Greater Cambridge Local Plan Issues & Options 2020

Southern and Regional Developments(Joscelyn) 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 occupation by a thriving local business that has been resident on the site for an established 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 site could provide a significant boost in housing numbers on a site that would not harm the Green Belt, given there is no certainty attached to when it will become available, 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.

Agree

Southern and Regional Developments (Cottenham) 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 and covers the minimum time frame. The timescale of any plan should however alsoo respond to long-term requirements and opportunities including major improvements to infrastructure 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 this proposed plan period so that a sustainable strategic approach is adopted that has longevity. This is demonstrated by the strategic plan 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 associated strategic 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 adopts. 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 Swavesey must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site to the north east of Cottenham can demonstrate this important contribution to assist in meeting the demanding housing needs for Greater Cambridge. 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

Southern & Regional development (Cottenham) identifies that it is essential for a Local Plan to demonstrate that it has discharged its statutory Duty to Co-Operate with neighbouring authorities and other relevant organisations to ensure that it is sound. Without due consideration of cross-boundary issues, including housing requirements and economic functions, a Plan will not have demonstrated its requirements as contained within the Duty to Co-Operate. Although the Greater Cambridge Local Plan is at an early stage of its preparation, it is vital that is able to demonstrate that it has taken into appropriate consideration cross-boundary issues. These issues will influence the strategies of the new Plan, including the approach in achieving residential and other types of development across the Local Plan area. Those issues which have been identified within the Issues and Options document address significant considerations which will inform the trajectory of the Plan during the preparation process. It is considered that those areas of concern relating to cross-boundary factors are appropriate. Although it is recognised that the Cambridge HMA is relatively self-contained, with a travel to work area similar in size and pattern to the housing market area itself, this should not result in a Plan which reduces the significance in cross-boundary impacts on the ability of the Planning Authorities in delivering their housing needs. For instance, given that the neighbouring Authorities are generally unconstrained, with no Green Belt, it is likely that they will be able to meet their own needs within their own jurisdiction. As such, there may be lesser need for Greater Cambridge to assist in accommodating cross-boundary housing numbers. However, it is considered that the emerging Local Plan must take into account the impacts that a rapidly growing local economy will have on these cross-boundary issues. This includes the influence of strategic infrastructure projects, such as East-West Rail and the Oxford-Cambridge Expressway which will open the housing market up further to additional influxes of people commuting to the expanding job market within Cambridge. This in turn will have a material impact on strategic residential need as a result of increasing demand and exacerbate housing costs. A careful approach to cross-boundary considerations is therefore required, to ensure that the new Plan remains responsive to these issues given that they arise from outside the Local Plan area and are beyond the control of the Local Authorities. Summary of Comments: The list of cross-boundary considerations is appropriate, however the Local Plan should acknowledge the degree of importance and significance to each.

Nothing chosen

Southern & Regional Developments (Cottenham) 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 not considered 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 satisfied 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. Southern & Regional Developments (Cottenham) consider 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. The big themes do not provide the correct balance between the elements of sustainable development, with inappropriate emphasis on climate change.

As has been explored by Southern & Regional Developments (Cottenham) in their response to Question 6, the Plan does not provide an appropriate approach to the identified big themes with a clear emphasis provided towards achieving environmentally sustainable development. This results in weight attached to objectives focussed on climate change and the natural environment which reduces the Plan's ability to ensure development that meets the other requirements of the Plan, such as the quantum of residential development implemented in the correct locations. It is considered that although the themes of "Climate Change" and "Biodiversity and Green Spaces" should be important issues that need to be addressed through the new Local Plan, these should not preclude the ability of the Plan in engaging with the other big issues. Furthermore, by prioritising these themes into a hierarchy does not aid the Plan is recognising which issues are the most significant in combating. As currently drafted the Plan establishes an approach which automatically quashes the significance of some themes in favour of others. If the Plan wishes to inappropriately prioritise its objectives, it is considered that the big themes should be categorised as follows: 1. Wellbeing and Social Inclusion 2. Great Places 3. Climate Change 4. Biodiversity and Green Spaces It is maintained that the above themes are interlinked. For example, achieving development that combats Climate Change should include strategies to enhance biodiversity and provide open space as part of a sustainable approach. It is considered that, by categorising these themes into a hierarchy, this undermines this interconnectivity and simplifies the circumstances which the Plan looks to engage with. Summary of Comments: 1. Wellbeing and Social Inclusion, 2. Great Places, 3. Climate Change, 4. Biodiversity and Green Spaces.

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Southern & regional Developments (Cottenham) believe that achieving net zero carbon emissions as an objective of the plan is an ambitious goal which does comply with paragraph 16a of the National Planning Policy Framework's assertion that Plan-making should be ambitious. However, the NPPF also stresses that with this aspiration, Plan-making should be deliverable. Given the cost and complexities involved in achieving such a target, Southern & Regional Developments (Cottenham) consider that this is not a realistic objective over the life time of the Plan alone, particularly given the proposed timeframe that is until 2040, not 2050. Whilst the Plan should incorporate aspirational efforts in realising a net zero carbon Plan area, these efforts should not be to the detriment to the existing communities with Plan area and not to the other aspects of the Plan in ensuring sustainable development is achieved. As such, the requisite levels of development must be planned for and implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land are implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions beyond the plan period, when infrastructure is to be delivered and standards beyond national requirements may give rise to issues of viability and deliverability if restrictive planning policies relating to this objective are applied. Summary of Comments: This objective must ensure that it is deliverable and does not prevent the Plan from engaging with its other requirements, such as housing delivery.

Nothing chosen

Southern & Regional Developments (Cottenham) expresses 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 supression of the delivery of growth.

Response to Question 2 Claremont Planning are instructed on behalf of Southern and Regional Developments (Cottenham to promote a site to the north east of Cottenham. The site was submitted to South Cambridgeshire District Council through the "Call for Sites" process in Spring 2019 and a revision to the site extenet has been made to facilitat the site's consdieration by the Council. The submission to the Issues and Options Consultation reflects the land promoted a comprehensive extension to Cottenham. The site is available, suitable and viable for residential development and can contribute towards the housing supply of the new Local Plan area. The site is located towards the northern and eaterns limits of Cottenham, within walking distance of the main services located within the village, including the primary school, secondary school, pharmacy and retail outlets. This established and wide service base available in the village reflects its position within the adopted settlement hierarchy of the South Cambridgeshire Local Plan. It asserts Cottenham as a top tier settlement, a Rural Centre and therefore represents one of the most sustainable locations within the District for development and growth. As such, the identified site to the north east of Cottenham should be considered postively against this context, given its location within one of the most appropriate villages of the Local Plan area for new development. This should be appropriately reflected within the emerging spatial strategy as a village that is able to accommodate new levels of development over the new Plan period and materially contribute towards meeting the identified strategic need of the emerging Greater Cambridge Local Plan. The promoted site, to the north of east of Cottenham extends over an area approximately 13.1ha in size and is currently laid to pasture. The site is partially bound to the east by Broad Lane and the rear of private properties off Kingfisher Way, open to farmland and Lode Farm in the norh and south west. In the south, the site's boundary is formed by the curtilages of residential dwellings. It is considered that the site can provide an appropriate and suitable location to achieve new residential growth at Cottenham, which responding to its immediate context through the provision of landscape buffers, drainage regimes and appropriate linkages to establish a coherent extension to the village. In November 2019 Claremont Planning submitted further information to the Councils regarding the suitability of the site and its influence by flood waters. Reference to the EA Flood Map for Planning identifies that the Site lies predominantly within ‘Defended’ Flood Zone 3, with a small localised area identified to be in Flood Zone 2 and the remainder identified to be Flood Zone 1. There are Formal Flood Defences forming the banks of the Cottenham Lode. Southern & Regional (Cottenham) have employed WSP to review the flood environment to the northeast of Cottenham. WSP carried out investigations in accordance with best practice, actively consultating with the Environment Agency (EA) in regard to the potential fluvial flood risk to the Site. Through acceptance of a Model Scoping Note it was agreed with the EA to undertake a site-specific modelling study to enhance understanding of the potential fluvial flood risk. Based on the site-specific hydraulic modelling, the respective EA Flood Zones, assuming these to be equivalent to the 1 in 100 Year and 1 in 1000 Year ‘defended’ modelled extents across the site. The Site should be considered appropriate, in its entirety, for residential purposes in accordance with PPG and the NPPF. It is considered ‘best-practice’ to locate all development outside of the maximum extents of the 1 in 100 Year plus 35% Climate Change allowance. The site-specific hydraulic modelling in the 1 in 100 Year plus 35% Climate Change allowance for the ‘defended’ scenario demonstrates that the site north off kingfisher Way is fully developable. As such, the promoted site warrants consideration through the emerging plan. Through ongoing discussions with the Environment Agency the extent of the flood risk has been questioned and found to be exaggerated across the promoted lands. Otherwise, the site is unconstrained by any other environmental, statutory, local or historic designations.

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Southerrn & regional Developments (Cottenham) 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 locational 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. It is considered that 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 suitably amended. Southern & Regional Developments (Cottenham) 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 and should reflect the requirements as identifed in the latest SHMA.

Nothing chosen

Southern and Regional Developments (Cottenham) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options across the plan area and reduce travel distances within communities so reducing climate impacts. They support the direction established by 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 to the north east of Cottenham benefits from good access to social infrastructure, with close walking distance, with amenities to includes a medical clinic, secondary school, post office and village shop. As these are within close proximity to the site, it should be recognised that the site is a sustainable location to accommodate new development. Furthermore, the site is not designated Green Belt and so its development will not result in wider impacts or harm to the strategic purposes of it. As such, review of Green Belt sites alone will not go far enough in ensuring an adequate spatial strategy, given that there are suitable locations for development that exist beyond it and located in sustainable settlements that are able to and have the capacity to accommodate new development to meet the needs of the new Plan period. Summary of Comments: Releasing sites from Green Belt should be an element of wider and more comprehensive spatial strategy that includes other approaches.