Greater Cambridge Local Plan Issues & Options 2020

Agree

1.3 Our client agrees with the proposed big themes and believes that these can be achieved in part by focusing future housing growth in the most sustainable rural settlements in the Greater Cambridge area, especially those near to Cambridge. These higher order settlements contain a range of services and facilities are well served by public transport and are within cycling distance of Cambridge. Our client’s sites at Comberton, which is a Minor Rural Centre, offer the opportunity to further develop an enclosed parcel of land that will deliver much needed new homes in this sustainable location. These sites perform well against the big themes for the emerging Local Plan as demonstrated below: Climate change: Whilst modern building regulations are increasing the sustainability of new dwellings it is the impact of residents’ travel that needs to be addressed when considering where to locate new homes. Bennell Farm is within walking distance of the services and facilities of Comberton and within cycling distance of the employment and recreational areas of Cambridge. Therefore, the site’s location will ensure that residents’ reliance on the use of the private car will be reduced. This reduction on car dependency will also help reduce the negative impacts that unsustainable modes of travel have on climate change through increased greenhouse gas emissions. Wellbeing and Social Inclusion: As with the approved development the additional sites at Bennell Farm will offer a range of housing types, including different affordable housing tenures. This mix of household sizes and tenures will result in a balanced community. Moreover, the layout of the site offers residents the opportunity to interact with each other when enjoying the green spaces and play area to the south of the site. Through the promotion of walking, cycling and public transport residents will experience more positive interactions with each other and other residents of Comberton and beyond than if they were reliant on private cars to meet their daily needs. Biodiversity and Green Spaces: As with the approved scheme the proposed extensions to the Bennell Farm scheme will aim to achieve a net gain in biodiversity through the retention, protection and enhancement of on-site habitats, provision of extensive new public open space and high-quality landscaped areas. Existing boundary landscaping will be retained and enhanced with new planting to further add to the visual amenity of the area and create additional habitats for wildlife. Surface water attention features will be landscaped to create additional habitats that will have a positive impact on the biodiversity of the area. Great Places: The approved development at Bennell Farm has successfully interpreted the existing vernacular of the village and will create a new neighbourhood for Comberton that has place-making at its heart. Comberton is a popular village within the district, which is in part due to the success of the village college that includes modern sporting facilities that are available for use by both students and residents. The proximity of the site to the village college means that residents will benefit from a range of sporting and social facilities on their doorsteps, all of which can be reached without the use of the private car.

1.4 The Greater Cambridge area is consistently ranked as one of the best places to live in the UK with a strong economy that continues to outperform other cities. As a result of the continued job creation in the area Greater Cambridge experiences high levels of in-commuting due to years of persistent under-delivery of new homes. This has resulted in the city and surrounding villages becoming increasing unaffordable for people employed in the area and those who have grown up here. 1.5 The limitations to the existing rail network serving the city means that those who in-commute are increasingly reliant on private modes of transport that are predominantly powered by carbon-based fuels. The increasing number of these vehicles travelling through Cambridge and the outlying villages is creating environmental impacts at both the local and global level. Even with the promotion of electric vehicles, which rely on electricity from a heavily carbon-based national grid, the need to travel into the area will only be reduced once the supply of new homes increases in line with new jobs. 1.6 The key for the Greater Cambridge Local Plan is to plan positively for housing growth in areas where residents will have access to existing services and facilities and sustainable travel options to access employment and education whilst minimising the impact on local landscapes. Public transport is a good alternative to the private car but in many areas the service is not convenient enough for all residents. Therefore, by promoting sites that are within cycling distance of Cambridge, such as Bennell Farm, residents will have greater control over their own travel and can choose sustainable modes to meet their daily needs

1.7 Studies have shown that people experience greater social interactions through use of sustainable modes of travel, particularly walking and cycling, than when using private cars. The delivery of sites where people can walk and cycle to meet their daily needs also helps residents to establish lifestyles that benefit their physical and social health. Therefore, when allocating sites for new homes priority should be given to sites near to the services and facilities of higher order settlements, like Comberton, where residents will have greater opportunities to walk, cycle and use public transport to meet their daily needs. 1.8 The Councils’ own Issues and Options document acknowledges that Cambridge is one of the most unequal cities in the UK. This view is supported by the Cities Outlook 2019 Report, produced by Centre for Cities, that ranks Cambridge as having the 3rd highest housing affordability ratio (based on average house prices to average wage) in Great Britain. 1.9 Inevitably it is the lowest earning people employed in the Greater Cambridge area, or who have grown up here, that are unable to afford to live in the area. These people have no other option than to live in the surrounding areas and commute into the area. To counter this trend, ‘good growth’ needs to focus the delivery of new homes in the most sustainable locations within the Greater Cambridge area near to jobs so that residents have the option to choose sustainable modes of travel. This ‘good growth’ also needs to ensure the delivery of affordable housing in these same sustainable locations to meet the growing number of people on the Councils’ housing lists. 1.10 The delivery of sites that don’t achieve the Councils’ targets for affordable housing do little address this imbalance. The amount of infrastructure needed to deliver strategic sites like Northstowe, Cambourne West, Waterbeach and Bourn Airfield means that the percentage of affordable housing they deliver is inevitably reduced. Therefore, ‘good growth’ involves delivering a range of different scale of development sites with a focus on maximising the use of existing social and transport infrastructure. 1.11 Our client’s approved site at Bennell Farm has delivered 40% affordable housing as it is a greenfield site that is on the edge of a well-developed existing settlements with only minimal improvements needed to the existing infrastructure. The additional sites that will in effect extend the approved site will benefit from these infrastructure improvements and as such they will be able to deliver a policy compliant level of affordable housing. 1.12 Comberton presently has good cycle infrastructure for those travelling in the direction of Cambridge, though there are areas where it could be improved. The Greater Cambridge Partnership’s proposed greenway to serve the village will further enhance this route making it more attractive for new and existing residents to use.

1.13 Our increasingly sedentary lifestyles are compounded by the fact that many people spend large parts of their day travelling to work, principally in private motor vehicles, due to the fact that they cannot afford to live near their places of work. This daily commute can have long term physical and mental health issues especially when travel patterns get interrupted by infrastructure works such those seen recently with the A14 upgrade. With further infrastructure planned for the Greater Cambridge area there is an urgent requirement for the new homes to meet the immediate needs of the area to be built in locations where sustainable modes of travel can easily be used to access the places of employment in and around the city. 1.14 The Greater Cambridge area’s present overreliance on new settlements and urban extensions means that new homes take longer to come forward and sustainable travel options are not always in place when new residents move in. Our client’s sites at Bennell Farm can be delivered quickly and will allow new residents the opportunity to access local services and facilities by foot or cycle rather than having to rely on the private car. The proximity of the site to the sporting and leisure facilities at Comberton Village College also means that residents will have these facilities on their doorsteps to enable them to adopt healthy lifestyles. 1.15 The Greater Cambridge Partnership’s planned enhancements to the cycle route between Comberton and Cambridge as part of their greenways project will further encourage new and existing residents to cycle in order to access the services, facilities and employment opportunities of Cambridge and beyond.

1.16 Where development is located within or on the edge of existing settlements it is important that is pays attention to the local vernacular so as to best integrate new homes into the existing urban grain of the settlement. 1.17 Our client’s existing site at Bennell Farm has successfully interpreted the vernacular of Comberton and ensures that streets and public open space are well overlooked by new homes. The development of land to the west and north of the approved development will build on the design themes of approved scheme and accommodate further homes in this well screened site in a sustainable location on the edge of the Minor Rural Centre village of Comberton. 1.18 Notwithstanding the above, the introduction of arbitrary design standards has the potential to delay the delivery of sites. Whilst the District Council’s Design Guide SPD 2010 is a useful starting point for considering design matters it is now a decade old and does not reflect the policies of the adopted Local Plan. Any successor document to this SPD should clearly identify that the recommendations within it are for guidance only and are not planning policy requirements. Whilst design matters are important there are often other material considerations, such as viability, that need to be taken into account when assessing planning applications. Design guidance that is applied too rigidly without identifiable outcomes can have negative impacts upon the timing and delivery of new developments.

1.19 If the Councils do not plan for enough homes for the Greater Cambridge area this will worsen the existing affordability issues, limit the benefit that the area has for the local and national economy, damage social inclusion, and have implications for climate change as people travel further to access jobs. 1.20 The adopted strategy of large new settlements and urban extensions takes years to deliver and whilst they deliver new housing they have consistently under-delivered on affordable housing due to the significant infrastructure needed to develop the sites. This isn’t just the case with brownfield sites like Northstowe and Wing. Large greenfield sites like Cambourne West also under-delivered on affordable housing with only 30% and a tenure split that did not accord with the District Council’s affordable housing SPD. 1.21 The Councils should look to maximise the use of land in existing sustainable locations, rather than new locations that need significant infrastructure to make them sustainable. The expansion of existing development sites, or the development of land on the edges of the more sustainable rural settlements, will maximise the use of existing social and transport infrastructure and minimise disruption to existing communities. 1.22 Development frameworks are a negative planning tool that are too rigidly enforced without officers being given the ability to use their sound planning judgement. A relaxation of development frameworks would allow for a large number of new homes to come through as windfall sites. If priority were given to self-build plots on the edge of villages, where all other material planning considerations could be satisfied, then this would also help the Councils to address their statutory obligation to deliver self-build plots in the Greater Cambridge area. 1.23 There should be a greater focus on small and medium size developments on the edges of the District’s more sustainable rural settlements that can be build out quickly and where residents are more easily integrated into existing communities. Our client’s sites at Bennell Farm offer one such opportunity to deliver new homes in this sustainable location with a policy compliant level of affordable housing.

Yes, strongly agree

1.24 Our client strongly agrees that the Councils should plan for a higher number of homes than the minimum required by Government. Whilst Paragraph 60 of the National Planning Policy Framework (NPPF) identifies the use of the Government’s standard method for assessing local housing need it also acknowledges that an alternative approach can be justified in exceptional circumstances based on demographic trends and market signals. 1.25 The Greater Cambridge area has enjoyed years of strong economic growth alongside a persistent under-delivery of new homes. This has resulted in significant issues with affordability of housing in the city and surrounding villages. Therefore, it is essential that the Councils’ future housing targets seek to address both the future growth aspirations of the Greater Cambridge area and the acute affordability issues that it presently suffers from. 1.26 The Issues and Options document clearly identifies a level of economic growth that will further increase the historical imbalance between the delivery of new homes and jobs in the area. Therefore, our client strongly believes that the predicted economic growth in the area justifies the Greater Cambridge Local Plan planning for a level of housing growth in excess of the figures identified by using the Government’s standard method. This approach would be entirely in accordance with paragraph 60 of the NPPF. 1.27 Should housing needs continue to be constrained by the Councils seeking a delivery target based on the standard method alone, without taking into account other material considerations that are unique to the Cambridge area, then the proposed big themes of the Local Plan will never be achieved. The economy of Cambridge is too important both nationally and globally to plan for the minimum number of homes and the Councils will need to be more flexible in the approach they adopt for calculating future housing needs. 1.28 It is evident that the Greater Cambridge area has been providing insufficient housing over successive plan periods and therefore a substantial uplift in the level of housing growth is necessary to redress the imbalance between new homes and jobs that has resulted in a housing market where affordability has worsened significantly over the last 10 years. 1.29 The implications of a failure to positively plan for the bespoke housing needs of the Greater Cambridge area will be that existing residents will continue to suffer the negative impacts of the widescale daily in-commuting of workers from outside the area. This in-commuting will continue to have wider environmental and health implications that impact negatively on the quality of life of residents of the villages of South Cambridgeshire in particular. 1.30 In accordance with the requirements of the NPPF any housing targets, whether they be for the Greater Cambridge area or individual allocations, should be clearly identified as minimum figures in order to stimulate positive growth. This would also accord with paragraph 59 of the NPPF that requires Councils to boost the supply of housing.

1.31 Whilst there is a statutory requirement to provide self-build plots there should be more of a criteria based approach for when they are required with development viability being a material consideration. This is especially the case for larger sites where the costs of delivering infrastructure often impact negatively on the percentage of affordable housing that is delivered. A requirement for self-build plots, which generate less revenue for developers than finished homes, has the potential to further reduce the level of affordable housing on these large sites. It seems perverse that the needs of people with the financial means to build their own homes could be prioritised over low earning residents who cannot afford to buy or rent homes in the Greater Cambridge area. 1.32 Our client is concerned that the need for self-build plots can be often be overstated by self-build registers. In particular, many registers are rarely updated to remove those no longer in need of a self-build plot or to assess whether there is double counting across registers. Given the attractiveness of the Greater Cambridge area there is also the concern that the self-build register has been inflated by people with aspirations to live in the area, meaning that there is an artificially high number of people on the registers compared to neighbouring authorities. 1.33 With the above in mind, it will be important for the Councils to ensure that their evidence on the need for self-build homes has been effectively reviewed if it is to offer a robust position on the demand for this type of development. Whilst South Cambridgeshire is a vanguard for self-build housing Cambridge City has not been as proactive towards promoting its self-build register. This may also have artificially inflated the number of people on South Cambridgeshire’s register. 1.34 Rather than targeting major developments it is suggested that the Councils look at what opportunities exist to promote self-build plots on the edges of development frameworks. Especially where the development of small sites and residential gardens would not result in wider harm. By including self-build plots in the criteria for a bespoke policy that permits the development of sites on the edges of development frameworks it would help to boost the supply of housing, address the Councils’ self-build registers and provide a continued source of employment for small builders and tradespeople. 1.35 The Councils should not adopt overly restrictive policies that require a precise mix of housing to be provided on all sites. The reliance on the Strategic Housing Market Assessment (SHMA) for a plan period of several decades does not give officers the flexibility to take into account other material planning considerations that may make alternative housing mixes more appropriate for specific sites. Therefore, the SHMA figures should be used as a guide only for the mix of housing on sites rather than a requirement. Any new policy should allow officers the flexibility to take into account other material considerations when considering planning applications, especially as they would be used the assess the needs of developments in both urban and rural settings.

1.36 The Government is already implementing significant increases in building regulations standards at a national level and our client believes that national standards rather than local ones are more appropriate. Moreover, where councils have specific standards for energy efficiency, accessibility and adaptability it can have a negative impact on affordability. This is especially important for an area like Greater Cambridge where affordability issues are already entrenched. 1.37 The Councils will need to ensure that they provide the necessary evidence, as set out in the National Planning Policy Guidance, on the need for any increased percentage of adaptable homes and the impact on development viability of such a requirement if it is to be included as a policy in the emerging Local Plan.

1.38 Within the District’s higher order rural settlements there is already capacity to accommodate growth, or capacity can be secured through the enhancement of existing services and facilities. One of the most important pieces of infrastructure, which is often overlooked, is social infrastructure. That is why the Councils need to focus growth on the most sustainable rural settlements where new residents can benefit from established social infrastructure. Our client’s approved scheme at Comberton demonstrates how new homes can successfully be integrated into an existing community where the new residents will benefit from existing infrastructure. 1.39 Notwithstanding the above, Comberton will soon benefits from enhanced cycle connectivity with Cambridge as a result of the Greater Cambridge Partnership’s greenways projects. The proposed east west rail route is also likely to result in a new station at Cambourne, which would give new residents alternatives to travelling into Cambridge to access rail services. 1.40 The adopted strategy that focuses on new settlements and urban extensions can bring substantial improvements to local infrastructure. However, these take time to deliver and these sites should not come forward at the expense of smaller or medium sized development sites. Developments like Bennell Farm provide financial support for local infrastructure and bring increased use of local services that can be at risk from closure