared.
The Council's apparent justification for not adhering to the 10% requirement on small sites is not justified and the plan is not positively prepared as a result. It is also inconsistent with paragraphs 73 and 75 of the 2024 NPPF. This is particularly important in South Cambridgeshire given that the district comprises a high number of villages which will require some growth in order to sustain them.

The land within Allocation S/CB needs to be amended to include further land by including the land between the A1198 and the A428 - see the plan provided in the attached response.
The policies map should be made clearer to differentiate between the East West Rail and the A428 scheme.

See attachment which includes a plan showing the area which should be included within Allocation S/CB.

Amend the policy map to allocate the land to the east of Oakington Road, Girton.

Whilst we have no comments on the policy itself the need for Green Belt release is, in our view, clearly required in order to deliver new housing development. As such our comments relate to the need to release Green Belt land for development. One such opportunity is the land to the north of Girton (land to the east of Oakington Road). In light of the requirements within Appendix C for housing growth within neighbourhood plan areas Green Belt release will be essential in Girton. The land to the east of Oakington Road is suitable for release. The land is shown via the attached plan.

Provide further clarity around the position and include the link on the plan at Figure 63.

Paragraph 16 b of the supporting text to Policy S/CBN refers to a 'direct link under the proposed station for both active travel and public transport' which will seemingly be funded through a future CIL tariff. The Council does not currently operate a CIL tariff albeit it is acknowledged that the Council is seeking to adopt one.
This raises two principal considerations. Firstly what occurs if CIL is not adopted and in any event what is the likely cost of the link.
Secondly Figure 63 does not appear to include this 'direct link' - is the link proposed to serve the existing Cambourne settlement and therefore to go under the A428 also?
Further clarification is required here.

Amend the site allocation of S/CB to include the land owned by Abbey and to ensure that the allocation aligns with Figure 67.
The word 'to' is missing between contribute and the under part 2 of the policy.

Figure 67 is ambiguous at the western side of the site where the site allocation adjoins the A1198 and the A428. The red line boundary includes a straight line whereas the actual allocation is kinked to exclude land owned by Abbey Developments Cambridgeshire Limited. To the north of that area a wildlife corridor/noise buffer is suggested. This is inconsistent with the position on the ground and in any event it is not clear how the two uses are able to operate together. Please see the plan and further representations attached.

Delete the policy and allow building regulations to provide the compliance for new development.

Whilst the policy objectives of Policy CC/NZ are admirable the policy exceeds many areas which can be controlled under planning legislation. There is also a very fundamental point here about how the LPA can enforce the related conditions on new developments as monitoring the position on each new development would be an impossible task. The policy strays in to building regulation requirements. There is no clear justification for key parts of the policy including preventing new developments from connecting to the gas grid. Gas may often be required as a back up fuel. Whilst battery storage should be promoted there will be occasions where storage will be outstripped by usage. Renewable technologies are by definition not consistent in their generation outputs. A back up fuel supply is essential and the policy does not appear to understand that.
In addition whilst the policy seeks to not support new developments connecting to the gas network planning permission would not be required to connect in the future so the policy seems redundant in that regard.
Part D of the policy suggests that offsetting payments will be made where policy compliance is not possible. This raises many questions including: who will dictate the level of that payment, who will it be paid to and for what purpose will the payment actually be used? These contributions would need to be secured via Section 106 Agreements which would slow down the determination of planning applications. The contributions would appear to be unlawful.
There is insufficient evidence to suggest that the policy is positively prepared as there is no justification having regard to energy shortage or supply constraints. The policy lacks justification on the same basis. The effectiveness of the policy is highly questionable and, to my knowledge, no LPA has adopted such a policy position previously. The policy is clearly inconsistent with national policy as there is no policy position (planning or otherwise) to confirm that all new developments must be self sufficient in terms of energy use which is what the policy is seeking to deliver.

Delete parts 3 and 5 of the policy.

Part 3 of the policy suggests that the Council will use enforcement powers to monitor the policy. If there is a breach how does the Council intend to enforce given that the water efficiency measures often do not constitute development themselves? Does the Council intend to monitor each development and require the submission of relevant data? What if the smart meter breaks and the owner is unaware?
Part 5 of the policy is not justified as future policy or legislation changes should be reviewed in future Local Plans.