Greater Cambridge Local Plan Issues & Options 2020

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On behalf of European Property Venutres (Cambridgshire), Claremont Planning recommends that the Plan recognises the key importance of sustaining th economic growth throughout the next Plan period and support the deliery of the strategic infrastructure strategy to 2050. Unless the Plan ensures economic growth as a fundamental component of the development strategy, it will fail to secure the longevity and vibrancy of the Plan area in the long term. It must be recognised that economic growth and prosperity across the Plan area has a significant relationship with other aspects of the Local Plan, in particular residential demand and housing growth. These elements of the Plan are directly related and therefore new policies that are adopted by the Plan must acknowledge this interconnectivity. It is recognised that the Plan area has benefited recently from significant levels of economic growth that has benefited the area considerably. It is essential that the Plan recognises the resulting significant pressures on the local housing market and address this appropiately through a necessary quantum of development. As such, the level of housing should reflect this and a substantial increase in housing numbers for the new Plan to deliver would ensure that this increased demand can be met. As such, the Plan, whilst supporting economic growth, must ensure that it is appropriately managed so that development which is implemented is sustainable and appropriate in terms of scale, design and location. Therefore, the Plan needs to implement a spatial strategy which can support both economic and housing growth to meet the needs of the new Plan period. Summary of Comments: The plan should support economic growth and recognise the need to implement higher levels of housing to support this growth.

It is a statutory requirement for Local Plans to address the housing requirements of their local plan area. This includes providing strategic policies to identify the requisite scale of development as well as the quantum of development, particularly housing numbers to meet the identified need of the Plan area over the established Plan period and reflect economic growth requirements. Paragraph 20a of the National Planning Policy Framework asserts that Plans should make sufficient provision for multiple elements of development, including housing, retail and other commercial development. As such, it is a fundamental priority for the emerging Local Plan to ensure that an appropriate objectively assessed need, underpinned by the relevant evidence, is identified and that this need can be realistically delivered over the Plan period. The Plan should also engage a deliverable spatial strategy that has the ability to provide a basis for growth that can accommodate the necessary housing requirement. The adoption of a realistic spatial strategy will contribute towards the Plan's ability to satisfactorily deliver the requisite housing numbers over the Plan period. An effective spatial strategy should consider all options in terms of locations and the distribution of development. Given that the Greater Cambridge area includes vastly different spatial characteristics, ranging from dense urban landscapes to rural village locations; the spatial strategy should positvely respond by allowing for a distribution of development and varying spatial options to accommodate development. It is considered that no single spatial option represents the most appropriate approach and instead the Plan should adopt a flexible approach to its emerging spatial strategy, by not precluding any possible avenues at this early stage. European Property Ventures (Cambridgshire) recognises that large quantums of development for housing and impeloyment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge. Alongside this the strategy should seek to provide development opportunities at smaller settlements where growth can be accommodate through amendment to Development Frameworks. Achieving development at sustainable settlements across the hierarchy would be able to deliver affordable homes and also provide new houses to address high house prices within rural locations where the lack of new housing stock has artificially inflated values. Summary of Comments: Adoption of a flexible and considered spatial strategy will contribute towards delivering the housing numbers the Plan needs to meet demand.

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European Property Ventures(Cambridgeshire) are of the position that the emerging Greater Cambridge Local Plan must plan for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review has recognised that the Combined Authority Area (Cambridgeshire and Peterborough) has experienced a higher rate of economic growth than forecast. This is a significant indicator that the new Plan for Greater Cambridge must consider actively planning for through delivery of a significantly higher number of homes. Furthermore, if implemented into the spatial strategy, an increase in the number of homes to be delivered will allow a better degree of flexibility that will otherwise not be available if the Plan only provides for the minimum. Given the evidence that is available, it would not be an appropriate or sound approach if the Plan were to avoid strategising for a higher number of homes than the government figure suggests - instead the government figure should be consdiered the minimum level required. If the economic trend is to continue within the Plan area, which the CPIER report establishes, it would be a failure of the Plan's statutory requirement to "make sufficient provision" for housing numbers and boost delivery, as asserted in the NPPF. If the Plan is to support the economic growth of the area over the new Plan period, a higher housing quantum will need to be incorporated into strategic policy. If insufficient homes are delivered over the new period, this will supress any potential for economic growth within the Plan area and result in diminishing the expansion of the jobs market in Cambridge and South Cambridgeshire. Summary of Comments: Higher quantum of housing is need to assure flexibility and to support the significant economic growth experienced in the Plan area.

European Property Ventures (Cambridgshire) consider that it is important for the Plan to deliver a varied range of housing, particularly with respect to bedroom size and tenure mix that reflects the findings of the Strategic Housing Market Assessment. However, to ensure that development can truly address local needs and respond to lcoational characteristics, such development requirements for residential proposals should not be overly or inappropriately prescriptive. Schemes for residential development should be required to deliver a housing mix that most appropriately caters for the needs of the community it will serve and should not be controlled by a restrictive development management policy which applies particular obligations for development to deliver at the strategic level. It is recognised that affordability is a major issue within Greater Cambridge, particularly within the rural areas and villages. European Property Ventures (Cambridgshire) considers there is a need for the emerging Local Plan policy to address this issue and ensure that a mix of types and tenures is catered for across the whole of the plan area. Similarly, where settlements are dominated by a particular housing type or scale, there should be the opportunity through emerging plan policy for Development Frameworks to be sutiably amended. European Property Ventures (Cambridgshire) maintain that although the new Plan should include policy guidance on housing types, including size and tenure mix, such guidance should be supported by the most up to date evidence and have the ability to respond directly to specific local requirements. The wording of any policy should reflect this and provide suitable provisions for housing mix to be informed by local circumstances and market influences. Taking into account the size of the plan area and the varied characteristics of the area, it is important that any policy guidance includes an appropriate degree of flexibility in its requirements for housing development. For example, housing mix requirements will differ between settlements across the entire Plan area, given that the needs of rural South Cambridgeshire will be different from those within Cambridge City. It is therefore important that any attempt to include specific housing mix and type requirements within development management policies should ensure a degree of flexibility and acknowledge locational considerations. Summary of Comments: Policies for housing mix/type should not be prescriptive, allow for local requirements alongside those identifed in the latest SHMA.

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European Property Ventures(Cambridgeshire) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options such as reducing travel distances and thereby reducing climate impacts. The removal of land from the Green Belt should be considered on the edge of sustainable settlements where growth responds positively to sustainable growth. The review of Green Belt boundaries is justified by the circumstance of the Greater Cambridge Plan preparation and the quantum of housing to be delivered, this review must address all settlement boundaries to ensure that the ssutaianble distribution of develoment can be achieved. Support is advanced toward the direction proposed for the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However, it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the site at Dry Drayton Road, Oakington, benefits from access to social infrastructure, which includes amenities such as a primary school and convenience store. These are within walking distance from the site and therefore should be recognised as demonstrating a sustainable location for new development. Furthermore, although the site is designated as Green Belt, it is considered that existing development along Dry Drayton Road establishes a significant urbanising influence over the area. This development also provides an extent of enclosure around the promotion site and therefore, its development would not result in a detrimental impact on the openness of the area to the south of the village. The site and the village also benefit from proximity to Cambridge, with good local transport linkages into the city via bus services from within the village itselt as well as via the adjacent guided busway. As such, the consideration of the site for Green Belt release and subsequent allocation for development would comply with this option in securing release of Green Belt sites that are supported by sustainable transport options and encourage a modal shift away from private car use. Summary of Comments: Releasing sites from Green Belt should be an element of wider and more comprehensive spatial strategy that includes other approaches.

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European Property Ventures (Cambridgeshire) consider that the Local Plan should be flexible toward development of both jobs and homes on the edge of villages. It is considered that the policy approach should apply flexibility with regard to the scale of development to be provided for at villages and the ability to amend the Development Frameworks to accommodate additional housing requirements, ensuring a flexible approach to development on the edge of villages. The adopted settlement hierarchy of the South Cambridgeshire Local Plan recognises that there are sustainable villages within the District that can appropriately accommodate levels of growth that can both contribute towards meeting the strategic needs of the Plan area and a flexible approach to development should be applied to the most sustainable settlement. The site controlled by European Property Ventures (Cambridgeshire) at Dry Drayton Road, Oakington represents a deliverable and appropriate example of an edge of village site. Although the site is designated as Green Belt, it is considered that existing development along Dry Drayton Road, such as the Oakington Garden Centre establishes a significantly urbanising influence over this particular area of Green Belt. Furthermore, this development encloses the promotion site to the south as well as to the north, which diminishes the openness of the site characterised by its undeveloped nature. Therefore, it is maintained that the site at Dry Drayton Road provides an appropriate and suitable location to secure new development that will not result in harmful impacts on the Green Belt at this location. Given that the overall openness of the Green Belt to the south of Oakington has been reduced by the presence of built form along the highway, it would be appropriate for the Authorities to consider a site for development at this location. Although the site would technically be regarded as edge of village in the context of planning policy, its immediate context is not open to the wider rural landscape and so its enclosure by existing built form lessens its typical edge of settlement characteristics. A spatial strategy should be advanced that provides for new development at the edge of villages to ensure that it maximises sustainable development opportunities. It is considered that sites such as at Dry Drayton Road, Oakington represent such opportunities and omission of them will result in a spatial strategy which has not appropriately explored all deliverable or realistic directions of growth to assist in meeting the demanding housing needs for Greater Cambridge. Summary of Comments: Development at the edges of villages is supported, as it is a sustainable approach which can contribute towards meeting the OAN of the Plan area.

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European Propoerty Ventures (Cambridgeshire) advance that the approach of the South Cambridgeshire Local Plan tshould encourage further development at sustainable villages through the expansion of existing village frameworks. The application of overly prescriptive guidance of what is then aceptable at such villages is not considered to be compliant with the National Planning Policy Framework's assertion to support development where it is demonstrated to be required whilst also achieving the best and most efficient use of land. It is acknowledged that development within rural settlements must respond to their context, including historical built form and rural character. However, it is maintained that many of these settlements demonstrate sustainability credentials that complies with the objectives of the Framework. Access to public transport and existing services are primary considerations that should support growth within the villages, particularly where these are recognised in the adopted settlement hierarchy at Rural Centres, Minor Rural Centres and Group Villages. Achieving appropriate densities in line with the requirements of the Framework currently cannot be achieved by existing policies, particulalry with respect to the opportunities to deliver housing on infill sites and achieve affordable homes. The nature of development at villages is also dictated by the quantum of housing to be attributed to such settlements village frameworks and therefore, a more flexible approach should be adopted by the new Plan in order to achieve varying levels of development at such locations. Summary of Comments: A more flexible approach is considered appropriate to ensure that efficient and appropriate densities are achieved in sustainable village locations.

European Property Ventures (Cambridgeshire) consider that densification can provide one option of boosting housing delivery by increasing in residential quantum without the loss of existing undeveloped or greenfield land. However, it should be noted that the support of the National Planning Policy Framework to improving the efficiency and use of land can pose practical challenges that reduce the extent of open space, landscaping and causes over-concentration of environmental and social. This also includes complex ownership patterns within tight urban environments that can result 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 will need to be particularly sensitive and considerate to heritage settings. By doing so, this will impact on the practical considerations of delivering higher density schemes given the high degree of design that will be required to ensure that impacts to heritage setting are mitigated. Strategies seeking to increase residential density are likely to result in the introduction of significant population numbers within a particular urban area. This will support local services by way of enhancement of the customer base but will also provide additional pressures upon infrastructure and the local environment. Increases in density requires consideration of environmental and social capacities in relation to certain infrastructure; including public transport provision, schools and health services as well as utility services including water and sewage. 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.

European Property Ventures(Cambridgeshire) consider the inclusion of the safeguarded site at Cambridge Airport is inappropriate within the emerging spatial strategy. 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 development of the airport site has also been assessed as harming the function of the Green Belt, which is not sutiably justified by the lack of certainty regarding the site's delivery and demonstrated contributed to the spatial strategy. Although development of the Cambridge Airport site could provide a significant boost in housing numbers, there is no certainty of when the site will become available and how it could contribut to the Plan's housing trajectory. Therefore reliance upon the airfield site does not provide a deliverable or roust spatial approach and would be unsound. It would not therefore be appropriate for the airfield site to be included in the spatial strategy or housing trajectory for the new Plan period. The Cambridge Airport site should remain a safeguarded site and should form part of the long term aspirational objectives of the Plan to 2050 and not a component of the true spatial strategy up to 2040. Summary of Comments: The site should remain safeguarded but not included in the spatial strategy given there is no certainty attached to its availability.

Summary of Comments: 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. Euopean Property Ventures (Cambridgeshire) identify that the Cambridge and Peterborough Independent Economic Review has established that the economic growth of the Plan area has significantly outstripped forecasts, and so are of the mind that exceptional circumstances do exist to justify Green Belt review. The quantum of housing demand that is coupled to the substantial increas in economic growth will result in new development pressures influecning the whole of the Local Plan area. As such, it is imperative that the new Plan reviews its Green Belt to ensure that sufficient sites can be identified to meet this increased need as a result of this rapid economic growth experienced within the sub-region. This review of the Green Belt however should take into account the existence of sites that are within elsewhere in the Local Plan area, beyond the fringes of Cambridge city. Areas of land such as that under control by European Property Ventures(Cambridgeshire) demonstrates lesser sensitivity in terms of release from the Green Belt than those sites located at the fringes of Cambridge. These sites, given that they are not located at the edge of large urban areas, do not contribute towards the strategic purposes of checking urban sprawl, nor do they contribute towards protecting the open countryside from encroachment. The site at Dry Drayton Road is located at the southern edge of Oakington, and its immediate context is characterised by significant urbanising influences arising from development located along Dry Drayton Road which includes a large garden centre and farm buildings. Their presence erodes the openness of the Green Belt at this location and undermines the contribution of the undeveloped site to the local rural landscape, which is significantly affected by this built form. As such, the delivery of the site would not result in wider harm to the strategic function of the Green Belt and should be viewed as a preferable location to achieve new residential development. Although this site represents a suitable and appropriate option to achieve delivery of important housing numbers, it should not in the first instance mean that the emerging Local Plan should not consider reviewing the Green Belt as a whole, including sites at the edge of the Cambridge urban area. The review of Green Belt sites at the edge of Cambridge must 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 edge of settlement locations are more likely to demonstrate function in safeguarding the countryside from encroachment as well as checking urban sprawl (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: More suitable Green Belt sites exist for release that are more appropriate for the emerging Local Plan's consideration.