Greater Cambridge Local Plan Issues & Options 2020

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It is considered that the Local Plan should be flexible towards development of both jobs and homes on the edge of villages. It is considered that the Local Planning Authority should be more flexible to the scale of development within the village framework and should allow a more 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 settlements. The site controlled by Southern and Regional Developments (Cottenham) to the north east of Cottenham represents a deliverable and appropriate example of an edge of village site that can be sensitively developed to contribute towards the strategic requirements of the new Local Plan. Cottenham is a higher order settlement within the settlement hierarchy that indicates that the village benefits from an extensive and established range of services and amenities. The site is not designated as Green Belt and offers a good opportunity to provide additional housing in a sustainable location. It is considered that an extensive landscape strategy can be adopted for the site which will contribute to the softening of the development edge. A spatial strategy which considers development at the edge of villages should ensure that it maximises sustainable development opportunities. It is considered that site to the north east of Cottenham represents such an opportunity. 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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It is advanced on behalf of Southern & Regional Developments (Cottenham) that the approach of the South Cambridgeshire Local Plan should 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.

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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 (Cottenham) 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 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. Southern & Regional Developments (Cottenham) 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 articfically 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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Southern and Regional Developments (Cottenham) consider 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 considered 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 needed to assure flexibility and to support the significant economic growth experienced in the Plan area.

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 (Cottenham) 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 (Cottenham) site to the north east of 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. Summary of Comments: Inclusion of new settlements is supported, but should not be considered a primary mechanism for housing delivery.

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.

Souther & Regional Developments (Cottenham) 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 to the north east of 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 to the north east of 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 (Cottenham) 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 Cottenham, 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 to the north east of Cottenham that is demonstrated as a reasonable and sustainable approach to strategic development. Consideration of sites at villages, such as the site to the north east of Cottenham demonstrate a reasonable and sustainable approach to strategic development. The site to the north east of 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.