Greater Cambridge Local Plan Issues & Options 2020

Agree

The Greater Cambridge Planning Authority’s ambition is to submit a new Local Plan for examination by 2022. Given the complexities of the planning issues associated with Greater Cambridge and its future development, it is reasonable to assume that the examination process will not be straightforward. The original Local Plans were submitted in 2014 and were not adopted until 2018 and even then, were subject to a commitment to an immediate review. While the new Local Plan will be based on a lot of the adopted Local Plan work, a pragmatic time table for adoption from submission would be a minimum two year period resulting in adoption in 2024 at the earliest rather than 2023 as suggested. Paragraph 67 of the NPPF requires planning policies to identify specific deliverable sites for the first five years of the plan period and specific, developable sites (or broad locations for growth) for years 6 to 10 and where possible for years 11 to 15 of the plan period. The plan should therefore cover a minimum period of 15 years from adoption, if future development is to be based on a genuinely plan lead approach. While the currently adopted Local Plans may provide some certainty, subject to housing delivery and five year housing land supply issues, for the first five years, i.e. 2018 to 2023, the new Local Plans should follow on for the next 15 years, i.e. up to 2038 as a minimum. If as set out above the reality is that the new Local Plan is not adopted until at least 2024, 15 years on would take it to 2039. It is therefore concluded that a plan period to 2040 is an appropriate plan period, in particular having regard to climate change and the imperative to take action now. However, the plan needs to be visionary looking forward beyond 2040 in particular having regard to the Greater Cambridgeshire non statutory plan which covers the period to 2050 and the Government’s commitment to reach Net Zero Carbon by 2050. The plan needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the plan area. Summary of Comments: We agree that the plan period to 2040 is appropriate although the plans vision should be beyond 2050.

Agree

Q6: Do you agree with the potential big themes for the Local Plan? 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 and Green Spaces; - Wellbeing and Social Inclusion; and - Great Places. We agree with 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) Scott Properties feel passionately about the need to address Climate Change. It is agreed that this is one of the most important factors to our future and as such should be a key consideration in the preparation of the new Local Plan. New policies should support appropriate measures to ensure the resilience of communities and infrastructure to climate change impacts such as floods, heatwaves and droughts which are considered likely to the Cambridge area. On the 21st February 2019, Cambridge City Council declared a ‘climate emergency’ and called on the Government, industry and regulators to implement the necessary changes to enable Cambridge and the rest of the UK to reach net zero carbon by 2030. Whilst we are supportive of the big themes, we do feel that an ageing population and affordability should be identified within these, to ensure that the Plan does not overlook these as important issues facing Greater Cambridge. The Housing for older and disabled people PPG, which was published after the adoption of the existing local plans, stresses the importance of the need to provide housing for older people. We therefore feel that provision for accommodation for older people should be clearly referenced in the big themes and addressed within the Local Plan. Furthermore, we believe that my client’s Site can help address these themes.The land to the east of Ditton Lane, Fen Ditton, could deliver c.30 single storey dwellings (both market and affordable) suitable for those aged 55 and over as well as those with or supporting someone with a disability, with associated infrastructure and open space. The provision of specialist accommodation for older people allows people to downsize while remaining in the local area and close to friends and family. New family housing also comes to the market as a result, reducing the pressure to provide additional family housing sites in the local area. This in turn allows new families to move to the area helping to redress the demographic imbalance and increase support for the continuance of demand for existing services and facilities. In addition, Scott Properties are working with landscape and ecology consultants, Lockhart Garratt, to develop a landscaping and ecology plan for the Site, providing a net biodiversity gain in excess of the Government targets. This will also contribute towards both the Great Places and the Wellbeing and Social Inclusion big themes, creating an environment rich in in biodiversity and enhancing the social wellbeing for existing and future residents. It is considered that the allocation of the Site within the Greater Cambridge Local Plan would be consistent with, and support the big themes for the area. Summary of Comments: We support the key themes, although would suggest they are of equal importance to one another.

Question 31. How should the Local Plan help to meet our needs for the amount and types of new homes? In accordance with the NPPF, the Planning Practice Guidance (PPG) and the Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should be seeking to meet housing needs through the development of a range of housing sites. While the existing strategic allocations and new settlements are an important component of housing delivery, paragraph 68 of the NPPF advises 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.” The existing planning strategy places a significant reliance on the strategic allocations around the City and also the development of new settlements which the Local Plan Inspectors raised concerns about. The new Joint Local Plan should signifcantly increase the allocation of small to medium sized sites in a variety of locations, including rural areas, to help speed up the delivery of homes and allow more flexibility in the type of properties that come forward. It is important that the rural areas are not left behind but allowed to prosper and thrive, in accordance with paragraph 78 of the NPPF. It will be necessary for the new Joint Local Plan to identify at least 10% of the housing allocations on sites no larger than one hectare (NPPF para 68 (a)). This, coupled with medium sized allocations, such as the land to the east of Ditton Lane, Fen Ditton, will provide greater potential to deliver a more diverse range of housing, better suited to local needs and capable of delivery within the short term, unlike the larger, strategic allocations. It will ensure that not all the growth is focused on the City but also supports the parallel growth of the rural economy. Increased allocations on small and medium sized sites will increase delivery and help improve affordability through increased supply. A wider range of sites will also allow more flexibility in the mix, type and tenure of homes delivered. It will be important to take a flexible approach to development proposals designed to meet the needs of an ageing population, a growing demographic group whose needs will need to be accommodated over the plan period. Paragraph 61 of the NPPF requires the size, type and tenure of housing needed for different groups in the community to be assessed and reflected in planning policies, which includes older people and people with disabilities. In addition, the Housing for older and disabled people PPG, which was published after the adoption of the existing local plans, stresses the importance of the need to provide housing for older people. It also recognises that housing needs amongst older people differ greatly, requiring strategic policy-making authorities to determine the needs of people who will be approaching or reaching retirement over the plan period, as well as the existing population of older people. According to ONS data, by 2035, almost 22% of the population within Greater Cambridge will be aged 65 or over, therefore it is imperative that the plan makes adequate provision for older people within the Joint Local Plan. The allocation of Scott Properties' Site to the east of Ditton Lane, Fen Ditton for c.30 single storey properties specifically designed for those aged 55 and over as well as those with or supporting someone with a disability would help towards meeting a locally defined need for specialist accommodation. The Site would fulfil all of the above objectives and while the Site's individual contribution to the total housing need referred to above would be modest, it would make an effective and proportionate contribution to a specific need at the local level. Attached to these representations is a Specialist Accommodation Needs Assessment, which seeks to assess the provision of specialist housing that may be required within Fen Ditton Parish, and, within a 5 minute drive-time of Fen Ditton. The latter generates a potential requirement for 125 specialist properties by 2023. The Site represents an opportunity to provide this type of accommodation in a highly sustainable location, close to key transport links and a number of facilities, both within Fen Ditton, adjacent Cambridge and proposed as part of the consented c.1300 dwelling scheme on land to the north of Newmarket Road. The provision of c.30 single storey properties would also represent a modest 10% increase to the existing property numbers in Fen Ditton. Summary of Comments: The new Joint Local Plan will need to allocate sufficient small to medium sized sites specifically to meet the needs of its ageing population.

Nothing chosen

Q32. Do you think we should plan for a higher number of homes than the minimum required by government, to provide flexibility to support the growing economy? 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 Greater Cambridge Local Plan acknowledges, 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.' 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 adds 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.' In terms of housing numbers, the Cambridge & Peterborough Independent Economic Review identified that the recent growth in employment has not been matched by corresponding house-building and state that ‘We are rapidly approaching the point where even high-value businesses may decide that being based in Cambridge is no longer attractive. If nothing is done, the damage to society from the continuing drift away of less well-paid workers may become irreparable.’ To support the job growth, around 2,900 homes would need to be built each year to deliver a total of 66,700 homes between 2017 – 2040, in contrast to the 1,800 homes per year using the Government’s standard methodology. The PPG is clear in that the standard method provides a minimum number of homes to be planned for, and that this should be used as a starting point when preparing the housing requirement in their plan, unless exceptional circumstances justify an alternative approach (Paragraph: 001 Reference ID: 68-001-20190722). This higher level of growth is supported, to help deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over 25 years and it is considered that these are exceptional circumstances that justify a departure from the use of the standard method for calculating housing need. 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'. To support the job growth around 2,900 homes would need to be built each year to deliver a total of 66,700 homes between 2017 – 2040 rather than the 1,800 homes per year using the Government’s standard methodology. This higher level of growth is supported and necessary to help deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over 25 years. For these reasons, we 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 support the growing economy'. Summary of Comments: Strongly agree that 'we should plan for a higher number of homes than the minimum required… to provide flexibility…for the growing economy'.

Question 37. How should we encourage a shift away from car use and towards more sustainable modes of transport such as public transport, cycling and walking? The spatial strategy approach is a key way of encouraging shifts away from car use towards more sustainable modes of transport by focusing development in locations with good existing public transport or with potential for improved public transport. However, this needs to be balanced in the rural areas where the NPPF recognises that the opportunities will vary between urban and rural areas. The need to identify a high number of small and medium sized sites in the rural areas means that sites which are well located in relation to existing services and facilities such as Scott Properties' site at Land south of Ditton Lane, Fen Ditton, should be preferred over more remote and isolated locations in the rural areas. The site is located to the south of Fen Ditton and abuts the Cambridge City boundary. The village operate as a larger settlement with Cambridge City nearby and shares a good range of services and facilities. Cambridge City Centre contains a full range of services, retail offers, employment opportunities and leisure and recreational facilities. It also has a mainline railway station providing regular services to London, Birmingham, Stansted Airport, Ely, Ipswich and Brighton. Newmarket Road Park and Ride is also within close proximity to the Site and accessible by a public footpath from the Site. Given the Site's close location to Cambridge City Centre and links, we consider that it to be in a highly sustainable location. In addition, the recently consented development including c.1300 dwellings to the north of Newmarket Road provides additional facilities including a food store, community facilities and open space which are within close proximity and easy access of the Site, owing to the extensive footpath and cycle links through the new development. In relation to this permission, document 16-097_PL_DOC_19_001_Infrastructure of reserved matters application S/1004/18/RM shows the pedestrian and cycle links as existing and proposed as part of the (granted) reserved matters application. This shows a pedestrian and cycle link north from the consented development into the east of my client's Site, land to the east of Ditton Lane from the disused railway line to the south of my client's Site. This is not an existing footpath, and this route of connectivity cannot be achieved without my client's land. The inclusion of my client's Site therefore represents an opportunity to increase connectivity, which would be of clear benefit to the existing and future residents of the area. The Plan attached to these representations shows how connectivity could be achieved through the allocation of my client's Site. Summary of Comments: The spatial strategy will need to recognise the different opportunities available between urban and rural areas.

Nothing chosen

Q39. Should we look to remove land from the Green Belt if evidence shows it provides a more sustainable development option by reducing travel distances, helping us reduce our climate impacts? It is known that the Government attaches great importance to the Green Belt, the fundamental aim of which is to prevent urban sprawl and keep land permanently open. The anticipated forthcoming Planning White Paper may make some changes to this situation with potentially some relaxation. However, until it is published, current national planning policy remains that the Green Belt serves five purposes: a. To check the unrestricted sprawl of built up areas; b. To prevent neighbouring towns merging into one another; c. To assist in safeguarding the countryside from encroachment; d. To preserve the setting and special character of historic towns; and e. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Green Belt boundaries are established through Local Plans and should only be altered where exceptional circumstances are fully evidenced and justified. As part of the preparation of the currently adopted Local Plans, minimal changes to the Green Belt were proposed. These were limited to a number of small scale changes to allow the expansion of some existing urban extension allocations and a small number of new allocations. The new Joint Local Plan should undertake a fundamental review of the entire Cambridge Green Belt to understand whether it still serves a relevant function in planning terms, or is stifling sustainable development. Potentially, it is promoting unsustainable patterns of development which simply leapfrog the Green Belt and result in development in less sustainable locations, increasing the need to travel between Cambridge and outlying areas that as such, are less connected to public transport routes. It is clear that given the geography of Greater Cambridge in which many of the most sustainable parts of the spatial planning area are located within the Green Belt, that some Green Belt release should form part of the overall spatial strategy. In this way, the area can help to reduce travel distances and help faciliate sustainability through the provision of sustainable transport infrastructure. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time the Green Belt was introduced, the need to promote sustainable development which meets today’s needs including housing, employment and environmental considerations were very different. Today’s issues of climate change, congestion, pollution, water security, food production and fuel poverty suggest that a more radical approach to planning policy is required. At the time the Green Belt was established, the tools available to planners were more limited and the ability to analyse opportunities and constraints and develop robust evidence and justification, were at best very basic. A blanket protection of large swathes of land was therefore considered appropriate. At the time the pressures for growth and essential need for development were considerably less than they are today. Greater Cambridge is an exceptional area, both in its contribution to the national economy and its international reputation. In order to sustain its natural growth in a sustainable way, a wholesale review of the Cambridge Green Belt should be undertaken. This should be a balanced review, not simply an assessment of the performance of various parcels of land against the purposes of Green Belt. It should be a challenging assessment balancing the scale of development required to support the growth necessary to deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over the next 25 years. To support this level of job growth around 2,900 homes will need to be built each year to deliver a total of 66,700 homes between 2017 – 2040. It is imperative both locally and at the national level that Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. Cambridge as a city is also exceptional and as such a radical review of Green Belt policy is clearly justified to facilitate its growth. The tools available today to analyse and inform plan making decisions are highly sophisticated and should be used to undertake a challenging and balanced review of the existing Green Belt. This should include taking a finer grain approach, to assess whether there are smaller parcels of land that could be released from the Green Belt without harm. This is particularly important within the areas that benefit from sustainable transport options, such as Fen Ditton, which benefits from Newmarket Road Park and Ride, as well as numerous pedestrian and footpath links. The land to the east of Ditton Lane, Fen Ditton, is located within the Green Belt, although is well contained by existing vegetation, providing effective screening for development. Although the site extends to 4.33 Ha in total, the identified development areas (as shown in the attached Context and Planning Policy Plan) extend to c.1.61 Ha providing significant opportunities for appropriate landscaping to enhance the landscape and maintain a gap between Fen Ditton and Cambridge. This represents 37% of the total site area, with 63% available for landscaping and ecological enhancement. Whilst the important role that the Green Belt plays is acknowledged, a flexible approach needs to be taken where sites such as land east of Ditton Lane, Fen Ditton benefit from their proximity to existing frequent public transport, and given the proposed use, is the most sequentially preferable Site in terms of distance from the doctor's surgery. The Site also presents opportunities for small-scale Green Belt release that would help to enable an existing sustainable village such as Fen Ditton to grow in a sustainable manner. The Site is being promoted for c.30 single storey properties designed specifically for those aged 55 and over as well as those with or supporting someone with a disability. This represents a modest increase in size of 10% for Fen Ditton, based on the existing number of properties within the Parish. In addition, it is also located close to numerous services and facilities, within Fen Ditton itself, Cambridge and the consented scheme north of Newmarket Road, which includes a foodstore, community facilities and open space. Sequentially, the Site is the closest development site within Fen Ditton, a highly sustainable location, which is within c.0.5km of the doctor's surgery, that can be brought forward for the type of small-scale development proposed, with the opportunities for increased biodiversity gain and considerable landscaping to create an attractive, biodiverse environment. Summary of Comments: The Local Plan should consider Green Belt release in sustainable locations close to existing transport.

No choices made

Within this question the Greater Cambridge Shared Planning Service invites consultees to rank a series of options about where new development should be located within the spatial planning area of Greater Cambridge. It explores six choices: - densification of existing urban areas - edge of Cambridge: outside Green Belt - edge of Cambridge: Green Belt - dispersal - new settlements - dispersal: villages - public transport corridors This is a rather blunt tool in which to assess the spatial approach and a flexible approach is likely to be more appropriate. The Cambridge & Peterborough Independent Economic Review, which was published in September 2018 concludes that 'Cambridgeshire and Peterborough is an area which already makes a huge contribution to the UK, and which holds great promise for the future. It also faces risks, which could bring the success to an end, and challenges realting to creating an inclusive society where economic growth works for everyone'. The CPIER, which admittedly covers a wider geography than Greater Cambridge, advocated a 'blended spatial strategy' of four possible scenarios. The scenarios considered included: - densification - dispersal - fringe growth - transport corridors The housing market area for Greater Cambridge is a very challenging one. Affordable housing delivery is a significant problem with high levels of demand for affordable and key worker housing. The ageing population will also add significantly to the demand for specialist housing. Consequently, the new Plan needs to be very ambitious in terms housing delivery to ensure that there is a significant supply and mix of deliverable housing sites across the plan area, in excess of the levels of identified need, to boost delivery and help maintain competition in market and drive affordability. This will require a flexible spatial strategy which allocates varying sized sites in various locations across Greater Cambridge. The joint Inspector’s Report on the Examination of the South Cambridgeshire Local Plan (August 2018) noted at para. 21: “The Plan proposes that development needs will be met at two new settlements at Waterbeach and Bourn Airfield. We have some concerns regarding the challenges of delivering new development at Waterbeach and Bourn…” However, because these development sites were not required to deliver housing in the early part of the plan period, the Inspectors concluded that due to the plans commitment to an early review there would be an opportunity to review progress as part of the preparation of the new Joint Local Plan. We consider the Inspectors concerns to be justified and that the new Joint Plan should include a range of allocations and essentially more small and medium size sites throughout the area to ensure that rural settlements have the opportunity to grow and thrive in line with National Planning Policy advice. It is important to note that the Inspector for the Uttlesford Local Plan Examination wrote to the Council on the 10th January 2020 raising significant concerns in relation to the soundness of the plan. In particular, in respect of the overall spatial strategy which relies on the development of three Garden Communities. At para 31. of their letter they stated: “…the scale of the need for housing for the next plan period is currently unknown and uncertain. We are concerned that the Council’s chosen strategy (reliance on three Garden Communities) would mean that other sites in the district would not be developed or permitted for a significant period of time in the future. This would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market. It would also be difficult to accommodate changes in demand for certain types of development/services required over the very long period being committed to within the current strategy.” The Inspectors went on to state that the reliance on Garden Communities carried with it significant risks and a lack of flexibility. Furthermore, it would result in a worsening of affordability problem as it would delay delivery of housing to meet an identified need for a number of years. They concluded (Para. 114) that: “In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5 year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing…” This reinforces the essential need for the new Greater Cambridge Local Plan to be based on a blended strategy which builds on the existing unban extensions already allocated around Cambridge and the strategic growth proposed at Cambourne, Northstowe, Waterbeach and Bourn Airfield through the allocation small and medium sized sites across the plan area. This is imperative to not only maintain supply and flexibility but to ensure that the rural areas can prosper and thrive and are not left behind. Fen Ditton is a village which is also on a public transport corridor, therefore we consider this to represent a suitable location for the type of development proposed, given the identified unmet need for specialist housing. Summary of Comments: A blended strategy is supported but specifically including development in villages.

No choices made

Q7: How do you think we should prioritise these big themes? Further to our response to question 6, we believe that the big themes are equally as important as one another and agree with the statements regarding each one within the consultation document. Therefore, we would propose that these are all ranked equally as all are important towards sustainability. As the NPPF states, the purpose of the planning system is to contribute to the achievement of sustainable development and should ‘meet the needs of the present without compromising the ability of future generations to meet their own needs.' We consider that the big themes cover the social, environmental and the economic objectives as set out in the NPPF, although would draw attention to our response to Q6 in relation to recognising importance of affordable housing and providing suitable housing for the ageing population and making adequate provision for this. Summary of Comments: We consider the big themes to be of equal importance to one another.

No choices made

Response to Question 42 Within this question the Greater Cambridge Shared Planning Service invites consultees to rank a series of options about where new development should be located within the spatial planning area of Greater Cambridge. It explores six choices: - densification of existing urban areas - edge of Cambridge: outside Green Belt - edge of Cambridge: Green Belt - dispersal - new settlements - dispersal: villages - public transport corridors This is a rather blunt tool in which to assess the spatial approach and a flexible approach is likely to be more appropriate. The Cambridge & Peterborough Independent Economic Review, which was published in September 2018 concludes that 'Cambridgeshire and Peterborough is an area which already makes a huge contribution to the UK, and which holds great promise for the future. It also faces risks, which could bring the success to an end, and challenges realting to creating an inclusive society where economic growth works for everyone'. The CPIER, which admittedly covers a wider geography than Greater Cambridge, advocated a 'blended spatial strategy' of four possible scenarios. The scenarios considered included: - densification - dispersal - fringe growth - transport corridors The housing market area for Greater Cambridge is a very challenging one. Affordable housing delivery is a significant problem with high levels of demand for affordable and key worker housing. The ageing population will also add significantly to the demand for specialist housing. Consequently, the new plan needs to be very ambitious in terms housing delivery to ensure that there is a significant supply and mix of deliverable housing sites across the plan area, in excess of the levels of identified need, to boost delivery and help maintain competition in market and drive affordability. The joint Inspector’s Report on the Examination of the South Cambridgeshire Local Plan (August 2018) noted at para. 21: “The Plan proposes that development needs will be met at two new settlements at Waterbeach and Bourn Airfield. We have some concerns regarding the challenges of delivering new development at Waterbeach and Bourn…” However, because these development sites were not required to deliver housing in the early part of the plan period, the Inspectors concluded that due to the plans commitment to an early review there would be an opportunity to review progress as part of the preparation of the new joint local plan. We consider the Inspectors concerns to be justified and that the new plan should include a range of allocations and essentially more small and medium size sites throughout the area to ensure that rural settlements have the opportunity to grow and thrive in line with National Planning Policy advice. It is import to note that the Inspector for the Uttlesford Local Plan Examination wrote to the Council on the 10th January 2020 raising significant concerns in relation to the soundness of the plan. In particular, in respect of the overall spatial strategy which relies on the development of three Garden Communities. At para 31. of their letter they stated: “…the scale of the need for housing for the next plan period is currently unknown and uncertain. We are concerned that the Council’s chosen strategy (reliance on three Garden Communities) would mean that other sites in the district would not be developed or permitted for a significant period of time in the future. This would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market. It would also be difficult to accommodate changes in demand for certain types of development/services required over the very long period being committed to within the current strategy.” The Inspectors went on to state that the reliance on Garden Communities carried with it significant risks and a lack of flexibility. Furthermore, it would result in a worsening of affordability problem as it would delay delivery of housing to meet an identified need for a number of years. They concluded (Para. 114) that: “In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5 year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing…” This reinforces the essential need for the new Greater Cambridge Local Plan to be based on a blended strategy which builds on the existing unban extensions already allocated around Cambridge and the strategic growth proposed at Cambourne, Northstowe, Waterbeach and Bourn Airfield through the allocation small and medium sized sites across the plan area. This is imperative to not only maintain supply and flexibility but to ensure that the rural areas can prosper and thrive and are not left behind. Summary of Comments: A blended strategy is supported but specifically including development in villages.

No choices made

Further to our response to question 6, whilst Climate Change is the most important theme, we believe that the big themes are equally as important as one another and agree with the statements regarding each one within the consultation document. Therefore, we would propose that these are all ranked equally as all are important towards sustainability. As the NPPF states, the purpose of the planning system is to contribute to the achievement of sustainable development and should ‘meet the needs of the present without compromising the ability of future generations to meet their own needs’ Summary of Comments: We support the key themes.