Greater Cambridge Local Plan Issues & Options 2020

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It is advanced on behalf of Southern & Regional Developments (Willingham) 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 accetpableat such villages is not considered to be compliant with the National Planning Policy Framework's assertion to achieve 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, particularly 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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Southern & Regional Developments (Willingham) 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 could impact on viability at this time 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.

Southern & Regional Developments (Willingham) recognsies that it is a statutory requirement for Local Plans to address the housing requirements for their local plan areas and tht this needs to influence the emerging plan. 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. 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 also needs to engage with a deliverable spatial strategy which can provide the basis for the growth that is required to meet this 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 however will need to consider all options in terms of locations for new development. Given that the Greater Cambridge area includes vastly different spatial characteristics, including dense urban landscapes to rural village locations, the spatial strategy will need to take this into account when it reviews the spatial options for development. It is considered that no single spatial option represents the most appropriate approach and therefore, the Plan should adopt a flexible approach to its emerging spatial strategy, by not precluding any possible avenues at this early stage. Claremont Planning recognises that large quantums of development for housing and employment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge, but the importance of sustaining existing communities in smaller sustainable developments is advanced as a key consideration on behalf of Southern & Regional Developments (Willingham). As such the strategy should seek to provide development opportunities at smaller settlements where growth can be accommodated through amendment to settlement boundaries and 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 (Willingham) consider that the emerging Greater Cambridge Local Plan must plan for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review ('CPIER') 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 planning for 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 degree of flexibility that will otherwise not be available if the Plan allows for a minimum number. Given the evidence that is available, it would not be an appropriate or sound approach if the Plan were to not plan for a higher number of homes than the government figure suggests. 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 number, as it asserted in the NPPF. If the Plan is to support this economic growth through the new Plan period, a higher housing quantum will be needed to be incorporated into strategic policy. If insufficient homes are delivered over the new period, this will supress any potential for economic growth within the Plan area and result in diminishing the expansion of the jobs market in Cambridge and South Cambridgeshire. Summary of Comments: Higher quantum of housing is need to assure flexibility and to support the significant economic growth experienced in the Plan area.

Southern & Regional Developments (Willingham) identify that it is crucial for the delivery of housing, particularly bedroom size and tenure mix, to reflect 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. Southern & Regional Developments (Willingham) consider 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 (Willingham) 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.

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Southern and Regional Developments (Willingham) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options such as reducing travel distances and thereby reducing climate impacts. 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. Releasing sites from Green Belt should be an element of wider and more comprehensive spatial strategy that includes other approaches. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the site at Priest Lane, Willingham, benefits from access to social infrastructure, which includes amenities such as a primary school and medical centre. These are within walking distance from the site and therefore should be recognised as demonstrating a sustainable location for new development. Furthermore, the Priest Lane 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.

Southern & Regional Developments (Willingham) agree that the Local Planning Authority have a duty to involve and consult with the community including local residents, businesses, interest groups and landowners in the formation of policies that will shape the Local Plan for Greater Cambridge. This is asserted at Paragraph 16c of the National Planning Policy Framework where it states that Plans should; "be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees." It is considered important to ensure that Local Plan documents including background information is easily accessible on the Council's website and it would be helpful if e-mail alerts were provided to Planning Consultants and Developers to make them aware of when each stage of the Plan is available for comment. It is important the Council ensures that the ongoing Plan preparation process is open and accessible to all, identifying the most appropriate times for public commentary which will provide significant local insight to the Plan process and practical requirements for local communities. Summary of Comments: Preparation of the emerging Local Plan must ensure accessibility for all and provide means of commentary throughout the process.

Response to Question 2 Claremont Planning are instructed on behalf of Southern and Regional Developments (Willingham) to promote land south oft Priest Lane, Willingham for residential development to the Greater Cambridge Local Plan Issues and Options Consultation. The site has been previously submitted to South Cambridgeshire District Council to the "Call for Sites" exercise in Spring 2019. The site is available, suitable and viable for residential development which can robustly contribute towards the housing supply of the new Local Plan area. The Priest Lane site is located towards the eastern fringe of Willingham and is highly accessible in terms of walking distances to services available in the village, including a primary school and medical practice. These services and facilities confirm the sustainability of the settlement that should be recognised through the emerging Local Plan. It is considered that this service base reinforces the suitability of the site for residential development and demonstrates that Willingham is a sustainable location to accommodate new levels of growth into the new Plan period. Extending over an area of approximately 3.4ha, the site is laid to grassland with established hedgerow boundaries, woodland. The site also accommodates a number of greenhouses and other horticultural structures which indicates the historical use of the land as a nursery. The nursery is now closed, which detracts from the visual amenity of the village with particular impact on the transitional character at the settlement fringe. The Priest Lane site is not designated as Green Belt and is located beyond the eastern boundary of the Willingham Conservation Area, with no other heritage assets within consideration distance of the site. Topographically, the site is flat with no gradients of note and is unaffected by fluvial or surface water flood risk. The site has a robust relationship with the settlement edge and is situated in a sustainable location that is unconstrained by environmental, historic or other statutory designations. The site's development for residential purposes would represent a moderate extension to the settlement and would assist in meeting the housing needs for the Plan area. Attached to these representations is a site plan demonstrating the site extent and location at the eastern fringe of Willingham. The site at Priest Lane provides an appropriate and sustainable opportunity to secure residential allocation that is able to support the needs of Willingham as well as provide strategic contribution to the housing requirements of the new Plan period. Summary of Comments: The Priest Lane site is suitable and appropriate site in a sustainable settlement that is appropriate for expansion for residential development.

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On behalf of Southern & Regional Developments (Willingham) 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 at Priest Lane - Willingham provides an assurance of deliverability and would make an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. 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.

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Southern & Regional Developments (Willingham) seek for the emerging Local Plan to identify the strategic issues which will affect the plan area for 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 satified 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. It is considered 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. Summary of Comments: The big themes do not provide the correct balance between the elements of sustainable development, with inappropriate emphasis on climate change.