Greater Cambridge Local Plan: Proposed Submission

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development on the edge of Cambridge.

Vision for Greater Cambridge

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. The Vision for Greater Cambridge in the Reg.19 Proposed Submission Greater Cambridge Local Plan (draft GCLP) refers to increasing quality of life for communities, minimising carbon emissions, reducing car use, providing housing, supporting infrastructure, and increasing green spaces.

As set out in these representations, we consider that the proposed housing target, the development strategy, and the selected allocations for draft GCLP are unlikely to fully deliver the Vision for Greater Cambridge. The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work, mostly by car. The development strategy is too focussed on the delivery of an expanded Cambourne, existing new settlements at Northstowe, Waterbeach and Bourn Airfield, and a proposed new settlement at Grange Farm near Little Abington. The delivery timetable for infrastructure to support an expanded Cambourne and at Grange Farm near Little Abington is uncertain. For all of the large strategic site allocations the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved.

The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. It is uniquely well-related to the future sustainable transport projects to the west of Cambridge i.e. the recently approved Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway. It is well-related to the very significant current and future employment opportunities at Cambridge West and at North West Cambridge, and to other employment opportunities available elsewhere in the City. It should be noted that the immediately adjacent Cambridge West is expected to have generated up to 15,000 jobs by 2041.

In addition to the substantial benefits of a new sustainable community, the University and Colleges seek to 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 approved Cambourne to Cambridge busway through a travel hub, enabling interchange and access to active travel options.

The site is also accessible to the wide range of services and facilities available in the City Centre.

The promoted development could support the delivery of a modal shift to sustainable modes of transport, which would support a reduction in car use and minimise carbon emissions. The promoted development would deliver a wide mix of house types, including 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. The promoted development would deliver green infrastructure in the form of publicly accessible open space, providing access from the city to the countryside to the west of Cambridge.

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development on the edge of Cambridge.

Strategic Priorities

COMMENT

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.

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 preferred housing target, the development strategy, and the selected allocations for draft GCLP are unlikely to fully deliver the strategic priorities.

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 more development to the edge of Cambridge, which are accessible by sustainable modes of transport, are well-related to proposed public transport infrastructure projects, and can deliver policy compliant levels of affordable housing. 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 those on the western edge of Cambridge, are unrelated to strategic development allocations that could support their delivery. In these circumstances it is unclear how those proposed green infrastructure opportunity areas are to be delivered, and failure to deliver them would not meet the biodiversity and green spaces strategic priority.

The location of the promoted development at South West Cambridge could support the delivery of a modal shift to sustainable modes of transport, which would support a reduction in car use and minimise carbon emissions. It would deliver green infrastructure, open space, and biodiversity net gain. It would provide a primary school, community centre, health centre, and a local centre with a food store and other shops, to meet the needs of the new community and existing residents and workers in the surrounding area. It would provide a new neighbourhood that is appropriate for the edge of Cambridge, which includes a mix of uses and connects the City to the countryside. It is adjacent to the current and future significant employment opportunities at Cambridge West and North West Cambridge, and it is accessible to other employment opportunities available in the City. The site 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. the recently approved Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway.

In addition to the substantial benefits of a new sustainable community, the University and Colleges seek to 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 approved Cambourne to Cambridge busway through a travel hub, enabling interchange and access to active travel options.

It is considered that the promoted development at South West Cambridge would be consistent with the strategic priorities 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 on the edge of Cambridge.

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, which 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 Greater Cambridge Development Corporation.

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

Policy S/JH: New Jobs and Homes

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

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/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.

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. 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. The ‘Review of Economic Data, Context and Representations’ Report (Iceni Projects Ltd June 2026) does not explain why the previous commuting patterns adjustment is no longer included. It is requested that the housing target is recalculated to include the previous commuting patterns adjustment. This approach would be consistent with Paragraph 110 of the NPPF, which refers to limiting the need to travel.

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”. It should be noted that Paragraph 008 relates to the delivery of affordable housing, and is distinct from housing affordability which is a separate factor included in the standard method calculations. 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 Cambridgeshire 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.

Cambridge is an area of national and international economic significance. In 2024 the Government established a Cambridge Growth Company to maximise Cambridge’s full economic potential and to deliver nationally significant growth. The Greater Cambridge Development Corporation was subsequently established in July 2027 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 Development Corporation 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 Development Corporation. 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, approved Cambourne to Cambridge Busway, Cambridge South East Transport project (currently at inquiry), 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 of 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 near Little Abington. 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.

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, which 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 Greater Cambridge Development Corporation.

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

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.

Policy S/DS: Development Strategy

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

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 identified as an area of major change for office, research & development, and industrial uses, and housing in appropriate parts of the site, but the option of the relocation of the Cambridge Waste Water Treatment Plant to enable the redevelopment of the site for mixed-use development is still being explored.

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. the recently approved 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. As set out in the representations to Policy S/GB, 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.

Policy S/SH: Settlement Hierarchy

SUPPORT

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/SH of draft GCLP defines the settlement hierarchy. Cambridge is at the top of the settlement hierarchy. It is acknowledged in the supporting text to Policy S/SH that Cambridge is the most sustainable settlement because it contains schools, employment, services and facilities, and public transport. In these circumstances, it is appropriate that Cambridge is identified at the top of the settlement hierarchy, and this is supported.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Policy S/GB: The Cambridge Green Belt

NOT SOUND – NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

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/GB of draft GCLP sets out the Green Belt policy for Cambridge. Paragraph 143 of the NPPF sets out the five national purposes for Green Belts. The second purpose listed in Paragraph 143 states “b) to prevent neighbouring towns merging into one another;”. The third purpose for the Cambridge Green Belt in Policy S/GB states “1c. prevent communities in the environs of Cambridge from merging into one another and with the city”. Purpose 1c in Policy S/GB is inconsistent with the second purpose in NPPF Paragraph 143 i.e. it refers to communities and not towns. Consistency with national policy is one of the soundness tests for local plan policies. The reference to communities rather than towns could have implications for how inappropriate development in the Green Belt is assessed and the implementation of grey belt policy at planning application stage in the future. It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities.

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 locations including on the edge of Cambridge, and there are exceptional circumstances to release land from the Green Belt. The draft GCLP already identifies sites within the Cambridge urban area that are suitable for redevelopment for housing and other uses. For all of the large strategic site allocations the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. The delivery timetable for infrastructure to support an expanded Cambourne and at Grange Farm near Little Abington is uncertain. All these factors indicate that additional allocations should be made in draft GCLP to meet development needs.

It is considered that edge of Cambridge, on land within the Green Belt, is the most sustainable option for additional allocations. In addition, as outlined in 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, and a positive outcome when compared with the amount of affordable housing that is being delivered at the existing new settlements at Cambourne, Northstowe and Waterbeach.

North BRLOG has promoted land at South West Cambridge, which is located on the edge of Cambridge and in the Green Belt. As a Green Belt site, the promoted development would provide 50% affordable housing. It would provide for the beneficial use of Green Belt land, including for public access, sport and recreation, landscape enhancements, and biodiversity. It is a sustainable location in transport terms. These outcomes would be consistent with Paragraphs 148, 150 and 156 of the NPPF. A significant proportion of the land at South West Cambridge would remain within the Green Belt as part of the promoted development.

An updated Landscape and Visual Appraisal and Green Belt Review has been undertaken of the site, and is submitted with these representations (see representations to Policy S/EOC requesting an additional allocation at land at South West Cambridge). The Green Belt Review highlighted the visual influence of the Cambridge West site and the M11 on the Green Belt to the west of Cambridge. There is limited visual or physical relationship between the historic core of the City and the site, and the promoted development would provide corridors through the site to retain views of key buildings e.g. the University Library. There is limited visual connection between the site and the West Cambridge Conservation Area. The building heights would be set below the skyline in important views. The promoted development would include a comprehensive landscape strategy to protect important views. It is concluded in the Green Belt Review that parts of the land at South West Cambridge would meet the definition for grey belt land, as set out in Chapter 13 and Annex 2 of the NPPF and in Section Id.64: Green Belts of the Planning Practice Guidance i.e. it does not strongly contribute towards Green Belt purposes (a), (b), or (d). The promoted development would not lead to the unrestricted sprawl of a large built-up area, it would not result in the coalescence of neighbouring towns, and it would not affect the setting and special character of a historic town. The site should be identified as grey belt.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Requested Change

It is requested that an additional allocation is made on the edge of Cambridge at land at South West Cambridge (Site Ref. 52643).

The promoted development contains the following mix of uses:
• Between 2,500 and 2,800 dwellings including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and potentially student accommodation;
• A comprehensive new green infrastructure network comprising open space and sports pitches, a new country park with connections to Coton Countryside Reserve, wildlife areas and biodiversity enhancement, and strategic landscaping including new woodland planting;
• Creation of new flood meadows and the potential rewilding of Bin Brook in certain locations to enhance capacity and its ecological benefits;
• A green landscape edge to the M11 to provide a landscape setting to the South West of Cambridge;
• Provide a primary school, community centre, health centre, and local centre including a food store and other shops, services, and facilities to serve the local community, nearby residents, and the Cambridge West campus;
• Enhanced pedestrian and cycle connections to the existing and planned walking, cycling and public transport network in the local area, and a development which places the needs of pedestrians and cyclists ahead of car users;
• A network of streets and spaces that are diverse in their function and character;
• A new public transport link that can enable a route connecting Cambridge West with the Cambridge Biomedical Campus.
• High levels of energy performance in building design that follow best practice in energy and carbon reduction; and
• Sustainability measures that embrace high standards for carbon neutrality, drainage and biodiversity and adopt low carbon construction techniques.

Policy S/EOC: Additional Allocation – Land at South West Cambridge (Site Ref. 52643)

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

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.

It is requested that this site is identified as an additional allocation on the edge of Cambridge. An updated Vision Document for the promoted development is submitted with these representations.

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct additional development to the more sustainable locations including the edge of Cambridge, 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.

The latest assessment of the site is provided in the updated HELAA. The site has mostly scored ‘amber’ for the majority of the suitability criteria, and some ‘green’ scores for open space/green infrastructure and accessibility to services and facilities. The two ‘red’ scores for the site relate to landscape and historic environment matters. In summary, the design and layout of the promoted development take into account both these matters.

An updated Landscape and Visual Appraisal and Green Belt Review has been undertaken of the site, and is submitted with these representations. The Landscape and Visual Appraisal identified key views across the site from the surrounding area. The promoted development includes a substantial central east-west open corridor through the site which takes into account some of the primary viewpoints towards the City from the west, retains existing landscape features, and locates development to avoid potential adverse effects on the setting of landmark/taller heritage assets in the City. The key views across the site would be retained as part of the promoted development. The open corridor through the centre of the promoted development would provide a new connection from the western edge of the City to the countryside. As a result of the proposed landscape strategy for the promoted development it is considered that the assessment score for landscape should be changed from ‘red’ to ‘amber’ i.e. the impact is capable of being mitigated.

An Initial Heritage Impact Assessment has been undertaken of the site, to identify the significance and setting of heritage assets that might be affected by the promoted development. The most sensitive parts of the site in heritage terms and the key views across the site remain undeveloped, and are part of the central east-west corridor through the site. The former historical field boundaries and routes that connect into the city from the west are retained within a strategic green corridor. The Green Belt Review submitted with these representations includes commentary on the heritage impact of the proposed development in the context of Green Belt purpose (d) preserve the setting and special character of historic towns. The Cambridge West site and the M11 have a strong influence on the character of the site. There is limited visual or physical relationship between the historic core of the City and the site, and the promoted development would provide corridors through the site to retain views of key buildings e.g. the University Library. There is limited visual connection between the site and the West Cambridge Conservation Area. The building heights would be set below the skyline in important views and the promoted development would include a comprehensive landscape strategy, which would protect those views. It is considered that the assessment score for the historic environment should be changed from ‘red’ to ‘amber’ i.e. the impact can be mitigated.

The Vision for a new neighbourhood at South West Cambridge is as follows:

• Provides between 2,500 and 2,800 high quality new homes with a range of housing types, densities and tenures including market, affordable housing, build to rent, housing for University and/or College staff, housing for the elderly (including care provision) and potentially student accommodation. It will have a real sense of identity, with distinctive neighbourhoods arranged around significant areas of open space. It will also be viable and deliverable in the immediate term.
• Is in a highly sustainable location, which is readily accessible by walking, cycling and public transport, including existing bus and cycle routes, the approved Cambourne to Cambridge Busway, and the Comberton and Barton Greenways. It is accessible to the wide range of services and facilities available in the City Centre. 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 can make a critical contribution to the delivery of a new public transport link connecting Cambridge West with the Cambridge Biomedical Campus. The needs of pedestrians and cyclists would be prioritised over car users.
• More than 55% of the site would be greenspace, and it is anticipated that a large proportion of this would be retained as Green Belt This would include a significant amount of accessible green infrastructure including open spaces and parks, sports pitches, green corridors, meadows, wetland habitat and the rewilding of Bin Brook.
• The green infrastructure within the development connects Cambridge with the countryside and Coton Countryside Reserve, and provides improved access to the site and opportunities for recreation and leisure for residents and neighbouring areas.
• Maintains the landscape setting of Cambridge and the character of the area, taking account of historic assets and views. A comprehensive landscape scheme would integrate the development, mitigate some of the more detracting elements currently present, and reinforce the character of the receiving landscape.
• Will provide important community facilities including a primary school, community centre, health centre, public square, and a local centre with a food store and other shops to meet the needs of the new community, and to serve other nearby residents. In addition, these facilities will be accessible for the Cambridge West campus and beyond serving the wider growth corridor, including research facilities and associated employment area.
• Will focus on a high-quality built environment, with ambitious design standards for public realm and buildings, including high levels of energy performance that follow best practice in energy and carbon reduction.
• Will achieve net biodiversity gains, with the creation of a variety of habitat types, and a substantial focus on natural capital underpinning the entire development. Sustainability measures will be extensive and will embrace high standards for carbon neutrality, drainage and biodiversity and adopt low carbon construction techniques.

The landowners - Corpus Christi College, Jesus College, St John’s College, Downing College, and the University of Cambridge - have a long-standing commitment to Cambridge and its future and will continue to be neighbours of the promoted development. North BRLOG are committed to the identified benefits and policy aims and their long-term stewardship of the site will assist in delivering these.

For all these reasons, the site at South West Cambridge should be allocated for a landscape-led new neighbourhood on the edge of Cambridge in draft GCLP. The Vision Document for South West Cambridge could form the basis for a site-specific policy and additional allocation. The key policy requirements for the promoted development are set out in the requested changes.

Requested Change

It is requested that an additional allocation is made on the edge of Cambridge at land at South West Cambridge (Site Ref. 52643).

The promoted development contains the following mix of uses:
• Between 2,500 and 2,800 dwellings including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and potentially student accommodation;
• A comprehensive new green infrastructure network comprising open space and sports pitches, a new country park with connections to Coton Countryside Reserve, wildlife areas and biodiversity enhancement, and strategic landscaping including new woodland planting;
• Creation of new flood meadows and the potential rewilding of Bin Brook in certain locations to enhance capacity and its ecological benefits;
• A green landscape edge to the M11 to provide a landscape setting to the South West of Cambridge;
• Provide a primary school, community centre, health centre, and local centre including a food store and other shops, services, and facilities to serve the local community, nearby residents, and the Cambridge West campus;
• Enhanced pedestrian and cycle connections to the existing and planned walking, cycling and public transport network in the local area, and a development which places the needs of pedestrians and cyclists ahead of car users;
• A network of streets and spaces that are diverse in their function and character;
• A new public transport link that can enable a route connecting Cambridge West with the Cambridge Biomedical Campus.
• High levels of energy performance in building design that follow best practice in energy and carbon reduction; and
• Sustainability measures that embrace high standards for carbon neutrality, drainage and biodiversity and adopt low carbon construction techniques.

It is requested that an additional allocation is made on the edge of Cambridge at land at South West Cambridge (Site Ref. 52643).

The promoted development contains the following mix of uses:
• Between 2,500 and 2,800 dwellings including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and potentially student accommodation;
• A comprehensive new green infrastructure network comprising open space and sports pitches, a new country park with connections to Coton Countryside Reserve, wildlife areas and biodiversity enhancement, and strategic landscaping including new woodland planting;
• Creation of new flood meadows and the potential rewilding of Bin Brook in certain locations to enhance capacity and its ecological benefits;
• A green landscape edge to the M11 to provide a landscape setting to the South West of Cambridge;
• Provide a primary school, community centre, health centre, and local centre including a food store and other shops, services, and facilities to serve the local community, nearby residents, and the Cambridge West campus;
• Enhanced pedestrian and cycle connections to the existing and planned walking, cycling and public transport network in the local area, and a development which places the needs of pedestrians and cyclists ahead of car users;
• A network of streets and spaces that are diverse in their function and character;
• A new public transport link that can enable a route connecting Cambridge West with the Cambridge Biomedical Campus.
• High levels of energy performance in building design that follow best practice in energy and carbon reduction; and
• Sustainability measures that embrace high standards for carbon neutrality, drainage and biodiversity and adopt low carbon construction techniques.

Policy S/EOC: Additional Allocation – Land at South West Cambridge (Site Ref. 52643)

Main representations uploaded in separate submission. The following reports are attached
Landscape and Visual and Green Belt Appraisal Appendices (main report included in main representations)
Flood Risk and Drainage Assessment (main report and appendices).

Policy BG/GI: Green and Blue Infrastructure

COMMENT

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 BG/GI of draft GCLP seeks to protect and enhance green and blue infrastructure and identifies a number of strategic green infrastructure initiatives. It is anticipated in Policy BG/GI that major development should provide financial contributions towards projects related to one of those green infrastructure strategic initiatives. North BRLOG has promoted land at South West Cambridge for a landscape-led residential development. Policy BG/GI identifies a green infrastructure strategic initiative at No.7 West Cambridge GI Buffer – Coton Corridor, which is located on the western edge of Cambridge and to the west of the M11 corridor.

North BRLOG supports in principle initiatives to improve the green infrastructure network on the western edge of Cambridge. However, it should be noted that there are no allocations identified in draft GCLP at the villages to the west of Cambridge that could make financial contributions towards the proposed green infrastructure strategic initiative at No.7 West Cambridge GI Buffer – Coton Corridor. The existing strategic developments at West Cambridge and North West Cambridge have outline planning permission, with associated planning obligations including for green infrastructure already agreed. It is not clear how the initiative at No.7 West Cambridge GI Buffer – Coton Corridor would be delivered effectively in the absence of related development. It is considered that draft GCLP needs to better align the development strategy and site allocations with the proposed strategic green infrastructure initiatives, in order to ensure that the initiatives are implemented.

The green infrastructure proposed for the promoted development at South West Cambridge would be consistent with the No.7 West Cambridge GI Buffer – Coton Corridor initiative, in terms of providing additional opportunities for recreation and nature, improving accessibility to green infrastructure for Cambridge residents, and connecting green infrastructure areas.

Cambridge Past Present & Future (CPPF) owns and manages the Coton Countryside Reserve, which involved taking land out of agricultural use to create habitats for wildlife including trees, hedges, orchards, and meadows. It is considered that the proposed new wetland habitat within the promoted development at South West Cambridge would represent a continuation of the environmental work that CPPF undertakes at the Coton Countryside Reserve.

It is considered that there is a real opportunity to deliver green infrastructure improvements on the western edge of Cambridge in conjunction with development at the South West Cambridge site and complement existing initiatives and activities.

No changes are requested to Policy BG/GI. 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 locations including on the edge of Cambridge. This approach could support the delivery of green infrastructure on the edge of Cambridge and contribute towards the green infrastructure strategic initiative at No.7 West Cambridge GI Buffer – Coton Corridor.

Policy WS/HD: Creating Healthy New Developments

COMMENT

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 WS/HD of draft GCLP seeks to ensure that new developments create healthy places, and refers to the delivery of additional health facilities, access to open spaces, providing allotments and food growing opportunities, and accessibility by active modes of transport. The delivery of developments that support good health and enable residents to lead healthy lifestyles is supported.

North BRLOG have promoted land at South West Cambridge. The promoted development would provide the health-related services and facilities referred to in Policy WS/HD. It includes a local centre and health services and facilities, which could accommodate a doctor’s surgery, pharmacy, and dentist. It provides substantial areas of land for open space, green infrastructure, and for outdoor sport and recreation. It is well-related to the recently approved Cambourne to Cambridge Busway, the Comberton Greenway and the Barton Greenway, which will enable residents of the promoted development to undertake journeys by active modes of transport (walking, cycling, and wheeling). The promoted development would include walking and cycling connections to all these transport projects and to the services and facilities within the development.

It is considered that the promoted development at South West Cambridge could contribute towards improving health and support the aims of Policy WS/HD if it was allocated in draft GCLP.