Greater Cambridge Local Plan Issues & Options 2020

Land North of Cambridge Road (A1307)

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We do not dispute that planning for the period up to 2040 is appropriate. However, in accordance with Paragraph 67 of the NPPF, it is more important for plans to identify a supply of specific, deliverable sites for years one to five of the plan period. After this, developable sites or broad locations for growth should be identified for years 6-10 of the Plan and, where possible, for years 11-15 of the Plan. 45. As such, it is clear that there should be a focus on allocating sites for delivery in years 1-5 of the Plan rather than planning for up to 2040. Medium and smaller sites, such as our Site, are best placed to come forward quickly (in years 0-5) as typically, they are not constrained by multiple land owners, viability issues or delays in progressing detailed design. As such, these smaller, well located sites must be allocated now to provide an immediate and robust supply of sites in the short-term.

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Any strategy which progresses must adequately respond to the needs of both Cambridge City Council (CCC) and South Cambridgeshire District Council (SCDC) and provide a sufficient supply and mix of sites to deliver growth needs across both areas. Therefore, reliance on a single growth strategy such as Edge of Cambridge or new settlements must be avoided, and a mixed and flexible approach should be adopted to ensure housing demand is met in all locations across the Plan area including established settlements and villages. Allocating a range of types and locations for development will ensure there is a robust supply which will enable a sufficient amount and variety of land can come forward where it is needed as encouraged by the NPPF (paragraph 59). This means there needs to be a step away from the existing preference for locating development, as set out in adopted Plans for SCC and CCC. At present, the priority is to deliver new housing on the edge of Cambridge, followed by within new settlements and lastly in the rural area at Rural Centres

Progressing a spatial strategy which links new homes with jobs, facilities/services, high-quality open spaces and public transport helps to achieve good growth. Allocating sensitive development on the edge of villages fulfils these criteria by being accessible to an existing provision of facilities which can encourage walking and cycle and provide access to established jobs and social act. By locating such development within established village communities, best use can be made of existing resources with less reliance and concerns on new housing being delivered before the necessary infrastructure to support it which is often a criticism of new settlements and large urban extensions. Additionally, the presence of an existing community structure means new development in these village locations have better opportunities for good levels of social inclusion and wellbeing.

53. Healthy lifestyles can be supported by allocating new developments in locations where daily activities such as travelling to school, shopping and work can be undertaken actively by foot or bicycle. Within or on the edge of established villages communities, such as Linton, provide ideal locations for new development which can deliver such active lifestyles as services and facilities are already contained within short distance. New development in these locations can, where appropriate, enhance or increase existing provisions / opportunities which provide benefits for existing residents as well. 54. New development should also be close to, or provide, open space and recreational activities. The proposed Site is located adjacent to the River Granta and a number of public footpaths and walks which provide the ideal setting and opportunities for a healthy lifestyle. The Indicative Concept Masterplan accompanying this submission show that it is intended to protect and enhance the riverside setting and be retaining an extensive expanse of open spaces which, alongside the existing village green to the north, will create a link of connected green space to provide a new green infrastructure and recreation hub for the village. An opportunity to create such a high quality new residential development, which also enhances the quality of life of existing residents, must not be missed.

Existing employment and business locations within Rural Centres and Minor Rural Centres should be protected to ensure they maintain the level of services and employment in these sustainable village locations. A number of employment sites in rural centres have already been lost to housing allocations which in turn can reduce the sustainability of such villages. Further loss should be prevented by considering alternative options for new housing such as redrawing the village boundaries and allocating edge of village sites.

In order to adequately respond to changing housing needs over the Local Plan period, flexibility and variety in the amount and type of new homes is required. As stated in response to Question 5, this can be achieved by avoiding reliance on a single growth strategy, and instead adopting a mixed and flexible approach to identifying and allocating new housing sites of different sizes and in different locations across the entire plan area. This will ensure a range of different housing types and products will come forward which are appropriate to the site context and development size and will help meet demand for housing in all locations including established settlements and villages. Additionally, Cambridgeshire has significant housing affordability issue which will only increase as job growth continues, and the Greater Cambridge Plan must seek to significantly exceed minimum housing requirements to begin to rebalance this issue, and ensure a range of different affordable housing types can be delivered.

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Local Housing Need figures are a minima and the intention should be to exceed the number of homes required by the Government both to provide flexibility and meet affordability challenges. In order to be robust and sound, the number of sites and dwellings to be allocated by the Plan should exceed the objectively assessed need to reflect the reality that some allocated sites will not come forward in the plan period or deliver the number of homes they are allocated for. Additionally, this is particularly the case when considering the aspirations for growth in jobs and economies across the district. Greater Cambridge’s current and future housing need is largely driven by the employment growth targeted as part of doubling the regional GVA by 2041. Research by Cambridgeshire & Peterborough Independent Economic Commission (CPIEC) clearly shows that the quantity of land/sites allocated for housing will need to be significantly more than that currently planned for in the Local Plans. Evidence on job density and economic activity shows there is little capacity among existing Greater Cambridge residents to expand the workforce and economic growth will need to rely on workers migrating or commuting into the area to avoid to not be limited. This places continuing pressure and demand on the housing market and to date, demand has vastly surpassed supply, creating a severe affordability issue. Therefore, the volume of house building needs to significantly increase across the district and exceed minimum requirements in order to prevent economic growth in Greater Cambridge stalling and housing unaffordability increasing. Allocating land for additional housing, above minimum targets, would also ensure there is sufficient flexibility within the Local Plan to respond to changing housing needs/trends over the Local Plan period.

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Whilst there are different advantages and challenges for each growth option as recognised by the consultation material, significant weight must be given to the NPPF in considering which growth options are appropriate to progress. The NPPF (paragraphs 133 and 136) is clear that great importance is attached to Green Belt and boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 137 explicitly requires the strategic policy-making authority to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries. Compliance with this process will be assessed through the examination of its strategic policies. Therefore, the onus is on the GC authority to demonstrate that all other reasonable options for growth have been exhausted before releasing Green Belt, regardless of the potential sustainability benefits of Green Belt locations. Therefore, it is clear that edge of village locations outside of the Green Belt, such as Linton, which present a suitable, available and sustainable location for development must be given significant weight and consideration for allocation before any land can be released from Green Belt. If further sites are required to meet growth needs once all edge of village and edge of Cambridge sites outside the Green Belt have been assessed and, where appropriate, allocated, then the Green Belt boundaries can then be changed and justified as necessary.

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Significant flexibility should be given towards the development of housing and jobs on the edge of villages, particularly for Rural Centres and Minor Rural Centres as identified in the adopted South Cambridgeshire Local Plan. Edge of village locations provide new development with access to established communities as well as services and other infrastructure which make them an ideal location for additional jobs and homes. For example, Linton is identified as a Minor Rural Centre which are villages with a greater level of services, facilities and employment than most other villages in South Cambridgeshire, and often perform a role in terms of providing services and facilities for a small rural hinterland. Providing additional homes in this location would deliver social and economic benefits which weigh heavily on presumption in favour of sustainable development, Given this, the settlement boundaries for existing Rural Centres and Minor Rural Centres should be reconsidered and reassessed particularly where edge of village sites are promoted for sustainable development. Additionally, the NPPF encourages planning policies to identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. As noted previously, edge of village sites tend to be smaller and within single ownership with less constraints than larger strategic allocations. This means they are a reliable and robust source for housing delivery and where such sites are immediately available, significant flexibility should be given to allow sustainable development to be delivered quickly.