Greater Cambridge Local Plan Issues & Options 2020

Disagree

Please see attached Representation Report (page 4). Disagree. 2050 would be a more appropriate date. 3.3 The NPPF (paragraph 22) states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. 3.4 Table 5 of the consultation document sets out a timetable which envisages Local Plan adoption in Summer 2023. However, we are aware that many other authorities are experiencing significant delays in their local plan preparations. This often occurs during the Examination in Public (EiP) phases and is therefore essentially outside of a local planning authority’s control. Any significant slippage in the Greater Cambridge Local Plan timetable could compromise the ability of the Councils to deliver a Local Plan with a minimum 15-year period from adoption. On this basis, a plan period to 2050 would be more realistic. 3.5 In addition to this practical point on timescale, we also note that a plan period to 2050 would correspond with other strategic plans for the area and may provide a better timeframe for long-term strategic decisions.

Question 31: How should the Local Plan help to meet our needs for the amount and types of new h omes? 4.4 The Greater Cambridge Local Plan provides a key opportunity to readdress the balance between economic growth and housing delivery. In order to ensure choice, affordability and diversity, the Local Plan must make provision for a sufficient quantity of housing. It must also include a range of housing types and sizes, across a variety of sites and locations. This should include small and medium sites, in addition to strategic sites, to ensure the ongoing delivery of housing throughout the plan period. In accordance with the NPPF (paragraphs 67 and 68), strategic policy-making authorities should identify a sufficient supply and mix of sites over the local plan period. 4.5 Determining the appropriate amount of housing to deliver in Greater Cambridge during the plan period is a critically important role for the Local Plan. It is essential that there is an adequate rate of housing completions across the plan period, maintaining a continuous five-year housing land supply to support economic growth and job creation, social cohesion and sustainable lifestyles. To ensure that delivery is continuous and consistent, a number of small- and medium-sized sites must be progressed. The NLP study of largescale site delivery ( Start to Finish , November 2016) highlights that lead-in times for large sites is 3.9 years and the planning approval period for schemes of 2,000+ dwellings averages 6.1 years. The research showed that the planning approval period increases significantly for sites in excess of 500 units. An over-reliance on large sites such as those currently proposed at Waterbeach and Bourn Airfield which require significant infrastructure provision will therefore undermine delivery and exacerbate the housing issues that exist at present.

Yes, strongly agree

4.6 Yes, we strongly agree. 4.7 In accordance with the National Planning Policy Framework (NPPF), the starting point for deciding how many homes need to be planned for in the emerging Greater Cambridge Local Plan is a local housing need assessment, conducted using the ‘standard method’ unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals (NPPF, paragraph 60). 4.8 The standard methodology is set out in Planning Practice Guidance (PPG)( Housing and economic needs assessment ) and uses a formula to identify a minimum annual housing need figure, calculated by setting the baseline household growth projection and then adjusting it to take account of affordability and finally capping the level of any increase. The standard method does not produce a housing requirement figure and neither does it reflect economic growth requirements. 4.9 Compared with the adopted 2018 Local Plans’ combined target of 1,675 homes per year, the standard method calculation for Greater Cambridge indicates a minimum need of around 1,800 homes per year. This alone reflects a minimum of +17,950 new homes than is currently planned for between 2017 and 2040. 4.10 Reflecting paragraph 60 of the NPPF, PPG (paragraph 10) explains that, “The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.” 4.11 PPG includes reference to circumstances under which housing need should be higher than derived using the standard method, including growth strategies, strategic infrastructure improvements and authorities agreeing to take on unmet need for neighbouring authorities. 4.12 Greater Cambridge is strategically located within the key economic corridors of the Cambridge-Milton Keynes-Oxford (CAMKOX) arc, the London-Stanstead-Cambridge (M11) corridor and the Cambridge-Norwich (A11) tech corridor. 4.13 The National Infrastructure Commission (NIC) published a report into the CAMKOX arc in 2017 ( Partnering for Prosperity: A new deal for the Cambridge - Milton Keynes - Oxford Arc ). This recommended that the current housing delivery rates will need to double up to 2050 to realise the Arc’s economic potential. This level of growth would also require significant investment in new transport infrastructure, including East-West Rail and an Expressway connecting Cambridge and Oxford. 4.14 At the sub-regional level, the Cambridgeshire and Peterborough Combined Authority has ambitious growth strategies for the area, with the Greater Cambridge Partnership (GCP) tasked to deliver infrastructure and a City Deal including £500m funding. The Combined Authority established the Cambridgeshire and Peterborough Independent Economic Commission to develop an evidence base and inform policy decisions. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) was published in 2018 and it reported (page 9): “Growth in employment has not been matched by corresponding house-building, or developments in infrastructure. Consequently, house prices haves soared and journey times have increased as congestion has intensified. This has meant that many have been forced to endure unpleasant commutes, or been priced away from the city altogether due to the unaffordability of rents. This is bad for both people and business, and we believe is an unsustainable approach to growth.” 4.15 The CPIER provided some recommendations. With direct reference to housing requirements, Key Recommendation No. 5 states: “There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast by the EEFM. This review should take into account the continuing dialogues between ONS and the Centre for Business research on employment numbers as well as the impact of the Cambridge-Milton Keynes-Oxford Arc. This should be used to set new targets which are likely to be higher than those already set – at the very least adding on accumulating backlog.” 4.16 The CPIER indicates that housing supply across the whole area (the Combined Authority Area) should be in the range of 6,000-8,000 homes per year over the next 20 years. For the Greater Cambridge area this translates into a CPIER figure of around 2,900 homes per year, which results in an indicative total of 66,700 homes over the period 2017-2040. 4.17 Following the recommendations of the NIC report (2017) and the CPIER (2018), Hill and Chivers strongly agree with the approach of planning for a higher number of homes than the standard method minimum. In order to support the growing economy, and key national, strategic and sub-regional growth strategies, a step-change in housing delivery is needed in Greater Cambridge to ensure that growth is sustainable. 4.18 Hill and Chivers reserve the right to provide appropriate evidence to justify the objectively assessed housing need (OAN) and housing requirement figure through the Local Plan process, as considered necessary.

4.19 The NPPF sets out that, within the context of local housing needs assessments, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. This should include, but not be limited to those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes (NPPF, paragraph 61). 4.20 The Issues and Options consultation document identifies the need for affordable homes, including a balance of affordable tenure types (affordable rented, shared ownership and community-led housing)(page 63). It also highlights the need for “diverse housing for diverse communities” (page 64), covering flexible housing that is accessible and adaptable; housing for downsizing; specialist housing; student accommodation; shared accommodation; custom and self-build housing; built to rent (BTR) and local worker housing. 4.21 The kind of housing that should be provided in Greater Cambridge will need to be based on a clear and robust evidence of need as set out in a new Strategic Housing Market Assessment (SHMA). However, housing policies within the Local Plan should ensure a realistic element of flexibility, so that a diversity of provision can be made. This will also ensure that housing policies are future-proofed and can respond to changing market conditions as may arise during the plan period. 4.22 Hill and Chivers support the provision of a range of house sizes, types and tenures. It is important that new housing is delivered across a variety of site sizes, typologies and locations. Their Site at Hardwick offers the opportunity to deliver a mix of housing, meeting a range of needs and supporting the local community.

4.23 As set out in the NPPF, the creation of high-quality buildings and places is fundamental to what the planning and development process should achieve. Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities (NPPF, paragraph 124). 4.24 The Issues and Options consultation document questions whether the new Local Plan should maintain the National Space Standards, as applied within the 2018 Local Plans. It also questions whether there should be specific standards for energy efficiency, accessibility and adaptability and a range of other design issues. 4.25 Hill has a reputation for delivering high quality homes, incorporating good and innovative design and creating sustainable homes and communities. Hill has a strong vision to minimise the impact of development on the environment, with health, safety, energy and environmental goals that seek to reduce energy use, reduce water use and divert waste from landfill. 4.26 Hill homes are created with an awareness of residents’ wellbeing, designed to promote the use of sustainable travel through walking and cycling and also with social and recreational areas to enjoy the wider environment whilst also incorporating the highest standards of sustainable technology, supporting biodiversity and benefiting local ecology and wildlife. 4.27 Hill is an award-winning housebuilder, leading the way in introducing measures to improve the environmental performance of new residential developments in reducing carbon emissions, providing gains in biodiversity and improving green infrastructure and the wider environment. 4.28 At the national level, measures such as the Future Homes Standard and Biodiversity Gain are being implemented as new regulatory targets for residential development. The construction industry and their representative groups face a significant amount of research and development to ensure that the required standards can be adopted and implemented within the timeframes required. A national approach to achieving high quality design and improved environmental performance is considered preferable to local authorities setting their own standards. 4.29 If the Councils seek to adopt any of the optional technical standards in the Local Plan then they will need to ensure that they provide the necessary evidence on the need for such homes and their impact on development viability, as required by PPG. Such standards should not require a higher standard than the optional technical standards, and they should be robustly justified. 4.30 We would caution against the Greater Cambridge Local Plan seeking to adopt standards that are overly ambitious, or which respond directly to current market trends. When setting policy requirements for the entire plan period, it is important that the standards are realistic and achievable for all developments across the area and the timeframe. Otherwise the policies could have the unintended consequence of constraining future development – or fuelling further escalating house prices – with a negative impact on achieving the Local Plan’s strategic policy objectives. 4.31 Hill and Chivers are committed to supporting the new and existing community in Hardwick through the delivery of a high-quality and sustainable village extension.

5.2 The Councils will need to work closely with infrastructure providers in developing their policies for infrastructure delivery within the Greater Cambridge Local Plan. It is important that projects identified in the Local Plan are ambitious, but also realistic and deliverable within the stated timescales. Whilst some transport and spatial strategies may include aspirational projects, it is essential that the Local Plan – as a statutory development plan – includes infrastructure that is committed and scheduled for delivery during the plan period. 5.3 The timing of infrastructure delivery is important. Some large-scale infrastructure, such as East-West Rail, will have significant lead-in times. Except where directly related to a development, delays in the delivery of strategic infrastructure should not be used as a reason for withholding planning permission. Likewise, requirements for developers to contribute to infrastructure projects should be directly related and proportional to the scale of development proposed. Geographically, housing growth should correlate with planned infrastructure. The Council should not see strategic development as an answer to delivering essential infrastructure. There needs to be a recognition that small and medium sized development opportunities can also support infrastructure delivery, often bringing benefits that are of great significance to local communities.

5.4 Creating a modal shift in transport use away from private vehicles towards more sustainable forms of transport will require a range of measures. The Local Plan has the ability to bring some of these elements together to have the overall effect of reducing the need to travel and increasing access to sustainable transport options. 5.5 A key factor affecting transport choices is the location of development. Cambridge has a large employment base and significant levels of services and facilities. As such, it has a significant ‘draw’ effect which can result in congestion at peak times due to the number of daily trips undertaken for both commuting and pleasure. Development in locations that are in close proximity to Cambridge, or well connected via sustainable travel options, will reduce the length of journeys and the dependence on private vehicles. 5.6 The Cambridge Green Belt currently restricts the potential for strategic development in close proximity to the City. The Green Belt Assessment undertaken in support of the 2018 Local Plans highlighted that the value of the Green Belt diminishes over distance from the City. The Green Belt edge extends to Hardwick and in that context can be seen to potentially have less value in this location than areas of the Green Belt closer to the City – a matter supported by the Preliminary Green Belt Assessment submitted in response to the Call for Sites 2019 (Appendix 2). 5.7 Permitting village extensions to well-located settlements such as Hardwick would serve to encourage the use of sustainable transport options without impacting on the Green Belt areas of greatest value. Hardwick benefits from existing bus services (Citi 4), cycling and walking routes. Accessibility will be further improved through the implementation of the Cambourne-to-Cambridge public transport project and potential linkages into the Greenways cycle network. 5.8 As promoted in the NPPF (paragraph 78), sustainable development in rural areas is about locating housing where it will enhance or maintain the vitality of rural communities. The sustainable growth of villages through additional housing development can contribute to the footfall needed to support village services and facilities, i.e. reaching a critical mass that can support a vibrant village economy. This reduces the need to travel by private vehicle and also rejuvenates local areas and their communities. 5.9 Likewise, the co-location of different land uses is another important consideration in making strategic policy decisions to shape travel choices. For example, where new residential developments in villages provide a mix of uses (employment, shops and cafes, community facilities and recreational spaces) or are located adjacent to existing services, then this will facilitate local residents to live, work and relax within their own local area and community. This will reduce the need to travel into Cambridge or one of the larger villages or towns for work, shopping and other facilities. It will also have a positive impact on wellbeing, local community cohesion and sense of place.

Nothing chosen

6.4 Yes. 6.5 It is important to note that the Green Belt is a planning designation rather than an environmental designation. As set out in the NPPF (paragraph 136), Green Belt boundaries can be altered where exceptional circumstances are evidenced and justified, through the preparation or updating of plans. The current and future constraints to housing development within Cambridge and its fringe, together with the high growth needs of the area and the importance of delivering growth in a sustainable way, presents a strong case to review the Cambridge Green Belt. 6.6 The high level of housing delivery needed to sustain an ongoing five-year housing supply throughout the plan period is best met through a mix of housing sites and land availability. Sustainable growth within settlements surrounding Cambridge can make an important contribution to this objective, creating opportunity to rebalance housing supply and foster zero carbon developments and lifestyles through reduced travel distances and sustainable travel options. Releasing land from the Green Belt in close proximity to Cambridge, where existing infrastructure can be enhanced, arguably provides the best opportunity to influence and change people’s behaviours around travel and commuting and encourage adoption of more sustainable modes of transport. 6.7 The villages that are fully or partly surrounded by the Cambridge Green Belt are those that are located in closest proximity to Cambridge and therefore bring significant opportunities for development that is accessible to the City. In order to provide truly sustainable development, some Green Belt sites in these locations must be considered through the Local Plan process as potentially suitable options. The appropriate release of Green Belt sites could assist in achieving sustainable development in keeping with the ‘climate change’ big theme of the emerging Greater Cambridge Local Plan. 6.8 Hill and Chivers consider that the Councils should undertake a comprehensive review of the Green Belt within Greater Cambridge as a key part of the Local Plan process. This will inform important strategic decisions regarding the most appropriate locations for development during the plan period. 6.9 In relation to land east of Cambridge Road, Hardwick, Terence O’Rourke has undertaken a Preliminary Green Belt Assessment (March 2019) which confirms that the Site performs poorly when assessed against Green Belt purposes. The release of the Site to create a sustainable village extension would provide a strong new Green Belt boundary, without prejudicing the remaining Cambridge Green Belt.

Highly flexible

.10 Highly flexible (in the approach to reviewing village boundaries) . 6.11 The emerging Local Plan will need to strike a careful balance when addressing the issue of development on the edge of existing villages. Some of the villages surrounding Cambridge – such as Hardwick – are located on strategic growth corridors with excellent transport links. These villages provide opportunities for sustainable development and they should be identified as such within the Local Plan. The boundaries of these villages should be reviewed and where there are sites that will appropriately support sustainable village extensions then these should be allocated for development within the plan period. 6.12 In terms of Local Plan policy, the existing approach of tightly-drawn ‘village frameworks’ (boundaries) has in practice not been adhered to through development decisions. The Council should review this policy approach.

Nothing chosen

6.14 We consider that the categorisation of South Cambridgeshire villages should undergo a comprehensive review through the Local Plan process. Even since the last Local Plan (2008), strategic developments and policy decisions have resulted in significant changes in the context for existing settlements. 6.15 Taking Hardwick village as an example, this is categorised as a Group Village (Local Plan Policy S/10) where residential development and redevelopment is permitted up to a maximum scheme size of eight dwellings within the development framework, or exceptionally up to 15 dwellings on a single brownfield site. However, Hardwick village has seen planning permission granted for significantly larger residential schemes than these thresholds at both Grace Crescent and St Neots Road. In addition, the strategic location of the village on the route between West Cambridge/Eddington and Bourn Airfield/Cambourne means that the village benefits from good public transport links. This will be further strengthened in the forthcoming plan period by the implementation of the Cambourne-to-Cambridge public transport project, including a new Park and Ride facility at Scotland Farm (north of Hardwick); the new Cambridge-Oxford Expressway; and EastWest Rail (with a station at Cambourne). In short, Hardwick’s current categorisation as a Group Village does not reflect the settlement’s potential as a very sustainable location for further growth, and it should be identified as such in the Greater Cambridge Local Plan. 6.16 The South Cambridgeshire villages should be re-categorised within a new settlement hierarchy. The new settlement hierarchy should consider not only the existing levels of services and facilities within the settlement, but also take account of the village’s potential as a location for sustainable future growth during the plan period. 6.17 Where villages are identified for strategic growth during the plan period, this should be carefully considered through the Local Plan process, including reviewing the settlement framework boundary and considering the release of land from the Green Belt where this is appropriate. Sites for development should be allocated in the Greater Cambridge Local Plan, providing the certainty required for both the local community and landowners/developers. By following a plan-led approach to site release and development, the step-change in growth that is needed in Greater Cambridge will be best accommodated to the benefit of existing and new communities.