Greater Cambridge Local Plan Issues & Options 2020

Q28: In providing for a range of employment space, are there particular locations we should be focussing on? Are there specific locations important for different types of business or industry? It is important that employment is dispersed within the Greater Cambridge area, with not all employment just focused on Cambridge. The potential of land in rural areas beyond existent settlements has to provide land for employment development is recognised in the NPPF at Paragraph 84; “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.” Provision for the allocation of employment sites on land adjoining the rural centres and larger villages is appropriate and will help support both the economy of the district and the rural community. This is in line with the NPPF’s aims of supporting a prosperous rural economy. In addition, it is also appropriate to focus a proportionate quantum of employment growth along key transport corridors. As expressed within our answer to Question 25, the AgriTech sector is growing at a significant pace within the Cambridgeshire area. These businesses require employment sites that are on larger outer city sites that are generally more rural in comparison to traditional employment sites located in and around Cambridge. Sites, such as the Land north-east of Villa Road, Histon, submitted by my client as part of the Call for Sites exercise in March 2019 are considered to be appropriate for allocation. In order to enable such sites to come forward and support the growth of the expanding AgriTech industry in Cambridgeshire, the Council will need to amend the boundary of the Green Belt. The preparation of the new Local Plan represents an opportunity to review this boundary in accordance with Paragraph 136 of the NPPF which states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation and updating of plans. The allocation of my client’s site would attract either AgriTech or high-tech firms to the area to complement the established firms that are located within Vision Park and NIAB’s crop research facilities at Park Farm. This would help to boost the local economy by attracting these firms to the area and create job opportunities. Summary of Comments: Employment space should be dispersed within the Local Plan area and in particular should focus on rural edge of settlement locations.

Yes, strongly agree

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? Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and it is therefore important that a sufficient amount and variety of land comes forward where it is needed. As such, planning policies are required to identify a supply of specific, deliverable sites for the first 5 years of the plan period and specific, developable sites (or locations for growth) for the next 5 – 10 years. Paragraph 68 recognises the important contribution that small and medium sized sites can make to meeting the housing requirement of an area as they can be built out relatively quickly. Neighbourhood Planning groups are encouraged to allocate small and medium sized sites suitable for housing in their area. The emerging Histon and Impington Neighbourhood Plan while unable to allocate sites because of the existing Green Belt constraints, is supporting development schemes of 50 units or less in recognition of the need for additional housing and in particular affordable homes to meet local needs. In order to ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. 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 is not significantly below the target is still falling short. The question asks whether or not the Greater Cambridge Shared Planning Service should plan for a higher number of homes than the minimum required by government to provide flexibility and 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 Local Plan acknwoledges, the Cambridgeshire & Peterborough Independent Economic Review (CPIER) ‘showed that our recent growth has been faster than expected, and that growth is likely to continue. As a result, demand for new housing in this area has been exceptionally high and housebuilding has not kept up'. 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'. 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 agree 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'.

Q37: How should we encourage a shift away from car use and towards more sustainable modes of transport such as public transport, cycling and walking? As reflected in the NPPF (2019) and the Planning Inspectors report on the South Cambridgeshire Local Plan (2018), a shift away from our reliance on cars and towards more sustainable transport can be achieved by locating development in existing villages, with established transport connections. The development of new, large settlements is less likely to be able to be served by existing transport networks, whereas existing villages have established services and transport links which can serve an increased population. Histon and Impington is on the Cambridge Busway and as such is located along a key public transport link into Cambridge, and also nearby towns of St Ives and Huntingdon within Huntingdonshire District. The Busway provides a service every 7 minutes, providing residents and employees with a reliable and sustainable option for travel. A potential new stop on the busway is currently being considered within Histon and Impington, within close proximity to land owned by our client, this is supported by the emerging Neighbourhood Plan and would further encourage a shift away from car use, towards more sustainable modes of transport for both existing and future employees and residents. The release of my client’s site known as Land west of South Road, Impington from the Green Belt would facilitate the creation of a cycleway/footway that could link into the Darwin Green development to the south, on the opposite side of the A14. It is proposed that as part of any development of the site, of any size, a cycleway/footway route connecting Histon and Impington to Cambridge to the south would be incorporated and provide an improved linkage over the A14 and directly to the existing cycle and pedestrian links within Cambridge. This would further encourage a shift away from car use and towards more sustainable modes of transport. The encouragement of the use of public transport, cycling and walking in and around the South Cambridgeshire District and City of Cambridge would assist in addressing a key and fundamental issue, congestion. New development should aim to address this problem which would also be compliant with the key issue of Climate Change, a big theme underlying the new Local Plan. Summary of Comments: The spatial strategy will need to recognise the different opportunities available between urban and rural areas.

No choices made

Q42: Where should we site new development? Rank the options 1-6 – Most Preferred 6 – Least Preferred) 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 relating to creating an inclusive society where economic growth works for everyone'. We consider that new development should be located strategically within the District, on sites that are considered to be both sustainable and suitable. Therefore, we feel that these options should not be ranked by those most and least preferred and should be considered on the basis of their location and sustainability merits. Fundamentally, new development should aim to address problems within the South Cambridgeshire and Cambridge City areas, such as reducing congestion and traffic within and around Cambridge City Centre. 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 Inspectors’ Report on the Examination of the South Cambridgeshire Local Plan (August 2018) noted at paragraph 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 sized 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 paragraph 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 Inspector 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 (Paragraph 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

Response to Question 7 Q7: How do you think we should prioritise these big themes? Rank the options 1-4 (1 - Most Preferred 4 – Least Preferred) Further to the above, whilst Climate Change is clearly the most important theme, we believe that all four of 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 to delivering sustainable development. 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 all of the key themes equally.