Greater Cambridge Local Plan Issues & Options 2020

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

Southern and Regional Developments (Cottenham) 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.

Southern & Regional Developments (Willingham have concerns regarding the densification of development and question whether it provides a sustainable route to achieving an increase in residential quantum without the loss of existing undeveloped or greenfield land. It should be noted that although the National Planning Policy Framework supports efforts in improving the efficiency and use of land, this can pose practical challenges which reduces the viability and deliverability of this approach. This includes resolving 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 that is larger in scale and bulk, which can have greater impact on local amenity and 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 will 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 to infrastructure. Increases in density requires consideration of capacities of certain areas of infrastructure, including public transport provision, schools and clinical services. Increases in population through the provision of enhanced density therefore need to be met with expansion of infrastructure and the service base that these provide. Summary of Comments: Densification can contribute towards achieving a high level of sustainable development, but should complement other elements of a spatial strategy

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

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. 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 (Willingham) site at Priest Lane, Willingham which provides a further option to achieve sustainable development. Although it is not constrained by Green Belt, it should be considered an alternative route to achieve requisite levels of growth. It is emphasised that all options to achieve a robust spatial strategy should be considered, including the review of sites in the Green Belt at Cambridge city and the villages, as well as non-Green Belt sites located within the villages of South Cambridgeshire. The review of Green Belt sites at the edge of Cambridge 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 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 and on the edge of villages in South Cambridgeshire given that the development at these locations will not result in significant sprawl or urbanisation. Summary of Comments: All options to achieve a robust spatial strategy should be considered including sites within the Green Belt as well as non Green Belt sites in village.

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 Northstowe. The allocation of the new town at Northstow will deliver strategically significant numbers of new homes to meet the needs of the District and this approach is recognised as forming part of the comprehensive spatial strategy of the new Plan. However, it is considered that the inclusion of new settlements as strategic opportunities to achieve substantial housing numbers should not prejudice other sources of housing from other elements of the spatial strategy. The National Planning Policy Framework provides the basis as to how Local Planning Authorities should approach identifying the realisation of new settlements at paragraph 72 where it states that; "The supply of large numbers of new homes can often be best achieved through the planning of larger scale development, such as new settlements […]." However, it also asserts that elsewhere in the Framework, specifically at paragraph 68, that the identification of smaller sites is vital to ensure a robust housing delivery that can maintain a consistent residential supply. On behalf of Southern & Regional Dvelopments (Willingham), it is considered that the new Plan should not provide inappropriate emphasis on allocation of new settlements or the delivery of those already identified. Their complexity, such as multiple land interests and provision of infrastructure can result in significant delay in implementation 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.

Southern and Regional Developments (Willingham) consider that the adopted spatial strategy of the South Cambridgeshire Local Plan appropriately recognises the opportunity and potential that exists at the villages of the District to accommodate strategically significant numbers of housing 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 smaller villages, have been recognised through the adopted Local Plan as being less sustainable locations for development and therefore not preferable to accommodate new growth. However, there remains other rural settlements that can demonstrate enhanced sustainability credentials which are established in the South Cambridgeshire Plan as Rural Centres and Minor Rural Centres. Willingham is regarded as a Minor Rural Centre in the adopted settlement hierarchy and is a preferable and suitable location to accommodate new residential allocations. The village itself benefits from an established service base that is within walking distance from the site. These include a primary school, public houses and medical centre which demonstrate that the village provides a significant range of facilities that reduces the need to travel out of the village to source such services. Furthermore, the village benefits from bus links into Cambridge as well as connections to other settlements in the wider area. This should be recognised within the emerging Local Plan, specifically the spatial strategy that needs to re-assess the status of these villages as sustainable and suitable settlements to accommodate moderate levels of residential growth. It is maintained 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. The consideration of the development dispersal to the villages should be included within the Plan preparation process, given the historical success in this approach. Summary of Comments: Southern and Regional Developments support a strategy in dispersing development to the villages.

It is considered that the settlement hierarchy for the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Local Plan. Southern and Regional Developments (Willingham) believe that Willingham is inappropriately placed within the second tier of the adopted settlement hierarchy, which establishes the village as with lesser sustainability credentials than those placed in the top hierarchical tier. Willingham's current position within the adopted spatial hierarchy undermines the suitability of the village to accommodate moderate levels of residential development. It benefits from an established service base and is located within reasonable catchment of higher level services, such as secondary schools, within nearby villages. The site at Priest Lane also benefits from being within walking distance of a number of amenities within the settlement, including a medical practice and primary school which supports the suitability and sustainability and of the site and so its consideration for residential allocation. It is important to note that whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, the emerging Local Plan should avoid applying inappropriate reliance on the delivery of these 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 NPPF emphasises 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. Such sites can more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as at that identified at Priest Lane, Willingham. The delivery of such suitable sites should be encouraged through the strategy of the plan by affording a development quantum toward sustainable village. This policy requirement would required the development framework extents to be revised and the necessary market and affordable homes provided. It is essential for the emerging plan to requires such a review of village settlement limits, particualrly where they do not relate to Green Belt revision. Summary of Comments: A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

Southern & Regional Developments (Willingham) require a review of all spatial options included in the emerging Greater Cambridge Local Plan to ensure that needs of the new Plan period can be met. 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, which will result in the Councils from being vulnerable to speculative development which deviates 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, including further provision of development at Willingham. 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. Given that there is land located outside of the Green Belt at sustainable settlements such as Willingham, 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 site at Priest Lane, Willingham demonstrate a reasonable and sustainable approach to strategic development. The site at Willingham is located within walking distance to a range of services that are established within the village, including a primary school as well as benefitting from access to public transport provision which provides linkages to nearby secondary schools at adjacent settlements and to Cambridge. 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.

Nothing chosen

Southern and Regional Developments (Willingham) consider 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. Accordingly, a flexible approach to development should be applied to the most sustainable settlement. The site controlled by Southern and Regional Developments (Willingham) at Priest Lane, Willingham 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. It demonstrates the criteria needed to be a suitable and preferable location for growth, benefitting from walking distance to local services within the village and is unconstrained by local or national designations. Currently, given the derelict nature of the site it detrimentally harms the visual amenity of this edge of village location. The land houses a number of horticultural structures which do not positively contribute to the local character and affect the open setting of the countryside. Development of the site will materially enhance the aesthetic of the area and provide an appropriate transitional character between the settlement edge in the west, to the Fen-edge landscape of the countryside to the east. A spatial strategy which considers development at the edge of villages should ensure that it maximises sustainable development opportunities. It is considered that sites such as at Priest Lane, Willingham 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.