Greater Cambridge Local Plan Issues & Options 2020

8.3 It is recognised that no single solution will deliver a sound Local Plan; rather, a combination of approaches to the distribution of spatial growth will be necessary to establish the appropriate locations of new housing and employment development in the district. A hybrid approach will be required but should be underpinned by a focus on accessibility to public transport, employment and other daily needs. 8.4 It is considered that a dispersal to villages should form part of a hybrid spatial strategy. Development within villages is essential to support a prosperous rural economy. Paragraph 84 of the NPPF (2019) notes that: Planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. In these circumstances it will be important to ensure that development is sensitive to its surroundings, does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable (for example by improving the scope for access on foot, by cycling or by public transport). The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.

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8.5 Strongly agree. It should be noted that some villages are also located in the Green Belt and are on transport corridors, and as such development options that include these locations are also supported. 8.6 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. 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 is a realistic option. 8.7 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. 8.8 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.

9.1 In reviewing the documentation prepared by the Council, we recognise that this is an early stage in the plan’s preparation and that an SA 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. 9.2 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. 9.3 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. 9.4 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. 9.5 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. 9.6 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. 9.7 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. 9.8 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. 9.9 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 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.

Response to Question 2 - ADDITIONAL INFORMATION 2.1 Axis Land Partnerships is promoting ‘Station Fields, Land north of Foxton’ (“Station Fields”) for allocation as a new village community of circa 1,500 homes, alongside a proposed new travel hub and level crossing bypass, employment land, community and recreational facilities, public open space, sustainable urban drainage, new habitats and structural landscaping. 2.2 The vision for Station Fields is: “to create a vibrant 21st Century rural community that integrates with its existing surroundings and provides enhanced and more plentiful local services and facilities with excellent transport links” 2.3 Station Fields was submitted for consideration under the 2019 Call for Sites consultation. Axis are continuing to promote the Station Fields for allocation in the new Local Plan. Further technical assessment and design work has been undertaken to develop the emerging proposals to ensure that they are suitable and deliverable. Further information is contained within the revised Vision Document prepared by Barton Willmore and should be read in conjunction with these representations. 2.4 A replacement Call for Site form accompanies these representations to reflect the change to the site boundary and the refinement of the development proposals. In addition, several supporting technical documents have been prepared and can be shared upon request. A Logical Location 2.5 Station Fields is located six miles from Cambridge, outside the Green Belt. It benefits from existing and planned sustainable transport infrastructure; it is located next to Foxton Train Station and is the proposed location for a new Rural Travel Hub. It also benefits from an existing public rights of way network and will be located along the route of the proposed Melbourn Greenway. Not only will it promote sustainable travel into the centre of Cambridge, but it also has the potential to support the overall vitality and viability of the local rural area as part of a cluster of well-connected villages. It is a logical and sustainable location for growth. Further detail on the accessibility to sustainable transport infrastructure is provided below. Key Public Transport Corridor 2.6 Station Fields lies at an interchange between rail, road and cycle/walking greenways. The site is centrally located between the villages of Foxton, Barrington and Shepreth on the A10, adjacent to Foxton railway station and the proposed Melbourn Greenway. Foxton Train Station - Rural Travel Hub 2.7 Foxton Station is the first stop out of Cambridge with a journey time of just 6 mins. London Kings Cross station is a 1hr 14min journey on a direct train. From Foxton Station commuters can also connect with Royston, Letchworth Garden City, Hitchin and Stevenage all in under 30mins. 2.8 The Greater Cambridge Partnership (GCP) is promoting a ‘Travel Hub’ at Foxton Station to encourage more journeys into Cambridge by rail or cycle. They have, therefore, already identified that the site has very good non-car accessibility, particularly to Cambridge. A10 level crossing 2.9 The proposed development presents a significant opportunity to deliver a solution for the Foxton level crossing issues – a number one safety issue of local residents as highlighted in their Neighbourhood Plan research and highlighted by the Greater Cambridge Partnership (GCP) as an issue that needs attention for the Strategic Highways Authority. Axis have had early-stage discussions with both GCP, Network Rail and Homes England about the deliverability of a bypass in this location and are open and supportive to ongoing engagement and discussions about a solution. Melbourn Greenway 2.10 The Melbourn Greenway is a proposed route to enable cyclists, walkers and equestrians to travel sustainably from Melbourn into Cambridge. Its route passes close to Station Fields which could be incorporated into the Greenway offering an alternative route for new and current residents. There is potential to provide a well-positioned stop-off for users of the Greenway to provide convenience, refreshment and local services within the proposed Station Fields development. Supporting Local Villages 2.11 The National Planning Policy Framework 2019 advocates the need for plans to help villages grow and thrive. It also recognises the role that villages can have in supporting each other. 2.12 Station Fields is an area of land entirely outside of the Cambridge Green Belt, with the potential to support the surrounding local villages of Foxton, Barrington and Shepreth by providing the range of facilities and services that residents would wish to see as well as for those who would call it home. 2.13 In the current South Cambridgeshire Local Plan the settlement hierarchy classifications of Foxton, Barrington and Shepreth means there is little scope for development and as such provision of any meaningful services to future- proof the villages for generations to come. 2.14 With its location in the centre of these 3 villages, Station Fields is perfectly located and connected to provide rural jobs, natural open space, housing and services that will complement the existing communities of Foxton, Barrington and Shepreth , whilst protecting their individual identities and supporting them as attractive places to live for years to come. 2.15 The addition of a bypass, along with an improved travel hub and greenway would be a considerable improvement of connectivity locally and improve access to surrounding villages. Non-Green Belt Location 2.16 Station Fields is not within the Cambridge Green Belt. The National Planning Policy Framework 2019 confirms that the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development prior to releasing land from the Green Belt for development (paragraph 137). 2.17 In summary, a new small-scale settlement where future residents have direct access to sustainable transport infrastructure, allowing them to walk, cycle and/or use the train station to access facilities and amenities in surrounding villages, Cambridge City Centre and other key employment and leisure destinations, provides a sustainable allocation for the new Local Plan. Benefits of a new village 2.18 The National Planning Policy Framework 2019 recognises the role that new settlements can have in contributing to housing supply and bringing a greater scope of wider social, environmental, and economic benefits. 2.19 Paragraph 72 states that: “the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements…provided they are well located and designed and supported by the necessary infrastructure and facilities.” 2.20 Station Fields provides an excellent opportunity for a new comprehensively planned village supported by existing and planned sustainable transport infrastructure. Its scale allows for a mixed-use, socially inclusive community offering a greater range of homes, employment, health and recreational opportunities to be delivered. It also provides greater scope for environmental net gain both on and off-site. Responding to the Big Themes 2.21 Station Fields location, along with the proposed scale of development, offers numerous opportunities to contribute towards the Councils’ four Big Themes. Further detail of how this can be achieved is provided within the accompanying Vision Document, with a summary provided in the table below: BIG THEME SITE-SPECIFIC CONTRIBUTIONS Climate change Mitigation: BIG THEME SITE-SPECIFIC CONTRIBUTIONS ● Offering new and existing residents a realistic alternative to private car use through creating a new ‘Travel Hub’ to accommodate local car clubs, electric charging points and bike parking; ● Locating employment opportunities, retail and community facilities, and attractive public spaces within a walkable neighbourhood that will discourage the need for private car use; ● Creating increased and enhanced pedestrian and cycle links to better connect the surrounding villages; ● Adapting to new technologies and sustainability standards – realising the opportunities facilitated by a larger scale of development; and ● Incorporating renewable energy and smart solutions to energy efficiency through the use of photovoltaics and micro renewables focused on community buildings, schools and employment areas where larger roof expanses aid greener solutions. ● Creating new areas of woodland planting to contribute towards carbon offsetting within the site – areas close to the watercourse, public open spaces and local village greens all provide the opportunity for significant tree planting; ● Providing opportunities for growing food, through allotments, orchards and edible landscaping; ● Providing large areas for Sustainable Urban Drainage through attenuation ponds that are able to more sustainably manage water runoff and storage Biodiversity and Green Spaces ● Provision of sports facilities, allotments, and children’s play facilities, supporting healthy lifestyles; ● Promoting access to nature and the wider countryside, including the River Rhee County Wildlife Site, by returning arable land to its past use and opening up areas of natural grassland and wildflower meadows, taking advantage of the existing wildlife corridor along the watercourse ● Maximising the opportunity of the scale of development to achieve 10% biodiversity net gain on site without reliance on off-site mitigation; and ● Gathering spaces providing safe areas for social interaction with varied characters (contemporary / village green / naturalistic). ● A large area of the south west corner of the site is proposed for use as a ‘Countryside Park’. This will preserve a generous buffer of public open space that will be sympathetically designed to reflect the broadly rural setting of the ‘Roman site N of Brown Spinney’ scheduled monument (1006873). Wellbeing and Social Inclusion ● Creating well-used and active public places that will help to foster a sense of community and reduce crime, including the ‘Countryside BIG THEME SITE-SPECIFIC CONTRIBUTIONS Park’, sports provision, children’s play areas, and streets and local greens. ● Places that will offer natural sociability, interaction and neighbourliness; ● Capitalising on its proximity to Foxton Station and the planned Melbourn Greenway, which will enhance the development’s walking and cycling accessibility; ● Connecting the surrounding villages of Foxton, Barrington, and Shepreth to the wealth of new facilities through the integration with existing walking, cycling and public transport networks and provision of plentiful new pedestrian and cycle links; ● Addressing issues of affordability by providing a variety of housing including self/custom build and being adaptable to changing needs of an ageing population; ● Providing easily accessible new employment opportunities that will contribute directly to local populations, including commercial spaces suitable for smaller start-up companies; ● Ensuring a high quality of public spaces, buildings, community events, virtual notice boards, seating, meeting places and active streets that people want to use; and ● Promoting physical activity and health through the creation of natural and recreational open spaces; ● Creating a Wellness centre within the mixed-use area of Station Fields that offers lifestyle courses, exercise classes and places to encourage mental wellbeing; ● Locating new homes, employment, community facilities close to public transport and within a walkable neighbourhood, encouraging access to existing and new facilities by all; ● Providing local grow spaces, community allotments and orchards that will help people get interested in healthy foods and diets with a central market square able to hold weekly food markets selling local produce; and ● Supporting the implementation of air quality action plans through the promotion of sustainable transport modes infrastructure to support electric vehicles. Great Places ● Preserve the historic and distinctive identities of Foxton, Barrington, and Shepreth, by incorporating key characteristics of their vernacular and surrounding landscape; ● The Countryside Park will provide an opportunity for interpretation boards to improve public understanding and appreciation of the scheduled monument adjacent to the site. BIG THEME SITE-SPECIFIC CONTRIBUTIONS ● Capitalise on opportunities to use the intrinsic landscape positively in the design, including the retention of visual connections to Barrington All Saints Church and the creation of publicly accessible places in the setting of distinctive natural features such as the watercourse and trees; ● Safeguard local distinctiveness, whilst supporting the vibrancy and vitality of the existing communities through new complimentary facilities; ● Establish a truly connected and accessible place, providing clear and direct sustainable transport links between existing and new facilities; and Deliverability 2.22 The development proposals for Station Fields meet the definition of deliverable as set out within the National Planning Policy Framework (2019). ● Available – the site is available now with agreement with all landowners. ● Suitable – the site offers a suitable sustainable location for development now, benefitting from its location adjacent to Foxton train station and the A10 corridor. ● Achievable – there is a realistic prospect that housing will be delivered on the site within five years of adoption of the plan. Summary 2.23 In summary, Station Fields is located on a key public transport corridor; it benefits from access to Foxton Train Station, is the proposed location for a new Rural Travel Hub, has access to an existing PROW network and is along the route of the proposed Melbourn Cycleway. Therefore, future residents will not be reliant on use of private cars; they will be able to access both the City of Cambridge and its key employment and leisure locations, and also the surrounding villages, by walking, cycling and using bus and train services. 2.24 The proposed scale of development allows for a comprehensively planned new village, which can embed the Councils’ four Big Themes in its design. The scale means that a large supply of a variety of new homes, jobs and community and recreational facilities can be delivered, along with a wider scope for environmental net gains.

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Agree

3.1 Paragraph 22 of the National Planning Policy Framework 2019 (NPPF) states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. The proposed plan period up to 2040 will meet this minimum requirement, subject to the plan being adopted by 2025; this should be closely monitored as the preparation of the plan progresses. 3.2 However, there are several national and regional strategic spatial strategies and policies e.g. the Combined Authority’s Non-Statutory Spatial Strategy, the national requirement to achieve target net carbon zero by 2050 and the economic potential of the Cambridge-Oxford Arc, which look forward towards 2050 and will still be evolving during the course of the plan period. Therefore, the new Local Plan needs to build in sufficient flexibility to respond to these changes. 3.3 Moreover, it is imperative that the new Local Plan has flexibility to allow for additional growth to come forward to realise the potential of the economic corridors as they develop through cross boundary and national discussions, potentially within the early/mid stages of the plan period. Mechanisms, such as triggers for an early review of the Local Plan, should be explored.

Agree

3.4 The new Local Plan needs to align with the national and regional strategic planning for the Greater Cambridge area and beyond. In particular, the new Local Plan must include a commitment to contribute towards harnessing the potential of the Cambridge – Oxford Arc for Greater Cambridge by delivering new homes, jobs and infrastructure in the right locations to support the wider growth agenda. It should also aim to support the Combined Authority’s NonStatutory Spatial Planning Growth strategy target of doubling economic outputs, over the next 25 years. 3.5 Paragraph 22 of the NPPF 2019 advises that strategic policies should anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. The draft strategic policies should set out clear strategic priorities for the area, including the important cross-boundary issues and how this are addressed. In addition, the new Local Plan will need to build in sufficient flexibility to respond to development in cross-boundary infrastructure. 3.6 Many of the cross-boundary issues are still evolving and each stage of the plan’s preparation will need to respond accordingly. To achieve this, the Councils’ must effectively collaborate with the Combined Authority, Greater Cambridge Partnership and the County Council to ensure that all strategic, cross-boundary matters are aligned, beyond the Councils’ statutory duty to cooperate. We look forward to seeing statement of common grounds between all parties; these should be made publicly available throughout the plan-making process to provide transparency (as per paragraph 27 of the NPPF).

Agree

4.1 Axis agree that 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. 4.2 The four big themes will generate a new way of planning, which may require a different way to make decisions. 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.

4.4 Axis supports the Councils’ commitment to achieve net zero carbon by 2050. However, as climate change policy and best practice is changing quickly, with climate change scenarios predicting extensive changes by 2050, the new Local Plan will need to build in suitable flexibility to accommodate these changes within the plan period. 4.5 The new Local Plan will need to incorporate flexibly worded policies, which recognise that a range of on-site and off-site measures can contribute towards achieving net zero. It should avoid restrictive requirements and targets for meeting net zero carbon. 4.6 A needlessly stringent policy may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well as the current grid challenges in implemented EV charging places. 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 Page 15 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. 4.7 If the new Local Plan is to achieve its ambitious targets on climate change the Council should consider new ways of achieving net zero. It should recognise that seeking to achieve net zero on all sites regardless of their site, location and site-specific factors may not be feasible. Linked initiatives such as an offsetting scheme, secured through S106 financial contributes, could be an appropriate way of achieving net zero. 4.8 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. 4.9 The spatial growth strategy for the new Local Plan will have a significant role in achieving net zero carbon across Greater Cambridge. The aim to promote low-carbon lifestyles, encourage low carbon activities, and promote alternatives to private car use is supported. The spatial strategy should support this, with patterns of development that enable travel by low-carbon modes such as walking, cycling and public transport prioritised. 4.10 As part of a hybrid approach, the new Local Plan should recognise the role and scope that larger scale development, which builds upon existing sustainable transport infrastructure, can have in achieving net zero and support the allocation of these sites for development. Station Fields, which is being promoted by Axis, is located along a strategic public transport corridor. The scale of development offers opportunities for creating cost-effective and integrated solutions as part of an overarching climate change strategy. 4.11 We note that the Councils’ have commissioned further work to test the options for higher standards of carbon reduction to understand potential to achieve net zero carbon in new development. This should be made publicly available as part of the Council’s evidence base. 4.12 In addition, the Local Plan’s Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios as a lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound.

Nothing chosen

4.13 Due to the anticipated rate of change in climate adaptation and mitigation measures over the plan period, a policy approach which allows for different solutions to be considered for each new development, as and when they come forward, is essential. This will allow for new or advancing technologies to be considered at the appropriate time.

4.14 This new Local Plan must deliver effective policy which protects and enhances natural capital. To achieve this, the new Local Plan should be flexible enough to enable creative and cost-effective solutions for the delivery of net gain both on and off-site. 4.15 An off-site net gain solution should be allowed for by policy. The Councils’ should work collaboratively with other key stakeholders to develop a strategic offsetting mechanism to support this. This would allow for new green infrastructure and biodiversity habitats to be strategically planned. This has potential to provide a greater overall net gain, than the provision of small, uncoordinated and disconnected new habitats across a range of new developments and locations. 4.16 In addition, the Local Plan should recognise the scope that larger scale development/new settlements have in providing net gain in biodiversity through onsite and offsite provision, taking a more radical approach to the use of planning contributions in improving the natural environmental on the local and wider scale. 4.17 Overall, any future Local Plan policy must allow for a planning judgement and balanced decision to be made for each site taking into account development specific issues.