Greater Cambridge Local Plan Issues & Options 2020

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 Green Belts, 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 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 for the City, 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. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time Green Belts were 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 Belts were 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 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. In respect of our client’s sites at Park Farm paragraph 138 of the NPPF indicates: “…Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.” NIAB Trusts’ extensive land holding at Park Farm would allow these objectives to be fulfilled. Public open space could be provided for the enjoyment of both new and existing residents through the development of my client’s sites. There is the opportunity expand the connectivity of the footway/cycleway network via the A14 bridge to Darwin Green, broadly in line with the aspirations of the Histon and Impington Neighbourhood Plan. It will be possible to deliver net biodiversity gains compared to the current agricultural use through the provision of green infrastructure, wildlife corridors and dedicated ecology areas which would also contribute to the big themes that are proposed to be included within the new Local Plan. We therefore conclude that the new local plan should take the opportunity to review the Green Belt boundaries around Park Farm and allocate these additional development sites. Summary of Comments: A radical review of the Cambridge green belt is required to facilitate growth within the Greater Cambridge area and sites need to be released.

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Q40: How flexible should the Local Plan be towards development of both jobs and homes on the edge of villages? Flexibility should be given to the development of jobs and homes on the edges of villages, within sustainable locations. As stated at paragraph 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. In addition, villages within the Local Plan 2018 have been categorised dependant on their ‘sustainability’. Histon and Impington are categorised as a ‘Rural Centre’ (Policy S/8) which are considered the most sustainable villages in the district with good access to a secondary school, employment and various services and facilities in addition to good transport services. Whilst Girton, is identified as a Minor Rural Centre (Policy S/9), the next level down from Rural Centre’s within the hierarchy and are considered to have ‘a lower level of services, facilities, and employment than Rural Centres, but a greater level than most other villages in South Cambridgeshire’. Both settlements are therefore sustainable locations for growth with good public transport links to Cambridge. The new Local Plan should be more flexible at focussing development at the edge of the village boundaries, particularly those that rank higher in terms of sustainability such as the Rural Centres and Minor Rural Centres at policies S/8 and S/9 of the current Local Plan. Proposals such as those at our client’s sites, Land west of South Road, Impington and Land east of Redgate Road Girton should be supported. The additional benefits of the proposed improvements to sustainable transport linkages through the introduction of a new cycle/footway into Cambridge would significantly improve the sustainability of the sites. As such these proposals should be ranked highly in terms of sustainability, creating great places and being mindful to climate change. Summary of Comments: The new Plan should be highly flexible towards development of jobs/homes on the edge of villages to be able support the significant development needs.

Q45: What do you think about developing around the edge of Cambridge in the Green Belt? The focus on growing our villages throughout South Cambridgeshire District would, as paragraph 5.4.3 of the consultation document outlines, maximise the potential for sustainable transport. Paragraph 136 of the NPPF is clear that Green Belt boundaries should only be altered where exceptional circumstances can be evidenced and justified through the preparation or updating of plans. In respect of the three sites being put forward by NIAB, they are located between Girton, Histon and Impington which are settlements located on the edge of Cambridge and have excellent public transport links into the centre, which is also accessible by cycling and walking. We are of the view that a strategic case for the allocation of all three sites can be made which would provide additional housing and employment space within compatible sites and in a sustainable location. Paragraph 138 of the NPPF states promoting sustainable patterns of development should be taken into account when reviewing Green Belt boundaries. It goes on to state that Local Planning Authorities should channel sustainable development towards urban areas within the Green Belt boundaries and the impact of removing land from the Green Belt should be offset through compensatory improvements. The sites are located within the Green Belt and therefore the Council will need to amend the boundary to accommodate their allocation. The preparation of the new Local Plan therefore represents an opportunity to review the Green Belt boundary for the sites being put forward by NIAB. We believe the three sites are suitable for a sympathetic, sustainable and proportionate extension to the existing settlements of Histon, Impington and Girton for additional housing and employment land. These sites are ideally located on the edge of Cambridge with excellent transport links into the centre via public transport, cycling and walking. In view of this, with the support of an allocation, we would encourage our client to bring forward a development that takes advantage of these links to reduce the amount of private car journeys into Cambridge and improves footway and cycleway connections, access to the remaining Green Belt with biodiversity and environmental quality compensatory improvements. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time Green Belts were 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 Belts were 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. 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, 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 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. Summary of Comments: Development needs to take place within the Cambridge Green Belt, a radical review of the Green Belt is required to facilitate growth in the area.

Q47: What do you think about growing our villages? We strongly support suitable growth within villages, particularly the villages located in the most sustainable locations. The focus on growing our villages throughout the District would help sustain existing facilities and infrastructure within them 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. The new Plan needs to ensure that existing businesses within the villages are able to stay open and provide services not only for the village that they are located, but also for smaller infill Villages, many of which rely on the services within and adjacent to larger settlements. Sustainably located villages such as Histon, Impington and Girton are ideally located and of a size to accommodate a suitable proportion of housing and employment growth. Growing these would not necessarily see an increase in commuting by car or the need to travel to access services and facilities due to availability of services and easy access to public transport links. Conversely, it would assist with minimising the impact on the already at capacity highway infrastructure in and around Cambridge City Centre, which has recently had substantial housing growth. In addition, to ensure supply is maintained, Local Planning Authorities are also required to monitor the progress in building out sites, to comply with the housing delivery test, as outlined within our covering letter. Currently, the supply of housing in South Cambridgeshire is only marginally above the 5-year requirement (5.05 years – Appeal Reference APP/W0530/W/19/3220761) and the Government’s recently published housing delivery figures for 2019 indicate delivery to be at 95% which while not significantly below the target is still falling short. The current Local Plan 2018 for both South Cambridgeshire and Cambridge City includes allocations for two new settlements at Waterbeach and Bourn Airfield as well as the continued development of Northstowe. However, these larger growth sites will only be delivered later on in the plan period and as acknowledged within the Inspectors Report, there is ‘no requirement for these sites to deliver housing in the early years of the plan period and consequently there will be an opportunity to review progress through the preparation of a joint local plan.’ The Council will also be aware of the recent outcome of the Uttlesford Local Plan Examination, where the Inspector was concerned that an overreliance had been placed on the development of three new garden communities and that insufficient smaller sites had been identified throughout the rural area to ensure that a 5-year supply could be maintained. 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. Histon, Impington and Girton are fortunate in this regard and have maintained a number of its key services and transport options. It is therefore important to enable modest, appropriately-sized extensions to rural centres and villages so that the remaining services can be supported and to enable much needed new market and affordable housing to be provided. Summary of Comments: Support for a strategy that includes growth in villages at a level that is commensurate with their size and scale and enables sustainable growth.

Q48: What do you think about siting development along transport corridors? Focusing homes and jobs along key public transport corridors and around transport hubs extending out from Cambridge could be achieved by focusing growth around the towns and villages located along these routes and this is strongly supported. Summary of Comments: Growth should be focussed within transport corridors to enable growth.

Q49: Do you have any views on any specific policies in the two adopted 2018 Local Plans? If so, what are they? It is considered that the development strategy and settlement hierarchy policies in the South Cambridgeshire Local Plan: S/6, S/7, S/8, S/9, S10 & S/11 are unnecessarily restrictive and do not promote sustainable patterns of growth or allow appropriate levels of growth in rural areas, as required to support a prosperous rural economy. The NPPF recognises that rural settlements operate in a more complex way then a simple hierarchy, based on the presence/location of services and facilities. Often, a larger centre acts as a focus for a network of surrounding hinterland villages and it would be more appropriate for these groupings to be considered as a whole. It may be more appropriate that development in a number of hinterland villages, which would support, and be supported by, services and facilities in a larger settlement, would represent a more sustainable pattern of growth. It is not always the best solution to be adding growth to larger settlements where smaller settlements may be able to accommodate growth with less environmental harm. The new Local Plan should be more flexible and not apply upper limits to levels of growth, rather look to allocate a significant range of small and medium sized sites throughout the rural group areas, selecting the most appropriate sites, rather than those simply closest to services and facilities. As set out in question 31, in order to deliver 10% of small sites of one hectare or less, potentially over 266 sites will need to be found in the rural areas and a similar supply of medium sized sites will also need to be found to maintain delivery and provide flexibility. It needs to be recognised that opportunities to maximise sustainable transport solutions are different in rural areas (NPPF paragraph 103). Reduced sustainable transport opportunities should not simply be used as a reason to rule out growth which may have greater benefits in terms of enhancing the vitality of rural communities. It is important that opportunities for villages to grow and thrive are identified rather than stifled by overly rigid policies. Summary of Comments: Support for a blended spatial strategy that includes growth in the villages.

Agree

Q4: Do you agree that planning to 2040 is an appropriate date in the future to plan for? If not, what would be a more appropriate date and why? 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. Therefore, a plan period to 2040 is considered appropriate, 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 - 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 In line with the objectives and provisions of the Climate Change Act 2008, Paragraph 149 of the NPPF states 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 impacts to climate change. Impacts such as intense and frequent extreme weather events such as floods, heatwaves and droughts are likely to have an impact for Cambridge in particular. 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. Furthermore, we believe that our client’s sites can help address the four big themes and it is considered that the three sites previously promoted through the Call for Sites exercise reflect the themes and aims of the emerging Local Plan. Summary of Comments: We support the key themes.

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Q24: How important do you think continuing economic growth is for the next Local Plan? Continuing economic growth is important for the next Local Plan, it is important the edges of the more sustainable settlements are well connected to provide varied employment sites at a range of scales to reflect this. The NPPF has a focus on sustainable development, in particular stating in paragraph 84 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”. My client’s site known as Land north-east of Villa Road, Histon is the exact type of site the NPPF is referring to; it is of a medium size, located adjacent to the settlement edge, and provides a site for employment space nearby to existing and proposed housing, adjacent to an existing employment site and could accommodate both small and medium sized local businesses. The guided busway runs along its northern boundary meaning it is will served by public transport. In order for the emerging Greater Cambridge Local Plan to be found ‘sound’ it must be consistent with the policies detailed in the NPPF; including paragraph 84 identified above and as such a site such as our clients should be included. It is predicted that Cambridge’s economy will grow by approximately 20% over the next decade and employment levels will also grow by approximately 23.9%. The Greater Cambridgeshire’s aspirations are for even higher levels of employment growth. The city currently benefits from its employment parks, reputation and transport connections to London. With the Government’s focus on the East – West Rail link and the Oxford to Cambridge expressway, investment is required along these routes to ensure the continued economic growth throughout the next plan period. Furthermore, the Greater Cambridgeshire’s strategic plan recognises the importance to the AgricTech sector to the local economy and reputation, the further growth of this sector which our client falls within is strongly encouraged. It is important to ensure this growth is planned for within the new Local Plan in order to ensure Cambridge City and South Cambridgeshire District are kept an attractive place for people to work and live. Summary of Comments: Continuing economic growth is very important for the next local plan.

Q25: What kind of business and industrial space do you think is most needed in the area? A range of both business and industrial space is needed within the area, including distribution, start-up business and AgriTech business space. Business space that would provide for smaller start-up businesses should be allowed for within and on the edge of the surrounding towns and villages in the district. These sites would allow for the flexibility that start-up/growing businesses need with good connectivity into Cambridge City. The opportunity provided by small start-up space allows businesses to invest and expand over time, which will create additional employment opportunities and growth within the District. Our client’s site, Land north-east of Villa Road, Impington is located an optimal distance from Cambridge and could provide crucial business space in a sustainable out of city location. The site also benefits from its location on the edge of Histon and Impington, in a location within close proximity of a potential new bus stop along the guided busway, promoted as part of the emerging Neighbourhood Plan. Furthermore, the AgriTech sector is growing at a significant pace within the Cambridgeshire area. The appropriate building space and agricultural land needs to be allocated to progress this growth and ensure its development continues to move forward. With the UK facing food security issues and a future sustainability crisis due to Climate Change, it is important that the appropriate sites are allocated for AgriTech businesses to tackle these issues and address one of the big themes of the new Local Plan. AgriTech businesses require sites that are on larger rural outer city locations in comparison to the traditional employment sites located in and around Cambridge. The development and enhancement of the AgriTech industry will in turn support Cambridge’s existing and established high tech industry, resulting in economic benefits for both South Cambridgeshire and the City. Summary of Comments: Business space for start up, AgriTech and HighTech industries is most needed in the area. Allocations for AgriTech sites is important.