Greater Cambridge Local Plan Issues & Options 2020

Yes

2.76 We agree that the potential to remove land from the Green Belt should be fully considered as part of the development options for Greater Cambridge. Our representations have demonstrated that Comberton is a highly sustainable option in terms of its proximity to Cambridge giving realistic options for cycling as an alternative to commuting by private car as well as benefiting from a regular bus service. 2.77 As one of the larger villages it also benefits from a good level of services and facilities, particularly education with a Sixth Form college, which are within easy walking and cycling distance from the site. Accordingly, there are good opportunities for shorter trips to be undertaken in a sustainable fashion. 2.78 We would, therefore, contend that Comberton is one of the most sustainable village locations within the Green Belt and the comprehensive opportunity including later living and community uses means the site is entirely suitable for removal from the Green Belt. 2.79 Looking more widely at the aspirations for the Local Plan, a key ambition is the transition to a net zero carbon society highlighted within the ’Welcome’ from Cllrs Hawkins and Thornburrow and forming a fundamental ambition as part of the four big themes under the climate change heading. In order to transition to a net zero carbon position, there needs to be a release of sites such as Comberton within the Green Belt in proximity to Cambridge that will allow residents to live sustainable lifestyles with realistic opportunities to commute by alternative methods to the private car, particularly where there is the provision of infrastructure such as the proposed Greenway. 2.80 In considering the removal of sites such as Comberton from the Green Belt, it is anticipated that a Green Belt assessment will be undertaken, against the five purposes. Although no formal assessment has been undertaken at this stage it is considered that the parcel or parcels of land forming the site would score poorly against Green Belt purposes. The site has development on both sides and a new strong and defendable Green Belt boundary could be secured through development that would endure beyond the plan period. 2.81 Accordingly, removal of the site from the Green Belt would do little harm in terms of ‘purpose a’ under paragraph 134 of the Framework to check the unrestricted sprawl of large built-up areas. Similarly, under purpose b it is anticipated the site also scores poorly in terms of preventing towns merging, whilst there is also limited encroachment into the countryside (purpose c). Under purpose d the site does not play a significant role in preserving the special character of historic towns and again the landscape proposals provide an opportunity to enhance a strong, defendable boundary when approaching Comberton from the north. Finally, under purpose e, “assisting in urban regeneration, by encouraging the recycling of derelict and other urban land” it is acknowledged that the scale of growth required in this Plan exceeds that which can be met on brownfield sites alone and that some Green Belt release will be needed. We have also rehearsed above that removal of the sites from the Green Belt provides the best opportunity to meet the Council’s zero carbon aspirations in proximity to Cambridge.

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2.82 We would contend that the Local Plan should take a highly flexible approach to the development of jobs and home on the edge of villages in general and Comberton in particular. As set out above Comberton is a highly sustainable location and, therefore, allocating growth here would meet a number of the aspirations of the Local Plan in general, and the four big themes in particular. The later living retirement village comprises a distinct offer in that context which will also see job creation. 2.83 The Vision Document and in particular landscape analysis sets out how the proposed development would form a natural extension to Comberton with development on 2 sides and Branch Road forming an obvious and defendable boundary, augmented by enhanced boundary planting that is multi-functional with trails, natural play and biodiversity gains

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8. As outlined within the Local Plan Issues and Options document, the future Local Plan must aim to ensure sustainable development. In order to achieve this, competing priorities and issues need to be balanced. Greater Cambridge Planning has grouped these into the following themes: - Climate Change; - Biodiversity & Green Spaces; - Wellbeing & Social Inclusion; and - Great Places. 9. My client supports the inclusion of these ‘big themes’ that have been proposed for the Local Plan, in particular ‘Climate Change’ and how the plan should contribute to achieving net zero carbon. Chapter 14 of the National Planning Policy Framework (NPPF) focusses on ‘Meeting the challenge of climate change, flooding and coastal change’. “The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.” Paragraph 148 – NPPF, 2019 10. In line with the objectives and provisions of the Climate Change Act 2008, Paragraph 149 of the NPPF focusses that plans should take a proactive approach to mitigating and adapting to climate change. Policies should support appropriate measures to ensure the resilience of communities and infrastructure to climate change impacts. Impacts such are intense and frequent extreme weather events such as floods, heatwaves and droughts are likely to become more frequent. It is acknowledged that the Local Plan is asking about meeting net zero carbon by 2050. 11. My client’s site, land to the rear of Fisher’s Lane, Orwell would reflect the themes and aims of the new Local Plan as well as National Policy and suggestions from the Planning Inspector as part of the currently adopted policies examination in 2018. 12. Summary: the four big themes are supported as a means by which to plan for housing, jobs, and infrastructure.

16. According to the NPPF, the Planning Practice Guidance and the Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through the development of small scale sites, such as those put forward by my client as well as large strategic sites. The supporting Greater Cambridge Housing Delivery Study prepared by Barton Willmore draws attention to slow delivery rates and a concentration of large sites to the north of the district. It notes that ‘Greater Cambridge has seen several large-scale strategic housing sites and long lead in times for new settlements such as Cambourne and Northstowe’. It concludes that while ‘Generally, large sites deliver more housing each year on average, but the advantage of smaller sites is that they tend to build out quicker and have shorter lead-in times overall when considering the planning approval process’. For this reason, village sites such as land to the rear of Fisher’s Lane, Orwell have an important role in delivery and achieving a mix of housing. 17. NPPF Paragraph 68 sets out that “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” This can be achieved by allocating a greater number of small to medium sized sites, rather than fewer large strategic sites or working with developers to encourage the sub-division of large sites, helping to speed up the delivery of homes. Additionally, the Planning Practice Guidance identifies the need to consider a range of sites for development, including small scale sites in villages and towns. 18. The existing planning strategy places a significant reliance on the strategic allocations around the City and also the development of new settlements which the Inspector’s raised concerns about. The new Local Plan should significantly increase the allocation of small to medium sized sites in the rural areas, to help speed up delivery of homes and allow more flexibility. Small-medium sized sites play an important role in providing a wide variety Greater Cambridge Local Plan Issues and Options 2020 Consultation of house types and mix and also deliver quickly compared to larger sites. In accordance with Paragraphs 67 and 68 of the NPPF, strategic policy-making authorities should identify an appropriate supply and mix of these sites across the District and Local Plan period. 19. Summary: The Local Plan should adopt a blended approach including a range of locations, and site sizes to ensure deliverability and choice in the market.

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20. The standard methodology indicates a need for 1,800 homes per year, or 40,900 homes for the suggested plan period of 2017-2040. However, as the draft Local Plan acknwoledges, the Cambridgeshire & Peterborough Independent Economic Review (CPIER) 'showed that our recent growth has been faster than expected, and that growth is likely to continue. As a result, demand for new housing in this area has been exceptionally high and housebuilding has not kept up'. 21. The draft Issues & Options Local Plan indicates that a rough indiactive calculation based on CPIER suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greate Cambridge, which equates to an indicative total of 66,700 homes over the period 2017-2040. 22. CPIER recommends that ‘There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast in the EEFM'. It states that ‘No economy can achieve its potential without an adequate supply of housing, which must offer a range of types and price points for all society' and add that it 'is concerned that Cambridgeshire & Peterborough is already runnning a very significant risk in this regard' and that risk is most acute in the Greater Cambridge area'. 23. CPIER continues, stating that 'There has been insufficient housing development to meet demand. Average house prices and commuting have risen, choking labour supply while reducing the well-being of those forced to commute longer and longer distances [from more affordabe areas]'. CPIER concludes that 'we believe the accumulated deficit in Cambridgeshire & Peterborough is so acute that the local authorities should re-examine their assessments of housing need, setting higher numbers, which at least reflect previous under-delivery'. It should also be noted that the CPIER indicates that job growth in recent years in Greater Cambridge has been under-estimated with a knock-on impact for the level of housing required, which is likely to be far higher than the numbers set out using the standard methodology method. 24. The supporting Housing Delivery Study prepared by Barton Willmore demonstrates that ‘current housing completions are on a par with the minimum houisng need identified using the Government’s standard method. However to keep up with the economic growth over the next 20 years, using the upper housing range recommended by CPIER will mean an uplift of 71% in housing supply compared to the current objectively assessed need (OAN) set out the the Cambridge and South Cambridgeshire Local Plan (2018)’. The NIC’s recommendations go even further than CPIER and recommend doubling the current OAN to reach a total of 3,350 homes per annum. The supporting Housing Delivery Strategy concludes that ‘Applying these indicative figures [set out in the CPIER and NIC] would result in a need to deliver 65,987-77,050 homes between 2017-2040. This would require a review of land available to support a further 29,587-40,650 homes during the Local Plan Period taking account the 36,400 homes that already have permission or are allocated in the adopted 2018 Local Plan’. 25. For these reasons, my client strongly agrees that the Greater Cambridge Shared Planning Service 'should plan for a higher number of homes than the minimum required by government, to provide flexibility to suppprt the growing economy'. While there is clearly more empirical evidence to be undertaken, the indicative CPIER calculation of 2,900 home a year (or 66,700 homes over the plan period) should be seen as an appropriate starting point. My client therefore supports the option of delivering a minum of 2,900 homes per year, as only by building at a higher level than has previously occurred will start to mitiage the significant negative effects on bothe the local and national economy should housing in Greater Cambridge continue to be constrained. 26. Housing should also reflect the upper housing range as recommended within the CPIER and the NIC to support the anticipated economic growth over the next 20 years. This equates to a minimum of 2,900 homes each year within Greater Cambridge and an uplift of a minimum of 71% of housing supply compared to the current OAN figures. This shows the potential need for 9,577 additional homes in rural areas up to 2040 based on the CPIER’s estimates against existing representation of growth across the existing adopted development strategy. 27. Summary: Strongly agree that ‘we should plan for a higher number of homes than the minimum required…, to provide flexibility..for the growing economy’. In order to meet the growth aspiration that has been set out by the Local Planning Authorities and CPCA, the plan must plan for the homes to support the anticipated growth.

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28. As stated within at 5.2.5 of the Issues and Options document, the currently adopted 2018 South Cambridgeshire Local Plan sets a development framework for each village, outside which development is heavily restricted. 29. In addition, villages within the Local Plan 2018 have been categorised dependant on their ‘sustainability’. Orwell is currently categorised as a ‘Group Village’. These are villages that are considered by the Plan to be generally less sustainable where development will be limited to sites of 8 to 15 dwellings. 30. The CLA’s report: Sustainable Villages – Making Rural Communities fit for the Future is critical of traditional approaches to what constitutes ‘sustainability’ and states that ‘Sustainability assessments measure villages against a range of services and amenities more akin to how previous generations lived and used services’ and argues that ‘Local authorities should factor in how advances in technology have helped shape modern life and consider how emerging technology will change rural England’. It concludes that many villages ‘are not allocated housing and have very limited development options to improve their sustainability leaving them in a cycle of decline’. 31. In light of the above it is recommended that the Local Plan should be more flexible in particular at focussing development at the edge of the villages contained within Policy S/10 that rank higher in terms of sustainability. It would be our recommendation that a new village group is provided within the Local Plan than encompasses the less sustainable Minor Rural Centres and more sustainable Group Villages and allows for development of up to 30 dwellings. 32. Furthermore, the Local Plan should allow for more flexibility in allowing the development of sites that directly abut the development framework of a village that is not within the Green Belt (or the edge of a village abutting the Green Belt). Sites such as the one put forward by my client, Endurance Estates as part of the Greater Cambridge Local Plan ‘Call for Sites’ exercise in March 2019. 33. Summary: The Local Plan should be highly flexible towards development of jobs/homes on the edge of villages and be able to respond to changing circumstances.

39. The focus on growing our villages throughout the District would help sustain existing facilities and infrastructure in villages and assist in diversifying their population. In order to help sustain existing facilities and infrastructure within villages, it is key that they are grown by increasing housing numbers. 40. Paragraph 78 of the National Planning Policy Framework states that ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services’. It is important to ensure that existing businesses are able to stay open and vital services to not only the Minor Rural Centres and Group Villages but also the surrounding Infill Villages, many of which rely on the services within adjacent larger settlements. 41. In Greater Cambridge, many younger people and families have effectively been priced out of areas in which they grew up. At the same time, older people wishing to remain in their communities and downsize to smaller properties, have been prevented from doing so as a result of a lack of supply of appropriate housing. This in turn has led to the underoccupation of larger properties, and the over-occupation of some smaller properties, particularly in Cambridge itself. 42. Over the same period, many villages have lost many of their services as shops have closed, public houses have been converted into houses, and bus services have been cut back or ceased altogether. Now, with better broadband connectivity, combined with the advent of home working and online shopping, there is a unique opportunity for rural areas to reinvent themselves but they need some housing to enable them to do so. 43. The Country Landowners Association’s (CLA’s) report Sustainable Villages – Making Communities fit for the Future which draws on the Taylor Review (2008) challenges the assumption that a lack of services means that these places are unsuitable for new housing ‘due to the negative impact this process has on house price affordability, social cohesion and economic performance. This process effectively fossilises these villages instead of seeking to address the reasons behind why services are being lost, creating a cycle of decline’. 44. Over the past 25 years, local authorities have increasingly sought to focus new development in major towns and cities. Instead of enabling modest, appropriate-scale extensions to villages, planning policies have focused on a smaller number of large allocations on the edge of urban areas, this has been the case in the Greater Cambridge area, where the current adopted South Cambridgeshire Local Plan places considerable emphasis on the growth of a small number of very large settlements including Bourn Airfield, Cambourne, Northstowe, and Waterbeach. 45. While it is acknowledged that larger settlements accompanied by high quality public transport can provide sustainable options, it is also critical that medium-sized villages such as Orwell take some development to enable it to grow in a sustainable well, helping to support local shops, services, and facilities including the local primary school. In recent years many villages across the Greater Cambridge area have lost vital services as shops have closed, public houses have been converted into residential properties and bus services have been reduced. Orwell is fortunate in this regard and has maintained a number of its key services and transport options. Now with much improved broadband connectivity and a significant increase in home working and ability to shop online, may of the historic barriers to sustainability in rural areas and villages are now reduced. 46. It is therefore important to enable modest, appropriately-sized extensions to villages so that the remaining services (including the primary school) can be supported and to enable much needed new market and affordable housing to be provided. It is considered that the proposed site is commensurate with the size and scale of the village and could provide a sustainable expansion to the settlement whilst potentially providing additional car and cycle parking for the adjacent employment site. 47. It is vital to preserve what is special about our rural communities and environment. But equally, carefully designed additional development that enables villages to become more vibrant is essential. Any new housing schemes should be targeted at local circumstances and be commensurate with the size and scale of the individual settlements. Of the top 25 local authorities in the Halifax’s latest Quality of Life survey, the majority are in predominantly rural areas – so a key challenge will be to ensure that any development is not at the expense of what makes them great places to live. 48. Summary: Support for a strategy that includes growth in villages at a level that is commensurate with their size and scale and enables sustainable growth.

49. Policy S/10 of the South Cambridgeshire Local Plan 2018 is far too restrictive and inflexible, and prevents appropriate-sized development in medium-sized villages such as Orwell. A much less restrictive approach to development in medium-sized villages like Orwell should be adopted, together with a much broader definition of what constitutes sustainability, focusing on the potential to enhance the sustainability of a place through allowing appropriate levels of development on the edges of villages. 50. Summary: Support for a more flexible and less restrictive approach to appropriate residential development within and on the edges of villages.

EXECUTIVE SUMMARY These representations are made on behalf of Endurance Estates and set out comments in relation to several questions in the Issues and Options Consultation on the emerging Greater Cambridge Local Plan (2017-2040). This representation is concerned mainly with the housing delivery strategy for Greater Cambridge and related Green Belt issues. However, it also touches upon interrelated topics such climate change, biodiversity and green spaces, wellbeing and social inclusion and great places. The emerging plan will need to strike the right balance between high growth needs and the character of what makes the area unique. It will also need to consider how the economic success of the area is not hampered by inadequate transport infrastructure, housing delivery and other infrastructure needs. Along with housing and economic drivers, the development strategy for Greater Cambridge will need to tackle sustainability in a holistic way, rebalancing growth in the area to respond positively to issues such as health and wellbeing, community, biodiversity, green infrastructure and climate change. In response to this challenge, this representation advocates allocating the widest possible range of sites in order to provide a more sustainable development strategy and to rebalance growth needs in Greater Cambridge in accordance with paragraphs 67 and 68 of the NPPF 2019. This means, amongst other things, allocating sufficient housing land for small-medium housing sites in rural settlements, which can deliver quickly and improve the rate at which houses can be absorbed by the market. To address this, it is clear that current settlement boundaries will need to flex to accommodate further growth in sustainable locations. Having assessed the reasonable options for meeting identified housing need set out in paragraph 137 of the NPPF, there is a compelling case for Greater Cambridge to initiate a review of the Cambridge 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.

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1.0 INTRODUCTION 1.1 These representations are made on behalf of Endurance Estates and set out comments in relation to several questions in the Issues and Options Consultation on the emerging Greater Cambridge Local Plan (2017-2040) in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012. 1.2 These representations should be read alongside Barton Willmore’s Greater Cambridge Housing Delivery Study (Appendix 1). This includes a detailed review of Greater Cambridge’s housing needs, current housing delivery strategy and local transport plan and the corresponding implications for the emerging Greater Cambridge Local Plan. Several key findings are made within this study in relation to the growth strategy for Greater Cambridge and provide the context for the recommendations set out in this representation. 1.3 This representation is concerned mainly with the housing delivery strategy for Greater Cambridge and related Green Belt issues. However, it also touches upon interrelated topics such climate change, biodiversity and green spaces, wellbeing and social inclusion and great places.

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