Greater Cambridge Local Plan Issues & Options 2020

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Southern & Regional Developments (Joscelyn) expreses caution relating to the application of higher levels of design standards and construction requirements through development management policies. their concerns is that such requirements will result in restrictions that will impact on viability and deliverability of development within the Plan area. Whilst it may be an objective of the Plan to combat Climate Change to mitigate development impacts and existing factors, the application of restrictive requirements to development design above national standards could directly impact on the Plan's ability to ensure adequate levels of growth are implemented. The Plan should not attach restrictive caveats to development management policies and should explore alternative strategies to combat climate change and achieve a highly environmentally sustainable approach to development. It is important that this is carefully balanced with the needs of the Plan area to achieve growth that meets the demands of its communities and support the everyday requirements of the area's residents. Summary of Comments: Application of restrictive development management requirements is not supported where it will result in the suppression of the delivery of growth.

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It is very important that the Local Plan supports economic growth through the next Plan period. Without the Plan ensuring economic growth as a fundamental component in its development strategy, it will fail to secure the longevity and vibrancy of the Plan area in the long term. Southern & Regional Developments (Joscelyn) recommends that the Plan should recognise the key importance of sustaining the 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 positively 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. Southern & Regional Developments (Joscelyn) recognise that large quantums of development for housing and employment 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.

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. Claremont Planning have advised Southern & Regional Developments and 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 influencing 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. It is considered 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 Kingfisher Way Cottenham which provides a further option to achieve sustainable development. As it is not constrained by Green Belt, Cottenham 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, alongside the review of sites in the Green Belt. 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: More suitable Green Belt and non-Green Belt sites exist for release that are more appropriate for the emerging Local Plan's consideration.

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. Therefore, it is considered that the new Plan should not provide inappropriate emphasis on allocation new settlements or the delivery of those already identified. Their complexity, such as overlapping land interests and provision of infrastructure can result in significant delay in implementation and so 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 strategies to ensure a robust housing delivery programme for the new Plan period.

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 which can make a materially beneficial impact on meeting the residential needs of the Local Plan area. This should be reflected within the emerging Greater Cambridge Local Plan by establishing that these settlements remain suitable locations to accommodate moderate levels of growth which can represent a major component of the spatial strategy and between them, deliver a substantial number of homes to meet the objectively identified need of the Plan area. It is understood that a number of these villages, such as those established as Group Villages in Policy S/10 of the adopted South Cambridgeshire Local Plan are recognised as less sustainable locations for development and therefore not preferable to accommodate new growth. However, there remains other settlements that can demonstrate enhanced sustainability credentials which are established in the South Cambridgeshire Plan as Rural Centres and Minor Rural Centres. In particular, Rural Centres are recognised as demonstrating the most sustainable settlements within the District due to their established and wide range of services available for the use of village residents. This includes, but is not limited to, a primary and secondary schools, medical facilities, community facilities and retail outlets. Cottenham benefits from such amenities and therefore reduces the need for residents to travel outside the village to meet their everyday needs. As such, the emerging spatial strategy of the new Greater Cambridge Local Plan needs to maintain this recognition, to both support the viability of this service base but also as an appropriate component of the new strategy that can ensure deliverable housing numbers to meet the identified need of the new Plan period. Although it is considered that delivery of sites as sustainable villages alone will not deliver sufficient numbers to meet the need of the new Plan, allocating sites at settlements such as Cottenham demonstrates an appropriate and deliverable approach to the new spatial strategy which will go a significant distance in satisfying the strategic housing need of the Plan area. However, it is maintained that the strategy in dispersing development to the villages of the Plan area cannot demonstrate a sustainable spatial strategy alone. 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 not be omitted from the Plan preparation process, given the historical success there has been in implementing this approach. Summary of Comments: Support is given to a strategy in dispersing development to the villages, alongside consideration of other approaches.

Southern & Regional Developments (Joscelyn) considers 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, the emerging Plan should not apply inappropriate reliance on the delivery of such allocations. The National Planning Policy Framework asserts 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 therefore that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites alongside larger strategic scaled allocations, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as at Kingfisher Way, Cottenham. Although it is appropriate that Cottenham is identified as a top tier settlement and recognised in the adopted spatial strategy as one of the most sustainable villages in the District, it is maintained that this hierarchy should be reinforced and supported so that appropriate levels of new development may be achieved. This should form part of a wider ranging and comprehensive re-assessment of the spatial approach to new development within the Plan area and should acknowledge the development potential of sites at sustainable settlement such as that at Kingfisher Way, Cottenham. Currently, without a robust reassessment of the spatial strategy, such sites may be omitted from the new Plan which will undermine its ability in seeking a sufficient number of sites to meet the strategic housing need of the new Plan period. Given that approaches of South Cambridgeshire and Cambridge city will be amalgamated through the implementation of a joint Plan, the approaches of both Authorities will need to be cohesive and supplementary, ensuring that no previous appropriate or deliverable approach is excluded. Directing development towards sustainable villages, including Cottenham, should be regarded as a significant component of the new spatial strategy and demonstrates a deliverable approach to spatial planning. Summary of Comments: The most sustainable settlements recognised in the South Cambs hierarchy should be reinforced and supported to accommodate new growth.

Southern & Regional Developments (Joscelyn) 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 land off Kingfisher Way at Cottenham that is demonstrated as a reasonable and sustainable approach to strategic development. Consideration of sites at villages, such as the site at Kingfisher Way Cottenham demonstrate a reasonable and sustainable approach to strategic development. The site at Kingfisher Way, Cottenham benefits convenient walking distance from a wide range and establish level of services, which supports the sustainability of the village as a top tier settlement in the adopted hierarchy of South Cambridgeshire. Cottenham, as one of the most sustainable existing settlements in the District, should be robustly considered for additional growth given the level of services available within the settlement which provides a level of capacity which should be exploited through the new Plan period. Therefore, it is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages if it is to adopt a 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. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including the identification of sites at villages.

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Response to Question 42 Southern and Regional Developments (Joscelyn) consider that no single development option for the new spatial strategy represents the most appropriate approach and consideration with a range of options provides the most sustainable strategy to ensure that adequate growth can be realised. It is considered that developments directed towards the edges of villages is a suitable approach that will help identify a range of small to moderately sized sites which will be able to robustly contribute towards the objectively assessed housing need of the Local Plan area.. For example, the site under the control of Southern and Regional Developments(Joscelyn) at Kingfisher Way, Cottenham has been identified as a suitable site that can assist in meeting the development needs of the plan area. This site would robustly complement a wider spatial strategy that includes multiple avenues in achieving the requisite levels of development. Furthermore, small to moderate sites, such as that at Kingfisher Way, Cottenham, have widely recognised faster build-out rates than strategic sized allocations. The National Planning Policy Framework asserts that Plans need to identify a range of smaller sites to offset any possible delays that are often attracted to strategic developments and therefore the spatial strategy should reflect this by identifying small to medium sized sites towards the edges of sustainable villages in the Local Plan area. Delivery of such scaled sites will able to more appropriately support the maintenance of a robust housing supply, given that these sites present schemes that are less complex and more easily deliverable. Therefore, if circumstances arise which delay the delivery of the strategic sized sites in the Plan area, small and medium sized sites could be brought forward to overcome any possible adverse impacts to the housing trajectory. This would comply with the National Planning Policy Framework where it asserts that Plans need to identify a range of smaller sites to offset any possible delays that are often attracted to strategic developments. As a result, the spatial strategy should reflect this by identifying appropriate small to medium sized sites that are located towards the edges of sustainable villages in the Local Plan area. The most preferred option for the new Plan to explore in the first instance is to disperse development to the sustainable settlements, which includes villages such as Cottenham. However, it is maintained that this should not be the only option considered as part of a new comprehensive spatial strategy. The identification and allocation of new settlements can provide a robust element to a strategy which provides significant numbers of housing to a supply, as recognised at Paragraph 72 of the National Planning Policy Framework. However, over-emphasis on the delivery of strategic allocations to a housing supply opens the spatial strategy up to possible impacts to the established housing trajectory due to likely delays related to the complex delivery mechanisms of strategic allocations. Therefore, it is more appropriate for a spatial strategy to encompass multiple development and delivery options to ensure that the residential requirement is satisfied, and delivery is maintained consistently over the new Plan period. Summary of Comments: Dispersal of development to villages is the preferable option, but it must form part of a comprehensive strategy including other development options.

Southern & Regional Developments (Joscelyn) 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 through 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.