Greater Cambridge Local Plan Issues & Options 2020

Edge of Cambridge: Green Belt, Dispersal: Villages, Public Transport Corridors, Densification of existing urban areas, Edge of Cambridge: Outside Green Belt, Dispersal: New Settlements

There are limited opportunities and constraints to development within the urban area of Cambridge, there are limited opportunities for development on the edge of Cambridge which are not in the Green Belt and those opportunities require the relocation of existing uses, and new settlements are complex and typically do not provide policy compliant levels of affordable housing. The options of focusing development in the Green Belt and along public transport corridors are preferred; the developments promoted on behalf of Axis Land Partnerships in Stapleford would be consistent with both of these approaches. It is considered that in reality the development strategy for GCLP will be based on a combination of spatial distribution options.

Strongly agree. It should be noted that some villages, including Stapleford, are also located in the Green Belt and are on transport corridors, and as such development options that include these locations are also supported; the response to this question is also relevant to Question 45. As set out in the response to Question 39 national guidance allows the release of land from the Green Belt through the plan-making process, and that exceptional circumstances exist to release land which is related to the significant need for housing, affordable housing and housing for older people in Greater Cambridge and Stapleford. The experience of new settlements and the redevelopment of previously developed land on the edge of Cambridge demonstrates that these options do not deliver policy compliant levels of affordable housing, and in the case of new settlements these types of development typically have much longer lead-in times than originally predicted. Therefore, releasing land from the Green Belt around Cambridge, including at Stapleford, is a realistic option. Paragraph 78 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The promoted developments at land east of Hinton Way and land west of Haverhill Road in Stapleford would support the existing good range of services and facilities available in the village. Paragraph 68 of the NPPF acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short-term housing land supply and the five year housing land supply position in Greater Cambridge. Therefore, it is requested that small/medium sized sites such those promoted by Axis Land Partnerships in Stapleford are allocated to meet the requirement for a mix of sites including those that are easily deliverable. Paragraph 102 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 103 expects significant development to be focused on locations which are or can be made sustainable. As set out in the response to Qu.37, Stapleford is very accessible by walking, cycling and public transport. It is well-related to the proposed new public transport route between Haverhill and Cambridge. The promoted development is well-related to the services and facilities in Stapleford by sustainable modes of transport. As set out in the call for sites submissions, there are no significant constraints to development at land east of Hinton Way and land west of Haverhill Road in Stapleford. The sites make a limited contribution to the Green Belt and could be released to meet the needs for housing, affordable housing and housing for older people. The promoted developments would include a sizeable open space and strategic landscaping, which would retain the openness of most of the Green Belt in this location and would enhance the setting of the sites and the surrounding area. Overall, Stapleford is a suitable village for additional development.

In reviewing the documentation prepared by the Council we recognise that this is an early stage in the plan’s preparation and that a Sustainability Appraisal is an iterative process. At the outset we would note that recent challenges at examination of local plans have included substantive criticisms of the SA which goes well beyond the legal tests and into professional planning judgement. For example, examiners in the North Uttlesford Local Plan, North Essex Local Plan and St Albans Local Plan have recently requested information on alternatives that goes beyond the legal position of “reasonable alternatives” selected by the local authority using broad questions of judgement. The Issues and Options Report is assessed in a SA report dated November 2019. The Issues and Options Report is largely of general content without spatial or specific focus, and consequently much of the assessment is general commentary. Six spatially discernible options are provided in the "Towards a Spatial Plan" Section, which are: • Option 1: Densification. • Option 2: Edge of Cambridge – Outside the Green Belt. • Option 3: Edge of Cambridge – Green Belt. • Option 4: Dispersal – new settlements. • Option 5: Dispersal – villages. • Option 6: Public transport corridors. With only high-level options assessed at this stage, there is substantial uncertainty over the outcomes of these options. As such, the conclusions of the SA also are substantially uncertain, and more assessment is required with specific details provided on the deliverable projects which will make up these options. There is a possibility that a preferred option will be advanced with an equally valid alternative discarded at this early stage due to lack of information. Additional assessment should take place at another local plan stage, with full assessments within the SA Framework, before any options are fully dismissed. Without a full consideration of all these options which considers substantive detail of deliverable sites, there is a risk of the plan's selected alternative not being properly justified, and the plan being found unsound at examination. The options assessed in the issues and options report will likely only be achievable in combination with other options (e.g. some density within existing development, with some expansion to villages, etc). For transparency, the extent to which these options are likely to be combined in ultimate implementation should be made explicit in any future local plan documents which discuss these strategic options. None of the options put forward in the Issues and Options Report are reasonable alternatives capable of meeting the objectives of the plan, as none of them is shown to be capable of meeting housing need and economic potential on their own. As none of the options are reasonable in current form, they will need to be re-assessed at a subsequent stage when sufficient detail is available to robustly evidence the selection of a preferred option. The significant negative or positive effects given within the SA report are at this stage based on the limited information available misleading due to assumptions used and uncertainty attendant with such high level options. The SA Report notes a large number of points of uncertainty, but still identifies a number of significant effects (both positive and negative). However, there are assumptions for the significant effects identified which aren't clearly explained and which can be questioned. For example, Option 5 (Dispersal – villages) is attributed a significant negative effect to SA Objective 6 (distinctiveness of landscapes) as it is assumed that expansion of these villages could have an adverse effect on the open countryside and landscape surrounding these villages, as well as village character. As recognised in paragraph 3.61 the actual effect will depend on the final design, scale and layout of the proposed development. We recognise that SA is an iterative process which will evolve as a Local Plan progresses. More information should be provided on the approach to considering alternatives. The most substantive point we raise that this point is that the options set out in the Issues and Options Report should all be taken forward to subsequent local plan stages, where deliverable options should be assessed in detail, and transparent and objective assessment of these options provided at a subsequent SA stage. This will help ensure the Local Plan process and SA would support a hybrid of development scenarios which would underpin all development proposals at this stage.

Land lying to the northeast of Whippletree Road, Whittlesford, Cambridge

3.84

Site 45586 map

Agree

4.1 Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67). 4.2 As recognised, Greater Cambridge falls at the crossroads of a number of key economic corridors, including the Oxford-Cambridge Arc, London-Stansted Corridor and the Cambridge-Norwich tech corridor. The Oxford-Cambridge Arc in particular is a key economic priority as recognised by Central Government. Further work on the delivery of these initiatives will take place including the need for cooperation between authorities and stakeholders. 4.3 It is imperative that the New Local Plan has flexibility to allow for additional growth to come forward to meet the needs of these important initiatives as they develop through cross boundary and national discussions, potentially within the early/mid stages of the plan period.

Agree

5.1 Agree - The four big themes for the Local Plan are considered suitable and all are important in the consideration of the spatial distribution of growth in Greater Cambridge, and for the determination of planning applications. 5.2 The four big themes will generate a new way of planning, this may require a different way to make decisions; to allow other impacts to happen to achieve these four priorities. The Local Plan policy framework will need to allow for a clear planning balance to take place to assess and prioritise impacts. The need for homes and jobs remains as does the need to ensure development is viable and can come forward.

Great Places, Climate Change, Wellbeing and Social Inclusion, Biodiversity and Green Spaces

5.4 The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the new Local Plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 5.5 A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 5.6 If the new Local Plan is to achieve its ambitious targets on climate change the Councils should consider new ways of achieving net zero. It should recognise that seeking to achieve net zero on all sites regardless of their location and site-specific factors may not be feasible. Linked initiatives such as an offsetting scheme, secured through S106 financial contributions, could be an appropriate way of achieving net zero for small and medium developments. As recognised in the NPPF, small and medium developments, with their ability to be delivered early in the plan period at pace, will play an important role in meeting the Councils housing requirements and the needs of existing villages. Such sites may best secure net zero by contributing to an offsite initiative. 5.7 If an offsetting scheme is the preferred mechanism, then the Councils will need to set out a clear, appropriate and practical way to implement this, which will mean identifying strategic off-setting projects with Greater Cambridge, and potentially beyond, in collaboration with other key stakeholders. Any financial obligations towards an offsetting scheme will need to meet the statutory tests and considered in the context of viability. 5.8 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 5.9 The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound.

Yes, somewhat agree

5.10 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the new Local Plan progresses and must build in flexibility.

5.11 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new developments. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. 5.12 An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be considered. A policy basis to facilitate off-site biodiversity net gain is essential for smaller and medium sized developments. As recognised in the NPPF, small and medium developments, with their ability to be delivered early in the plan period at pace, will play an important role in meeting housing requirements and supporting existing villages. Such sites may best secure biodiversity net gain by contributing to an offsite initiative. A strategy for the delivery of off-site biodiversity net gain funded through development contributions would allow the Council new green infrastructure and biodiversity habitats to be strategically planned, which in turn, would provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new developments.