Greater Cambridge Local Plan Issues & Options 2020

The emerging Greater Cambridge Local Plan must be confident that exceptional circumstances exist to demonstrate that releasing Green Belt at the fringes of Cambridge city is an appropriate strategy. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving adequate levels of development to meet the needs of the new Plan period. Southern and Regional Developments (Swavesey) considere that whilst the Plan should ensure that it robustly considers the options in releasing land from the Green Belt to ensure that the development potential of sustainable sites can be realised, it should not preclude the consideration of other suitable sites that are not constrained by their Green Belt designation. This includes Southern and Regional Developments site at Boxworth End, Swavesey which provides a further option to achieve sustainable development. As it is not constrained by Green Belt, Swavesey should be considered as an alternative route to achieving the requisite levels of growth. It is emphasised that all options to achieve a robust spatial strategy should be considered, including the review of sites in the Green Belt at Cambridge city and the villages, as well as non-Green Belt sites located within the villages of South Cambridgeshire. The review of Green Belt sites at the edge of Cambridge should ensure that they do not directly contravene national guidance in relation to the purposes and strategic functionality of the Green Belt. The review of Green Belt sites at Cambridge is sensitive given that these sites demonstrate purposes in safeguarding the countryside from encroachment as well as checking urban sprawls (Paragraphs 134a and 134c of the NPPF). As such, consideration of any Green Belt sites at the fringes of Cambridge city must in the first instance be assessed against these strategic purposes to ensure that wider function of the Green Belt at the edge of the city is not detrimentally compromised. Therefore, it is maintained that the preferable approach should be to assess Green Belt and non-Green Belt sites beyond the fringes of the city, located within the villages of South Cambridgeshire given that the development at these locations will not result in significant sprawl or urbanisation. Summary of Comments: It is considered that the Plan must exhaust other Green Belt and non-Green Belt sites at sustainable villages prior to assessing sites at Cambridge.

It is considered that the emerging Greater Cambridge Local Plan should capitalise on the success of the strategic allocations that have been established through historical strategies made by South Cambridgeshire, such as Cambourne and those made more recently, such as Northstowe. The allocation of the new town at Cambourne has delivered strategically significant numbers of new homes to meet the needs of the District and this approach should form part of the comprehensive spatial strategy of the new Plan. However, it is considered that the inclusion of new settlements as strategic opportunities to achieve substantial housing numbers should not prejudice other sources of housing from other elements of the spatial strategy. The National Planning Policy Framework provides the basis as to how Local Planning Authorities should approach identifying the realisation of new settlements at paragraph 72 where it states that; "The supply of large numbers of new homes can often be best achieved through the planning of larger scale development, such as new settlements […]." However, it also asserts that elsewhere in the Framework, specifically at paragraph 68, that the identification of smaller sites is vital to ensure a robust housing delivery that can maintain a consistent residential supply. On behalf of Southern & Regional Developments (Swavesey), is considered that the new Plan should not provide inappropriate emphasis on allocation of new settlements or the delivery of those already identified. Their complexity, such as multiple land interests and provision of infrastructure can result in significant delay in implementation which can result in detrimental impacts to the anticipated housing trajectory and supply. To reduce the risk and avoid such a scenario, it is stressed that the emerging Local Plan and its spatial strategy should include new settlements, but not as a primary source of housing numbers. New settlement allocations should form part of a comprehensive arrangement of multiple residential development strategies to ensure a robust housing delivery programme for the new Plan period. Summary of Comments: Inclusion of new settlements is supported, but should not be considered a primary mechanism for housing delivery.

Southern and Regional Developments (Swavesey) consider that the adopted spatial strategy of the South Cambridgeshire Local Plan appropriately recognises the opportunity and potential that exists at the villages of the District to accommodate strategically significant numbers of housing. Such housing delivery has suuported the housing delivery of the Councils and should be considered as making a materially beneficial contribution toward meeting the residential needs of the Local Plan area. This must be reflected within the emerging Greater Cambridge Local Plan by establishing that settlements such as Swavesey remain suitable locations and accommodate moderate levels of growth. such growth will be able to sustain existing communities whilst also representing a significant contribution to the spatial strategy. It is acknowledged that a number of these villages, such as hamletsthose established as Group Villages in Policy S/10 of the adopted South Cambridgeshire Local Plan are recognised as being less sustainable locations for development. However, there remains settlements that can demonstrate enhanced sustainability credentials which are established in the South Cambridgeshire Plan as Rural Centres and Minor Rural Centres. Swavesey is regarded as a Minor Rural Centre in the adopted settlement hierarchy and is a preferable and suitable location to accommodate new residential allocations. The village itself benefits from an established service base that is within walking distance from the site. These include a secondary school, primary school, post office, village store and medical centre which demonstrate that the village provides a significant range of facilities that reduces the need to travel out of the village to source such services. Furthermore, Swavesey village benefits from a link to the guided busway which provides rapid, frequent services into Cambridge as well as connections to other settlements in the wider area and is also in close proximity to the A14. This should be recognised within the emerging Local Plan, specifically the spatial strategy that needs to re-assess the status of these villages as sustainable and suitable settlements to accommodate moderate levels of residential growth. It is maintained by Southern and Regional Developments (Swavesey) that the strategy in dispersing development to the villages of the Plan area should form part of a wide ranging approach. Identification of the suitable sites at the villages should represent an element of a comprehensive strategy that includes other approaches to achieve the requisite level of growth that meets the identified demand of the Plan area. As such, the consideration of development at the villages of the Plan area should not preclude the consideration of other possible avenues, such as new settlements or development at the fringes of Cambridge city. Notwithstanding that, the consideration of the development dispersal to the villages should be included within the Plan preparation process, given the historical success in this approach. Summary of Comments: Southern and Regional Developments support a strategy in dispersing development to the villages.

It is considered that the settlement hierarchy for the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Local Plan. Southern and Regional Developments (Swavesey) believe that Swavesey is inappropriately placed within the second tier of the adopted settlement hierarchy, which establishes the village as with lesser sustainability credentials than those placed in the top hierarchical tier. Swaveseys's current position within the adopted spatial hierarchy undermines the suitability of the village to accommodate moderate levels of residential development. It benefits from an established service base, which includes services such as a secondary school which minimises the need to travel beyond the village to access amenities. Southern and Regional Development's site at Boxworth End benefits from being within walking distance of a number of amenities within the settlement, including a medical practice, primary and secondary schools which supports the suitability and sustainability of the site and so its consideration for residential allocation. It is also important to note that whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, such as at Cambourne, the emerging Local Plan should apply inappropriate reliance on the delivery of these allocations. The National Planning Policy Framework sets out at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the Framework emphasis elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. These sites can therefore more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as that at Boxworth End, Swavesey. Summary of Comments: A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

Southern & Regional Developments (Swavesey) require a review of the spatial options included in the emerging Greater Cambridge Local Plan to ensure that needs of the new Plan period can be satisfied. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply position, which will result in vulnerability of the Councils to speculative development which will deviate from the preferred growth strategy of the emerging Plan. It is considered that a sustainable and appropriate strategy approach to achieve the requisite levels of residential development is identifying sufficient sites at village locations within South Cambridgeshire. This has formed an element of the adopted spatial strategy of the District and it would be a logical step to consider incorporating this into the new spatial strategy of the emerging Greater Cambridge Plan. Furthermore, given that there is land located outside the Green Belt at sustainable settlements such as Swavesey, it would be inappropriate of the new Plan to exclude this approach. If new development is not considered at village locations, this would result in a spatial strategy that would be inappropriately attributing weight towards alternative development avenues, such as strategic sites and Green Belt release. Whilst it is considered that these strategies demonstrate a reasonable and deliverable approach to growth, it would not be appropriate if these strategies were not complemented by development directed towards the villages. This would provide a comprehensive spatial strategy which would achieve moderate levels of growth, but that which can contribute towards the strategic requirement of the new Plan period. Consideration of sites at the villages, such as the Dairy Farm site at Boxworth End, Swavesey demonstrates a reasonable and sustainable approach to strategic development. The identified site at Swavesey is located within walking distance to a range of services that are established within the village, including a secondary school, primary school, shops, GP Surgery and benefitting from access to excellent public transport services that link to nearby employment destinations such as Cambridge and Huntingdon. It is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages such as Swavesey for it to adopt an effecive, comprehensive and deliverable spatial strategy. If it does not do so, it will risk implementing a poorly deliverable strategy which will not be able to meet the identified needs of the Plan area over the new time period. Planning permission S/3391/16/OL was also considered for residential development of the site, through which the location was assessed as being suitable to accommodate residential development with a sensitive layout capable of being achieved without an adverse impact on the character of the surrounding landscape, with the site’s suitable for housing considered to outweigh the limited harm that would arise in relation to the Important Countryside Frontage designation along the roadside frontage. No technical concerns were identified through this proposal’s consideration, with the Highway Authority, Ecology Officer, Environment Agency, Lead Local Flood Authority, Urban Design. District Landscape Officer and Planning Department considering the site as suitable to accommodate new homes. In relation to secondary school provision, an extension to increase capacity at the Village College by 150 pupils has been completed, as a result of an identified shortfall in capacity in 2012. Following other residential consents at Swavesey any development at the village would enable the expansion of the Village College further, which would assist in ensuring capacity over the extended plan period. It is Southern and Regional Developments (Swavesey) position that the approach to be taken by Greater Cambridge Councils should identify a spatial strategy that is comprehensive across all of the sustainable settlement tiers; considering a number of avenues to achieve the requisite levels of housing development. Swavesey’s settlement status as a Minor Rural Centre should be recognised through the allocation of further housing growth proportionate to the facilities it provides. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including sites at villages such as Swavesey.

Southern & Regional Developments (Swavesey) consider that although densification provides one sustainable route to achieving an increase in residential quantum it cannot be relied upon to deliver housing across the whole plan area or to safeguard greenfield land. It should be noted that although the National Planning Policy Framework supports efforts in improving the efficiency and use of land, this is recognised as posing practical challenges reducing the viability and deliverability of this approach. This includes complex ownership patterns within tight urban environments which results in difficulties in land assembly to implement a coherent scheme. Furthermore, actively increasing density results in the implementation of development larger in scale and bulk, which can impact on sensitive areas including the historical urban landscape of Cambridge city centre. As such, strategies to increase densities here will need to be particularly sensitive and considerate to the heritage setting. By doing so, this will impact on the practical considerations of delivering higher density scheme as well as issues of viability given the high degree of design that will be required to ensure that impacts to heritage setting are mitigated. Strategies seeking increases in residential density could result in the introduction of significant population numbers and related impacts within a particular urban area. Although this intensification can support local services thorugh enhancement of the customer base, it will also provide additional pressures upon infrastructure. Increases in density requires consideration of capacities of certain areas of infrastructure, including public transport provision, schools and clinical services. Increases in population through the provision of enhanced density therefore need to be met with expansion of infrastructure and the service base that these provide. Summary of Comments: Densification can contribute towards achieving a high level of sustainable development, but should complement other elements of a spatial strategy.

Southern and Regional Developments (Swavesey) consider the inclusion of the safeguarded site at Cambridge Airport as inappropriate. Although it is acknowledged that the owners of the airport have indicated their intention to relocate to an alternative site in the future, as they are a third party unrelated and unconnected to the Local Planning Authority, the availability of the site is not assured and beyond the control of the Council. As such, there is no guarantee that the site will be available for development towards the latter part of the new Plan period or beyond. Furthermore, the Airport site is currently fully occupied by a thriving local business that supports the economic vibrancy of the location and provides employment. The occuption by a thriving local business that has been resident on the site for an estbalished period of time should not be ignored, particularly in respect of the ability of the business to successfully relocate and recreate the favourable business conditions that they have been in place. These consideration mean that this site opportunity is less likely to be available. Development of the Dairy Farm site could provide a significant boost in housing numbers on a site that would not harm the Green Belt, whilst there is no certainty attached to when the Cambridge Airport site will become available so it would not be appropriate for the site to be included in the spatial strategy or housing trajectory for the new Plan period. The site should remain a safeguarded site and should form part of the long term aspirational objectives of the Plan and not a component of the true spatial strategy to deliver housing for the identified need across the new Plan period. Summary of Comments: The site should remain safeguarded but not included in the spatial strategy given there is no certainty attached to its availability.

European Property Ventures (Cambridgshire) consider that the Local Planning Authority have a duty to involve and consult with the community including local residents, businesses, interest groups and landowners in the formation of policies that will shape the Local Plan for Greater Cambridge. This is asserted at Paragraph 16c of the National Planning Policy Framework where it states that Plans should; "be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees." It is considered important to ensure that Local Plan documents including background information is easily accessible on the Council's website and it would be helpful if e-mail alerts were provided to Planning Consultants and Developers to make them aware of when each stage of the Plan is available for comment. It is important the Council ensures that the ongoing Plan preparation process is open and accessible to all, identifying the most appropriate times for public commentary which will provide significant local insight to the Plan process and practical requirements for local communities. Summary of Comments: Preparation of the emerging Local Plan must ensure accessibility for all and provide means of commentary throughout the process.

Agree

European Property Ventures (Cambridgeshire) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date. The timescale of any plan should be able to respond to long-term requirements and opportunities including major improvements to infrastructure It is directed however that it is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond thi proposed plan period so that a sustainable strategic approach is adopted that has longevity. Thi is demonstrated by the strategic lan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positely to address the ssocaited astrategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040 whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adoptes. Major infrastructure projects that will provide for long term requirements have already been identified at the New Towns of Northstowe and Waterbeach. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Oakington must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Dry Drayton Road, Oakington can demonstrate such deliverability as an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing to cover this period.

Nothing chosen

European Property ventures (Cambridgshire) contend that the emerging Local Plan should identify the strategic issues that will influence the plan area over the new Plan period and beyond. It is considered that although the themes that have been identified attempt to overcome significant issues that will have wide impacts, such as Climate Change; the approach to this is ot consdiered to be coherent. It is understood that issues relating to Biodiversity and Climate Change are important, however the Plan's regard to these factors is inappropriate. Considerations relating to ecology, the natural environment and Climate Change are interlinked through the strategic theme of environmental sustainability and so should inform the strategic approach comprehensively. Presently, the approach of the Plan inappropriately provides emphasis towards environmental sustainability, which results in a reducing the value of social and economic sustainability and the associated contribution to realsigin environmental benefit. A more positive approach would be for these factors to be attributed equal significance so that the objectives of the Plan can be satified by delivering changes positively through economic growth and addressing social inequalities . The current arrangement of big themes is contrary to the National Planning Policy Framework, which asserts that all aspects of sustainable of development must demonstrate economic, social and environmental as equal components in achieving sustainable development. This is in the effort to ensure development that will not compromise the ability of future generations from meeting their own needs. It is considered that for the emerging Local Plan to provide an ambitious and positive approach to addressing climate change and environmental issues, economic and social factors must be recognised as informing development solutions. The delivery of enivronmental objectives should not be to the detriment of the other elements of sustainable development. Greater Cambridge is experiencing unprecedented levels of growth and so it is vital that the new Plan identifies an appropriate and deliverable strategy to meet the demands of this growth. This includes sufficient land and sites to meet the specific needs of Cambridge city, as well as the rural requirements of the larger area of South Cambridgeshire. Presently, there is insufficient emphasis on these other aspects of development. Summary of Comments: The big themes do not provide the correct balance between the elements of sustainable development, with inappropriate emphasis on climate change.