Greater Cambridge Local Plan Issues & Options 2020

Nothing chosen

Yes. Paragraph 60 of the National Planning Policy Framework (NPPF) outlines that strategic policies should be informed by local housing needs, using the Government’s standard method unless exceptional circumstances for an alternative approach can be justified which reflect current and future demographic trends and market signals. The evidence and explanation provided at page 61 and 62 of the Issues and Options document, regarding the scale of the future economic growth in area, justifies and indeed necessitates the need for the Greater Cambridge Local Plan (GCLP) to plan for housing growth in excess of the Government’s standard method figures. This would be entirely in accordance with paragraph 60 of the NPPF. Indicative calculations from the Cambridgeshire and Peterborough Independent Economic Review (CPIER), are that around 2,900 homes a year would need to be built in Greater Cambridge, creating an indicative total of 66,700 homes over 2017-2040. This compares with the adopted 2018 Local Plans target of 1,675 homes per year, and 1,800 homes per year to meet local needs using the Government’s standard method. Based on the CPIER 66,700 housing need figure the Issues and Options document states that the Local Plan will need to allocate housing sites capable of delivering an additional 30,000 dwellings over and above the sites already in the pipeline to be built out between 2017-2040. Given the early stage of the plan preparation and the need for further technical work and analysis regarding economic growth and housing need it is recommended that the additional 30,000 dwelling figure, based on the CPIER findings, is viewed as a minimum by the Councils. Indeed, the NPPF itself requires housing targets to be viewed as minimum figures in order to stimulate positive growth. The Councils will need to adopt a flexible approach to setting the increased housing target to ensure that available land is used efficiently to meet the economic and housing needs of the area. By planning proactively for increased rates of housing the GCLP will support and stimulate the anticipated economic growth and job creation in the area and in turn support the growth of the Cambridge area as it becomes a global leader in innovation. Preparing the GCLP on the basis of an enhanced figure to address economic growth is entirely justified given the context provided by the Cambridgeshire and Peterborough devolution deal, which aims to double economic output in the 25 years, and the continued high rate of job creation in Cambridge. Having established the principle and need to deliver a rate of housing growth above that set out by the Government’s figures, the Councils will now need to prepare and publish the evidence base to support the increased housing target for Greater Cambridge. This should be published as part of the next GCLP consultation; alongside a SHLAA review of the housing sites put forward by developers, land promoters and landowners. In our assessment, based on the information available and content of the Issues and Option document, it is strongly recommended that the GCLP plans for an increased housing need figure. This will support economic growth, reduce inequality, increase affordability levels and promote wellbeing through the delivery of additional market and affordable housing in sustainable locations. Even at this early stage of the plan preparation process it is evident that exceptional circumstances exist in this instance to justify increased housing delivery in accordance with paragraph 60 of the NPPF. It is inevitable that there will also be a need to undertake a Green Belt review as a result of these same exceptional circumstances.

As required by the NPPF paragraph 61, market, affordable, and specialist (student, older persons') housing is required to be provided to create a mixed and balanced community. In terms of market housing and starter homes, the Council's Housing Statistical Information Leaflet (December 2018) only notes a need for traditional types of affordable housing, based on information from its housing register. For Dry Drayton, where our client is promoting a site for up to 30 dwellings, it is notable that the affordable stock in the Parish includes no 1-bed houses and only one 2-bed house for those under 60. There are 17 3-bed houses and 1 4-bed, plus 12 bungalows for people over 60. Housing association stock comprises 2 houses (one 2-bed and one 3-bed). There is no shared equity housing and no sheltered accommodation. The stated need for Council and RP rented accommodation was two 1-bed and two 3-bed houses. The Council has not measured the need for starter homes: rent to buy or low cost home ownership, and there is likely to be a hidden need for both market and affordable housing relating to newly formed households. Over time, we anticipate that housing needs surveys will widen to include assessment of needs for the types and wider tenures and housing referred to in the NPPF. Even then, that snapshot of need will be only part of the evidence to be weighed in consideration of the design of a housing scheme on a particular site. In Parishes across Greater Cambridge, the type of market housing that should be provided should address market demand as well as need, and in different locations, the type of housing that will ensure a development site will be viable and attractive to developers will differ by site. It is therefore counterproductive to dictate a market housing mix . Therefore the type of market housing that should be provided should be subject to flexibility, rather than dictating arbitrary mixes for all development schemes.

How should we encourage a shift away from car use and towards more sustainable modes of transport such as public transport, cycling and walking? Paragraph 78 of the NPPF states that "to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." For example, land at Park Street, Dry Drayton, which we are promoting for allocation, would provide additional population to support the existing bus service through the village, contributing to its viablility and longevity. In this regard, the allocation of the site would benefit the whole community in terms of the availability of alternative transport modes. Additionally, the increased population would result in the support of services and facilities within the village, such as the village hall, school and pub which, along with the proposed public open space, will reduce some of the need to travel by whole community.

Yes

Paragraph 136 of the National Planning Policy Framework (NPPF) confirms that Green Belt boundaries should only be altered where exceptional circumstances can be demonstrated as part of the preparation of a Local Plan. Exceptional circumstances are present which would justify the Councils undertaking a review of the Cambridge Green Belt in the preparation of the Plan, in the context of the challenges and opportunities facing the area in respect of delivering housing and employment growth. These challenges and opportunities relate to the significant growth and investment anticipated and committed in the Greater Cambridge area. The exceptional circumstances are set out in the Issues and Options document it is estimated that an additional 30,000 new homes, above the Government’s standard method, will be required to support the economic growth of the area. This growth is driven and supported by the following initiatives: - The Cambridge and Peterborough Combined Authority (CPCA) have confirmed that due the high levels of growth and ‘exceptional’ housing market conditions in Greater Cambridge, the Government will provide £100m housing and infrastructure fund to help deliver infrastructure for housing and growth and at least 2,000 affordable homes. - The CPCA have confirmed that Central Government are to provide an additional £70m ring fenced for Cambridge to help meet the ‘exceptional’ housing needs of the city. - The CPCA anticipate that economic output will increase by 100% over the next 25 years. The GVA of the area is estimated to increase from £22bn to over £40bn. - Cambridge City and South Cambridgeshire anchors the eastern end of the Oxford-Cambridge Arc as defined by Central Government in March 2019. The Government have stated that the Arc area is an economic asset of international standing and can be influential to the performance of the national economy. The National Infrastructure Committee (NIC) found the Arc area to be home to UK’s most productive and fast-growing cities and has significant potential for transformative Growth. However, the growth and opportunity in this area is currently constrained by poor east-west infrastructure and a lack suitable housing. The Arc initiative aims to realise the full economic potential of the area by delivering significant new infrastructure and building up to 1 million new homes by 2050. - Cambridge and South Cambridgeshire also form part of the London-Stansted-Cambridge growth corridor, and the Cambridge-Norwich growth corridor. - Indicative calculations from the Cambridgeshire and Peterborough Independent Economic Review (CPIER), are that around 2,900 homes a year would need to be built in Greater Cambridge, creating an indicative total of 66,700 homes over 2017-2040. This compares with the adopted 2018 Local Plans target of 1,675 homes per year, and 1,800 homes per year to meet local needs using the Government’s standard method. Based on the CPIER 66,700 housing need figure the Issues and Options document states that the Local Plan will need to allocate housing sites capable of delivering an additional 30,000 dwellings over and above the sites already in the pipeline to be built out between 2017-2040. Against this backdrop of growth, it will be important to assess the most appropriate locations for addiitonal development, likely to be through a combination of spatial strategy appraoches due to the sheer number of dwellings required. This level of growth represents the exceptional circumstances that justify and indeed necessitate a Green Belt review. There are opportunties to remove from the Green Belt land which does not contribute to its established purposes (as set out in paragraph 2.30 of the current SCDC Local Plan). Green Belt designations are historical and in many cases appear to arbitrarily follow the village framework boundaries. Green Belt boundaries only appear to have been considered for removal on very large development sites, but some smaller locations do not fulfill the purposes of the wider Cambridge Green Belt designation, namely to: • Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre; • Maintain and enhance the quality of its setting; and • Prevent communities in the environs of Cambridge from merging into one another and with the city. There should be a comprehensive review of the outer edge, village edges and inner edges of the Green Belt boundaries, and there does not appear to be such a review in the evidence base documents. NPPF paragraph 139 states that plans should "not include land which it is unnecessary to keep permanently open." Land at Park Street, Dry Drayton is one such site that does not comply with the purposes of the Cambridge Green belt's designation. The Site Promotion Document for the site (submitted at the Call for Sites stage) sets out in greater detail why the allocation of that site and its removal from the Green Belt would be appropriate in this context.

Highly flexible

NPPF paragraph 78 which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. In the context of the requirement for the delivery of significant number of homes over the plan period, the spatial distribution of housing and employment is a serious challenge for the Plan. In previous Plans the Council (SCDC) has relied upon a strategy for villages involving tightly drawn village boundaries. This has had the effect of stifling sustainable development that would otherwise be acceptable in terms of development management policies, as evidenced by the granting of planning permission at local and appeal level during the period when the Council was unable to deminstrate a 5-year supply of housing land, thereby invoking the tilted balance. Those planning permissions were for scheme sizes greater than the numbers in the relevant policies, e.g. 8 units for group villages and have not resulted in overall harm to those villages. The Plan needs to balance the wider spatial strategy in light of the need for significant housing provision. This should acknowledge that windfall sites make a valuable contribution to housing supply and are not necessarily always located within the defined boundaries of villages. Cramming villages with increasing densities of development threatens their very rural nature, whereas development on the edges of villages can retain their character. Such developments are able to be delivered more quickly than major sites and brownfield sites. Additionally, this is acknowledged by paragraph 68.a) of the NPPF, which also requires that 10% of the housing requirement should be accommodated on sites less than 1ha in area. Some such sites are too small to be considered for allocation since they can accommodate fewer than the minimum 5 homes, meaning that opportunities for small windfall developments are extremely limited. The Plan should inlcude a criteria based policy that positively acknowledges that sites of varying sizes (not just 5 or fewer) on the edges of settlements will inevitably come forward and be sustainable and acceptable, whilst not undermining the wider spatial strategy. A criteria-based policy would ensure compliance with NPPF paragraph 78. Land at Park Street, Dry Drayton is one such location on the edge of a village, promoted by our clients for 30 dwellings. The Site Promotion Document submitted at the Call for Sites stage demonstrates that development on the edge of the village can be accommodated well in terms of the surrounding landscape, the wider spatial strategy and in contributing to the vitality of the village community by supporting the school population, bus service, facilities etc.

Nothing chosen

NPPF paragraph 59 reminds of the Government's objective of significantly boosting the supply of homes. Paragraph 117 requires planning policies and decisions to promote effective use of land while safeguarding and improving the environment and ensuring safe and healthy living conditions. Setting arbitrary numerical limits on development would be contrary to this national policy. Instead, the appropriate number of dwellings on any site would be established throught the application of criteria-based policies that achieve the safeguarding requirements of paragraph 117. The same should apply to sites on the edges of settlements.

Densification has its place. However, density is often defined in numerical terms rather than character. Thus 4 flats or 4 large family homes on the same sized site will have a different impact on the density character of the site, despite being the same density numerically. Policies should therefore refer to consideration of the impact on character and appearance, amenity and highway safety rather than arbitrary numbers. Cramming villages with increasing densities of development threatens their rural nature, whereas development on the edges of villages can retain that village's character. Such developments are also able to be delivered quickly. A criteria-based policy involving judgement on matters of planning merit (rather than a tick-box exercise) would ensure compliance with NPPF paragraph 78 which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. It would also comply with the requirement of NPPF paragraph 117 regarding the effective use of land. Paragraph 188.a) of the NPPF states that planning policies and decisions should encourage multiple benefits from both urban and rural land, including through mixed use schemes and taking opportunities to achieve net environmental gains – such as developments that would enable new habitat creation or improve public access to the countryside. Land at Park Street, Dry Drayton is one such location on the edge of a village, promoted by our clients for 30 dwellings. The Site Promotion Document submitted at the Call for Sites stage demonstrates that development on the edge of the village can be accommodated well in terms of the surrounding landscape, the wider spatial strategy and in contributing to the vitality of the village community by supporting the school population, bus service, facilities, etc. In particular the site is promoted with the inclusion of new public open space which is currently lacking in the village, and landscaping and ecological enhancements, facilitiating much needed net environmental gains as advoctaed by paragraph 118.a).

Paragraph 136 of the National Planning Policy Framework (NPPF) confirms that Green Belt boundaries should only be altered where exceptional circumstances can be demonstrated as part of the preparation of a Local Plan. Exceptional circumstances are present, which would justify the Councils undertaking a review of the Cambridge Green Belt in the preparation of the Plan, in the context of the challenges and opportunities facing the area in respect of delivering housing and employment growth. These challenges and opportunities relate to the significant growth and investment anticipated and committed in the Greater Cambridge area. The exceptional circumstances are set out in the Issues and Options document it is estimated that an additional 30,000 new homes, above the Government’s standard method, will be required to support the economic growth of the area. This growth is driven and supported by the following initiatives: - The Cambridge and Peterborough Combined Authority (CPCA) have confirmed that due the high levels of growth and ‘exceptional’ housing market conditions in Greater Cambridge, the Government will provide £100m housing and infrastructure fund to help deliver infrastructure for housing and growth and at least 2,000 affordable homes. - The CPCA have confirmed that Central Government are to provide an additional £70m ring fenced for Cambridge to help meet the ‘exceptional’ housing needs of the city. - The CPCA anticipate that economic output will increase by 100% over the next 25 years. The GVA of the area is estimated to increase from £22bn to over £40bn. - Cambridge City and South Cambridgeshire anchors the eastern end of the Oxford-Cambridge Arc as defined by Central Government in March 2019. The Government have stated that the Arc area is an economic asset of international standing and can be influential to the performance of the national economy. The National Infrastructure Committee (NIC) found the Arc area to be home to UK’s most productive and fast-growing cities and has significant potential for transformative Growth. However, the growth and opportunity in this area is currently constrained by poor east-west infrastructure and a lack suitable housing. The Arc initiative aims to realise the full economic potential of the area by delivering significant new infrastructure and building up to 1 million new homes by 2050. - Cambridge and South Cambridgeshire also form part of the London-Stansted-Cambridge growth corridor, and the Cambridge-Norwich growth corridor. - Indicative calculations from the Cambridgeshire and Peterborough Independent Economic Review (CPIER), are that around 2,900 homes a year would need to be built in Greater Cambridge, creating an indicative total of 66,700 homes over 2017-2040. This compares with the adopted 2018 Local Plans target of 1,675 homes per year, and 1,800 homes per year to meet local needs using the Government’s standard method. Based on the CPIER 66,700 housing need figure the Issues and Options document states that the Local Plan will need to allocate housing sites capable of delivering an additional 30,000 dwellings over and above the sites already in the pipeline to be built out between 2017-2040. Against this backdrop of growth, it will be important to assess the most appropriate locations for additional development, likely to be through a combination of spatial strategy approaches due to the sheer number of dwellings required. This level of growth represents the exceptional circumstances that justify and indeed necessitate a Green Belt review. There are opportunities to remove from the Green Belt land which does not contribute to its established purposes (as set out in paragraph 2.30 of the current SCDC Local Plan). Green Belt designations are historical and in many cases appear to arbitrarily follow the village framework boundaries. Green Belt boundaries only appear to have been considered for removal on very large development sites, but some smaller locations do not fulfil the purposes of the wider Cambridge Green Belt designation, namely to: • Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre; • Maintain and enhance the quality of its setting; and • Prevent communities in the environs of Cambridge from merging into one another and with the city. There should be a comprehensive review of the outer edge, village edges and inner Green Belt boundaries, and there does not appear to be such a review in the evidence base documents. NPPF paragraph 139 states that plans should "not include land which it is unnecessary to keep permanently open." Land at Park Street, Dry Drayton is one such site that does not comply with the purposes of the Cambridge Green Belt's designation. The Site Promotion Document for the site (submitted at the Call for Sites stage) sets out in greater detail why the allocation of that site and its removal from the Green Belt would be appropriate in this context.

Greater Cambridge already relies on new settlements that are still at relatvely early stages of development. Whilst new settlements are one option, this should not be at the expense of smaller sites elsewhere in the hierarchy that can deliver homes more quickly. Sites at village level have an important role to play in supporting the vitality of the existing community. Paragraph 78 of the NPPF states that "to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." Land at Park Street, Dry Drayton would provide additional population to support, for example, the existing bus service through the village, contributing to its viablility and longevity. In this regard, the allocation of the site would benefit the whole community in terms of the availability of alternative transport modes. Additionally, the increased population would result in the support of services and facilities within the village, such as the village hall, school and pub which, along with the proposed public open space, will reduce some of the need to travel by whole community.

We have explained in our response to question 39 that there are exceptional circumstances to justify a review of the Green Belt, namely the evidential need for significant additional housing. It is inevitable that the growth of villages both within and outside the Green Belt will be a vital component of the spatial strategy. Village growth creates the positive opportunity to support the vitality of rural communities: Paragraph 78 of the NPPF states that "to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services." Land at Park Street, Dry Drayton would provide additional population to suport the school and the existing bus service through the village, contributing to their viablility and longevity, as well as public open space which is currently lacking. In this regard, the allocation of the site and associated increase in population would benefit the whole community in terms of the availability of alternative transport modes and the support of services and facilities within the village, such as the village hall, school and pub, along with the proposed public open space.