Greater Cambridge Local Plan Issues & Options 2020

2.1 Figure 19 of the Issues and Options document shows a serious concern regarding growth in Cambridge. As noted, average house prices in Cambridge are more than double the national average, with South Cambridgeshire significantly above the national figure. It is an expensive place to live and is especially difficult for young professionals to get on the property ladder given the price of housing in comparison to other areas of the country. The rental market also suffers from inflated prices, whereby monthly renting costs are well above the national average. 2.2 In addition to causing stress for individual households, a lack of housing and worsening affordability has the potential to cause significant negative impacts on the local economy, communities and the environment. 2.3 The Local Plan provides an opportunity to address this balance, but in a sustainable manner that minimises impact upon the environment, and makes de-carbonisation a priority. In order to ensure affordability in the future, the Local Plan must include a range of land types for housing provision, and this must include small and medium sites in line with paragraph 68 of the National Planning Policy Framework (NPPF). Such sites help ensure early delivery of housing and do not suffer from longer lead-in times given the limited infrastructure requirements. However, The Local Authority must set clear objectives for provision of affordable housing and carbon reduction to ensure that these are enshrined in policy in a manner that is clear to landowners when factoring in sale and purchase of land. 2.4 The Local Plan must ensure that appropriate housing numbers within the area are planned for in order to lower the house price to income ratio and ensure that house purchase remains an option for residents.

Yes, strongly agree

3.2 The current Cambridge and South Cambridgeshire Local Plans seek to provide a combined 33,500 dwellings to be built up to 2031. The area suffers a great disparity between housing provision and affordability. This is acknowledged within Figure 19 of the Issues and Options document itself and accompanying paragraph 4.6.3 confirms ‘Greater Cambridge is an expensive place to buy or rent a home. High prices are fueled by high demand, which itself is fueled by the strength of the local economy which attracts highly skilled workers’. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) Report confirms that growth in the employment sector has not been matched by proportionate house-buildings. The result has been large increases in house prices. 3.3 In accordance with the National Planning Policy Framework (NPPF), the starting point for deciding how many homes need to be planned for in the emerging Greater Cambridge Local Plan is a local housing need assessment, conducted using the ‘standard method’ unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals (NPPF, paragraph 60). 3.4 The standard methodology is set out in Planning Practice Guidance (PPG)(Housing and economic needs assessment ) and uses a formula to identify a minimum annual housing need figure, calculated by setting the baseline household growth projection and then adjusting is to take account of affordability and finally capping the level of any increase. The standard method does not produce a housing requirement figure and neither does it reflect economic growth requirements. 3.5 Compared with the adopted 2018 Local Plans’ combined target of 1,675 homes per year, the standard method calculation for Greater Cambridge indicates a minimum need of around 1,800 homes per year. This in itself would require a further 17,950 homes to 2040. 3.6 Reflecting paragraph 60 of the NPPF, PPG (paragraph 10) explains that, "The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.” 3.7 PPG includes reference to circumstances under which housing need should be higher than derived using the standard method, including growth strategies, strategic infrastructure improvements and authorities agreeing to take on unmet need for neighbouring authorities. 3.8 Greater Cambridge is located within the key economic corridors of the Oxford – Cambridge arc, the London – Stansted - Cambridge corridor and the Cambridge – Norwich tech corridor. The Oxford – Cambridge arc seeks to create a strategic vision corridor between the University cities. The National Infrastructure Commission (NIC) published a report into the CAMKOX arc in 2017 (Partnering for Prosperity: A new deal for the Cambridge- Milton Keynes-Oxford Arc ). This recommended that the current housing delivery rates will need to double up to 2050 to realise the Arc’s economic potential, with a goal to deliver 1 million new dwellings in the arc by 2050. At the eastern end of the arc, the driver is the City of Cambridge and its need for residential development to complement its skilled workforce. This level of growth would also require significant investment in new transport infrastructure, including East-West Rail and an Expressway connecting Cambridge and Oxford. 3.9 At the sub-regional level, the Cambridgeshire and Peterborough Combined Authority has ambitious growth strategies for the area, with the Greater Cambridge Partnership (GCP) tasked to deliver infrastructure and a City Deal including £500m funding. The Combined Authority established the Cambridgeshire and Peterborough Independent Economic Commission to develop an evidence base and inform policy decisions. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) was published in 2018 and it reported (page 9): “Growth in employment has not been matched by corresponding house-building, or developments in infrastructure. Consequently, house prices haves soared and journey times have increased as congestion has intensified. This has meant that many have been forced to endure unpleasant commutes or been priced away from the city altogether due to the unaffordability of rents. This is bad for both people and business, and we believe is an unsustainable approach to growth.” 3.10 The CPIER report provides a number of Key Recommendations to assist with growth in the area. Key Recommendation #5 of the CPIER Final Report September 2018 states: ‘There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast by the EEFM. This review should take into account the continuing dialogue between ONS and the Centre for Business Research on employment numbers as well as the impact of the Cambridge-Milton Keynes-Oxford Arc. This should be used to set new targets which are likely to be higher than those already set – at the very least adding on accumulated backlog.’ 3.11 The CPIER indicates that housing supply across the whole area (the Combined Authority Area) should be in the range of 6,000-8,000 homes per year over the next 20 years. For the Greater Cambridge area this translates into a CPIER figure of around 2,900 homes per year, which results in an indicative total of 66,700 homes over the Local Plan period 2017-2040. 3.12 Following the recommendations of the NIC report (2017) and the CPIER (2018), Cross Key strongly agree with the approach of planning for a higher number of homes than the standard method minimum. In order to support the growing economy, and key national, strategic and sub-regional growth strategies, a step-change in housing delivery is needed in Greater Cambridge to ensure that growth is sustainable 3.13 A higher target of dwellings would assist in meeting the goals of the arc. A further positive resulting from increased housing numbers would be the subsequent proportion of affordable housing. At present, Cambridge City and South Cambridgeshire District Council seek affordable housing provision of 40% for schemes over 15 dwellings. Should the Plan seek 66,700 dwellings rather than the 40,900 dwellings from the standard method calculation, then this could provide over 10,000 much needed affordable houses.

4.1 Creating a modal shift in transport use away from the car will require a significant number of factors working together. The Local Plan has the ability to bring together some of these facets and ensure that, when considered together, the result of developments will likely see less vehicle journeys. Ideally a large proportion of these journeys could be undertaken on foot or by bicycle, as they are the most sustainable means of travel, whilst also positive on health and well-being. Key employment nodes such as the City Centre and the Science and Business Park should be highly accessible to many homes by bicycle and walking. 4.2 A key factor in making that possible is the location of development. Cambridge has a large employment base and significant levels of services and facilities located in the City Centre, but in other key locations such as close to Cambridge North – the Business Park and the Science Park. It suffers from significant congestion at peak times due to daily trips undertaken to these locations by car. As such promoting development in close proximity to Cambridge, will reduce the length of journeys to the City and make many of them possible by walking and cycling, particularly where enhancements can be made to the existing cycle/footpath networks. 4.3 The Cambridge Green Belt restricts the potential for strategic development near the City. However, small and medium sized extensions to villages such as Impington, Hardwick etc. particularly those that are closest in proximity to key areas of activity – such as the Science Park and Business Parks, would allow highly sustainable – and arguably the lowest carbon footprint developments to be delivered early in the plan process. 4.4 As well as proximity, development must be located where there are appropriate transport options. Promoting growth and development along public transport along corridors where existing and enhanced levels of public transport can be provided – i.e. the guided bus way and proposed Cambridge Autonomous Metro is also a highly sustainable solution which should be prioritised when determining where growth should be accommodated. 4.5 Further comments as to the appropriateness of development along transport corridors is provided in question 48 below.

Nothing chosen

5.1 The Local Plan should seek to find appropriate land for a further 30,000 dwellings on top of those sites allocated within the existing South Cambridgeshire District Council and Cambridge City Council Local Plans 2018. Cambridge is enclosed by its Green Belt, which covers approximately 25% of the Greater Cambridge area. Completely discounting this area will put pressure on the non-Green Belt land, which by its very nature is further from Cambridge. 5.2 The villages that are fully or partly surrounded by Green Belt are those that are in close proximity to Cambridge and, therefore, bring significant opportunities for development of an appropriate scale given their location. These locations are where the most truly sustainable form of development can be achieved – as they have the ability to minimise the carbon footprints associated with day to day travel and commuting into Cambridge. From a health and well-being perspective, they also offer the most viable means for achieving increased commuting by foot and bicycle, promoting day to day activity, such as running to commercial developments, required today to provide shower and cycle parking facilities for employees. The new commercial developments at the Science Park are a case in point, minimising car parking provision, and maximising opportunities for healthy living. In order to provide truly sustainable development contributing towards net zero carbon development, Green Belt sites must be considered as potentially suitable options. One of the proposed ‘big themes of the Plan is climate change, and appropriate release of Green Belt can assist in achieving this aim. Not considering Green Belt release would be contradictory to this big theme, which is considered in the context of the Climate crisis to have far greater importance than the function of Green Belt, established over 60 years ago in a very different world. This will require a Green Belt Review to be undertaken to assess appropriate sites/parcels.

Highly flexible

6.2 The emerging Local Plan will need to strike a careful balance when addressing the issue of development on the edge of existing villages. Some of the villages surrounding Cambridge – such as Impington – are located on strategic transport corridors with excellent transport links, and close proximity to key employment nodes such as the Science & Business Park. Small scale knowledge-intensive employment would be entirely appropriate in locations such as Impington to accommodate flexible working practices. These villages provide opportunities for sustainable development and they should be identified as such within the Local Plan. The boundaries of these villages should be reviewed and where there are sites that will appropriately support sustainable village extensions then these should be allocated for development within the plan period. 6.3 In terms of Local Plan policy, the existing approach of tightly-drawn ‘village frameworks’ (boundaries) has in practice not been adhered to through development decisions. The Council should review this policy approach. 6.4 As highlighted in our response to question 47, villages are often located in highly sustainable locations, and provide significant opportunities at appropriate scales, to meet objectively assessed housing and employment needs. This brings significant benefits to the future vitality of villages, especially those such as Impington which have seen very limited growth in recent years. A failure to consider the villages as appropriate locations for growth could lead to a stagnation of these villages and will locate development in less sustainable locations.

Nothing chosen

7.1 We think the development strategy should be more flexible about the size of developments allowed within village boundaries by recalibrating the settlement hierarchy based not only on existing levels of services and facilities in each settlement but also the potential sustainability enhancing effect of accommodating growth, particularly where the carbon footprint can be demonstrated to be particularly low, and embracing to zero carbon. 7.2 It is important to note that paragraph 78 of the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. It goes on to promote planning policies that identify opportunities for villages to grow and thrive, especially where this will support local services. 7.3Existing settlement frameworks have been defined to take account of the present extent of the built-up area and planned development, but the level of planned development has been notably limited by the application of the settlement hierarchy (Policies S/7 - S/11 of the South Cambridgeshire Local Plan, 2018) and the principle that development can only occur within the settlement framework boundary. This is evident in the categorisation of South Cambridgeshire’s ‘Group’ or ‘Infill’ villages and the tightly drawn settlement boundaries, which have created little room for villages to grow. Examples of this are provided in the appended Barton Willmore Housing Delivery Study (2020). 7.4 Considering future requirements for housing land supply and housing affordability, it is clear that current settlement boundaries will need to flex in order to accommodate further growth in highly sustainable locations. As previously mentioned, the settlement hierarchy has defined the sustainability of each village as determinate rather than giving merit to its transformative potential through sustainable development. We are not arguing here for a removal of the settlement hierarchy, but a recalibration measured against levels of services and facilities in each settlement and potential sustainability enhancing measures such as: - Transport improvements that better connect villages to surrounding larger settlements, employment areas or service centres; Local transport enhancements that provide more sustainable travel options to services and facilities and/or ease of access for satellite villages surrounding larger or better served settlements e.g. new footpaths/cycleways, real time bus stops; - Increasing capacity of local community facilities to better serve local needs; - Provision of new community services and facilities e.g. play areas, new business incubators; - New housing that provides different sizes, types and tenures to meet the needs of different groups in the community and supports a greater demographic mix; - Provision of much needed affordable housing; - Local employment generation; - Health and well-being through both commuting and recreational purposes; - New or enhanced access to public open space and recreation (i.e. health and wellbeing gains); and - Net gain in biodiversity and opportunities to ‘scale-up’ local green infrastructure networks. 7.5 The above factors present scope to expand village populations in a sustainable way; the degree of expansion will need to be scored against the level of existing and potential sustainability levels. Not all village settlements will be equal in this regard and therefore a scoping exercise will be required to assess each settlement and preferably define an extent of housing supply matched with new housing land allocations. 7.6 Local communities may have a particular view on the needs of their village or where growth opportunities are best located. Similar to the emerging Bedford Local Plan, housing policy could give the option to local communities to steer allocated growth through a Neighbourhood Development Plan or Neighbourhood Development Order (Regulation 16), or if one has not been submitted the Council can consider the need to allocate additional sites. 7.7 Further, significant weight should be given to proposals that seek to minimise their carbon footprint and embrace renewable energy, and highly sustainable forms of living. Developments that can make a contribution to de-carbonising should be prioritised, and it is for developers to demonstrate how and where this can be best achieved.

No choices made

8.1 The spatial strategy that will inform the emerging Greater Cambridge Plan must be realistic in ensuring that the housing requirement can be met on appropriate and deliverable sites across the area. As set out in the NPPF (paragraph 67), planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. 8.2 The Issues and Options consultation document presents a range of location options, as follows: • Densification of existing urban areas; • Edge of Cambridge: outside Green Belt; • Edge of Cambridge: Green Belt; • Dispersal: new settlements; • Dispersal: village; and • Public transport corridors. 8.3 Given the scale of new housing required over the plan period, site selection will require a mix of locations, and a particular emphasis should be placed upon the likelihood of achieving truly sustainable development, and de-carbonisation. No single option from the above list can provide the spatial strategy for the forthcoming plan period. For example, densification alone cannot accommodate the level of housing provision needed; some greenfield land will also be required. 8.4 There will be a need for development in the villages. Such an approach follows guidance within paragraph 67 of the NPPF, which seeks planning policies to ‘identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability’. 8.5 Paragraph 68 of the NPPF highlights the benefits that small and medium sites can make in meeting housing requirements, particularly in the short term. The temptation will exist to focus development solely on large scale new settlements outside of the Green Belt, but until such time as such settlements have sufficient critical mass – i.e. in excess of 2,000 or more homes, they will only support very limited levels of employment. Prior to that they will only serve to create additional traffic, and demand for public transport for commuting into Cambridge. Further, these larger sites require significant amounts of upfront infrastructure to be provided, leading to significantly longer lead-in times for development as highlighted by the NLP ‘Start to Finish: How Quickly do Large Scale Housing Sites Deliver’ (November 2016). The lead in times for smaller and medium sites is significantly lower, and provision of these will be essential to ensure consistent delivery rates through the early years of the Plan period. 8.6 Such small and medium sized sites are appropriate for village expansion and can deliver in the early years of the plan. They play a key role in ensuring early delivery of market and affordable units and as a result assist in allowing authorities to demonstrate a five year housing land supply, which in the case of the Authorities has recently been measured at only 5.09 years.

9.1 Paragraphs 136 and 137 of the NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of updating of plans. Prior to concluding exceptional circumstances the policymaking authority should demonstrate that it has examined all other reasonable options for meeting its identified need for development. This should include: 1) making as much use of possible suitable brownfield sites and underutilised land; 2) optimising the density of development; and 3) be informed by discussions with neighbouring authorities as to whether they could accommodate some of the identified need for development. 9.2 In light of the pressing housing problems in Greater Cambridge and the undersupply of housing relative to economic growth, there is a clear need for the emerging Local Plan to consider what capacity exists to accommodate housing delivery on brownfield sites, through densification and the duty to cooperate. Paragraph 3.112 of the adopted Cambridge City Local Plan (2018) acknowledges the lack of available previously developed land and with the exception of the Northern Fringe East it is hard to imagine where significant numbers of additional homes will be feasibly accommodated within the urban area and urban fringes of Cambridge by 2040. It is therefore vital that less sensitive locations on the edge of Cambridge are reviewed for Green Belt release, taking into account the opportunity to bring forward sustainable development in a location that arguably provides the best opportunity to influence and change people’s behaviours around travel and commuting and encourage walking, running, cycling as well as public transport for more sustainable modes of transport. Development in these locations can support residents living sustainable lifestyles, support well-being as well as living in sustainable buildings. 9.3 The high level of housing delivery needed to sustain a rolling 5 year housing supply throughout the plan period is best met through a mix of housing sites and land availability. Sustainable growth on the edge of the City where possible and within settlements surrounding Cambridge can make an important contribution to this objective, creating opportunity to rebalance housing supply geographically across the district and tie in with improved sustainable transport measures. 9.4 A total of 28 villages fall wholly within the Green Belt and 10 further villages adjoin the Green Belt totaling 36% of all village settlements in the district. A significant proportion of these villages fall within a ‘higher sustainability category’ taking into account both existing service and facilities and potential sustainability enhancements. The closer these villages are to the City the greater the options for sustainable travel and the use of new forms of mobility (e.g. electric bikes). 9.5 Limited release of Green Belt land has previously been identified in the villages of Comberton, Histon and Sawston – all of which benefit from relatively good levels of service provision, including secondary schools or colleges. There is therefore a precedent for this approach and one that must meet the strict tests Chapter 13 (Green Belt) of the NPPF. 9.6 Having assessed the reasonable options for meeting identified housing need set out in paragraph 137 of the NPPF, the time is right given the scale of identified need for housing in the immediate and wider area for a review of the Cambridge Green Belt. There is a compelling case for the Councils to initiate this review of the Green Belt in order to best meet the challenges of its housing need and direct growth to sustainable locations, enhance the sustainability of existing rural settlements and promote sustainable travel in accordance with paragraphs 78, 103 and 138 of the NPPF. In doing so, the opportunity presents itself to: Redistribute housing delivery in the area, enabling greater access to housing outside of Cambridge City and improving the wider sustainability of the area; • Recognise the role that small and medium sized sites can make in contributing to housing need, building out quickly and maintaining a rolling 5 year housing supply; • Promote more sustainable forms of construction, carbon reduction in rural areas and high quality design in line with Village Design Guides and the National Design Guide to enhance the character and appearance of villages; • Secure more affordable housing and provide greater housing choices to meet a range of community needs, including specialist accommodation for the elderly, self/custom build and a mix of market homes; • Rebalance the scale of growth in existing settlements to create sufficient opportunity to transform local services and infrastructure, directing more S106 funding contributions and public investment towards villages; • Bolster existing and proposed village services, improving vitality, demographic mix and social sustainability; • Relieve some of the development burden on Cambridge City, redistributing travel patterns, boosting opportunities for sustainable transport and reducing carbon emissions; and, • Support green infrastructure improvements and biodiversity net gain in rural areas that have hitherto lacked such opportunities due to limited growth and investment.

10.1 The emerging plan will need to strike the right balance between high growth needs and the character of what makes the area unique. Given the high level of housing need in the area it is inevitable that several villages will need to accommodate further growth. This means, amongst other things, allocating sufficient housing land for small-medium housing sites, which can deliver quickly and help distribute growth more sustainably throughout the district (para. 68 of the NPPF) and identifying opportunities for villages to grow and thrive in order to enhance or maintain the vitality of rural communities (para. 78 of the NPPF). 10.2 This will inevitably face objection, and be difficult to support where it would result in loss of the Green Belt, and as such, we believe that the growth should be focused in the right place – i.e. those most sustainably located to benefit from proximity to jobs and services. To make it more palatable, development in these village locations should aspire to be carbon neutral, of exemplar design, and provide genuine positive effects. Residents are far more likely to support growth if it can have a positive effect on carbon emissions and be proven to not reduce public transport capacity or exacerbate localised congestion. This is only achievable in locations that can support walking/cycling to workplace, flexible working conditions, and accommodate further growth in public transport capacity – i.e. the guided busway where additional services will not create further traffic on the roads. Aspiration for zero carbon development should be enshrined in the most accessible locations as a genuine ‘exceptional’ reason to support expansion of villages in the Green Belt.

11.1 Transport corridors present potential sustainable locations for new development, as well as better connecting rural areas to important facilities, services and employment areas. However, the development strategy needs to consider sustainability in a holistic way by considering other factors that contribute to the sustainability of existing and new settlements. 11.2 As previously mentioned, the settlement hierarchy has defined the sustainability of each village as determinate rather than giving merit to its transformative potential through sustainable development. We are not arguing here for a removal of the settlement hierarchy, but a recalibration measured against levels of services and facilities in each settlement and potential sustainability enhancing measures such as: • Transport improvements that better connect villages to surrounding larger settlements, employment areas or service centres – particularly where this can be provided without adding traffic to congested roads – i.e. the busway; • Local transport enhancements that provide more sustainable travel options to services and facilities and/or ease of access for satellite villages surrounding larger or better served settlements e.g. new footpaths/cycleways, real time bus stops; • Increasing capacity of local community facilities to better serve local needs; • Provision of new community services and facilities e.g. play areas, new business incubators; • New housing that provides different sizes, types and tenures to meet the needs of different groups in the community and supports a greater demographic mix; • Provision of much needed affordable housing; • Local employment generation; • New or enhanced access to public open space and recreation (i.e. health and wellbeing gains); and • Net gain in biodiversity and opportunities to ‘scale-up’ local green infrastructure networks. 11.3 The above factors present scope to expand village populations in a sustainable way; the degree of expansion will need to be scored against the level of existing and potential sustainability levels. Not all village settlements will be equal in this regard and therefore a scoping exercise will be required to assess each settlement and preferably define an extent of housing supply matched with new housing land allocations.