Greater Cambridge Local Plan Issues & Options 2020

Achieving net zero carbon emissions as an objective of the plan is an ambitious goal which directly complies with paragraph 16a of the National Planning Policy Framework assertion that Plan-making should be ambitious. Southern and Regional Developments (Willingham) aspire to meet this approach but that it should not impact upon the Plan-making process, which should ensure the resulting policy approach is deliverable. Given the cost and complexities involved in achieving such a target, it is considered that this is not a realistic objective at this time and caveats are required to be included within any related policy that reflects this position. Whilst the Plan can incorporate aspirational efforts in realising a net zero carbon Plan area, this should not be to the detriment to the other aspects of the Plan in ensuring that the requisite levels of development are 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 is 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 given issues of viability and deliverability which may arise if such restrictive planning policies relating to this objective are applied in reality. 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 (Waterbeach) 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 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 environmental 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.

Wellbeing and Social Inclusion, Great Places, Climate Change, Biodiversity and Green Spaces

Response to Question 7 As has been explored in the 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: If your comments are longer than 100 words, please summarise the main issues raised. 1. Wellbeing and Social Inclusion, 2. Great Places, 3. Climate Change, 4. Biodiversity and Green Spaces.

Achieving net zero carbon emissions as an objective of the plan is an ambitious goal which directly complies with paragraph 16a of the National Planning Policy Framework assertion that Plan-making should be ambitious. However, it also stresses that with this aspiration, Plan-making should be deliverable and given the cost and complexities involved in achieving such a target, it is considered that this is not a realistic objective. Whilst the Plan can incorporate aspirational efforts in realising a net zero carbon Plan area, this should not be to the detriment to the other aspects of the Plan in ensuring that the requisite levels of development are 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 is 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 given issues of viability and deliverability which may arise if such restrictive planning policies relating to this objective are applied in reality. 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.

Response to Question 2 - Additional Information Claremont Planning are instructed on behalf of Southern and Regional Developments Ltd (Waterbeach) to promote their site at Bannold Road, Waterbeach for residential development. The site was put forward during the 'Call for Sites’ process in Spring 2019. The site is available, suitable and viable for residential development and can contribute towards the housing land supply of the Local Plan area. The site is located at the eastern edge of Waterbeach and is highly accessible in terms of walking distance to services within the village and also the mainline rail station that provides fast commuter links into Cambridge and London. Waterbeach is recognised as a suitable location to accommodate a new settlement, this reinforces the village in terms as a location for growth for residential and other forms of development to contribute towards meeting the identified need of Greater Cambridge. The site itself is approximately 14 ha in size and is well contained through boundary treatment. The site falls partly within the Green Belt and the review of the Local Plan provides the opportunity to review the Green Belt boundary so as to accommodate development opportunities in sustainable locations. The identification of the strategic allocation at Waterbeach New Town is a positive step in terms of the development plan in delivering the identified need of the wider District, but caution must be applied in terms of assurance and guarantee of delivery of such large sites. Paragraph 72 of NPPF recognises the value of strategic sites but emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that delivery of these sites remains practical in realising the housing trajectory. As such, the importance of small and medium sized sites must not be overlooked and the NPPF at paragraph 68 states that these sites can robustly contribute to housing numbers given the relatively rapid build out times. The site at Bannold Road can demonstrate this important contribution and assist in meeting the demanding housing needs for the District and Greater Cambridge. The site at Bannold Road, Waterbeach provides an opportunity to identify a location for sustainable development at a settlement that has been recognised as an appropriate location to accommodate a strategic New Town development. Attached to these representations is a 'Promotional Document' for the site that provides an overview of relevant planning policy, technical considerations and detailed information highlighting the credentials of the site as a suitable site to allocate for residential development. Summary of Comments: The site at Bannold Road, Waterbeach is an appropriate site in a sustainable location to allocate for residential development.

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Agree

On behalf of Southern & Regional Developments (Waterbeach) 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 coers 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. 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 Waterbeach must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Waterbeach can demonstrate such deliverability as an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. 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 site at Bannold Road, Waterbeach 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.

Yes

Southern and Regional Developments (Waterbeach) 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. 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. It is considered that given the significant pressures within Greater Cambridge to deliver a substantial number of homes in line with the economic growth experienced in the sub-region, there is a need to review the current extent of the Green Belt.The site at Bannold Road, Waterbeach, under the control of Southern and Regional Developments is a site that benefits from good levels of accessibility. Waterbeach is recognised as a Minor Rural Centre, a second tier settlement within the strategic hierarchy, it is considered that access to a mainline station in the village enhances its sustainability credentials in accommodating growth. Furthermore, given that much of the land at the fringe of the village is designated as Green Belt, the new Plan should review the status of this land in its suitability for release from it and to accommodate development. It is maintained that the land at Bannold Road, Waterbeach demonstrates such suitability given the beneficial access it experiences to the train station at the village, which provides important access to major job markets located a Cambridge North and Cambridge city. If the Plan does not robustly consider these options as deliverable components of the new spatial strategy, it is likely that the new Plan will be unable to identify sufficient suitable sites to meet the identified residential need for the new Plan period. Summary of Comments: Releasing Green Belt land at locations benefitting from public transport is supported and complies with the strategic objectives of the NPPF.

Nothing chosen

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. Accordingly, a flexible approach to development should be applied to the most sustainable settlements. It is maintained that the site controlled by Southern and Regional Developments (Waterbeach) at Bannold Road, Waterbeach represents a deliverable and appropriate example of an edge of village site that could be sensitively developed to contribute towards the strategic requirements of the new Local Plan. It demonstrates the criteria needed to be a suitable location for growth, benefitting from access to public transport links and a coherent relationship with the existing settlement edge. Furthermore, existing features such as the Fen Mainline that forms the eastern boundary of the site provides a defensible boundary that is able to reinforce the settlement, and Green Belt's, new edge. Characteristics such as these are significant considerations which contribute towards the appropriateness of such edge of settlement sites. Where features exist to contain developments at the fringes of villages, these can ensure that the perceived outward sprawl of the settlements can be enclosed by utilising these features. This conserves the landscape character and provides a sensitive approach to development which is particularly important where release of Green Belt is involved in such proposals. 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 Bannold Road, Waterbeach represent such opportunities and as such, 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.

Nothing chosen

It is advanced on behalf of Southern & Regional Developments (Waterbeach) 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.

It is considered that densification provides a sustainable route to achieving an increase in residential quantum without the loss of existing undeveloped or greenfield land. However, 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 complex ownership issues within tight urban environments which results in difficulties in land assembly to implement a coherent and viable scheme. Furthermore, actively increasing density results in the implementation of development that is 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 schemes as well as issues of viability given the high quality 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. It is recommended that whilst increasing densities may be appropriate in some urban locations this approach may not work in the more rural parts of Greater Cambridge including some of the village locations and Greater Cambridge should look to provide a range of densities to suit more sensitive locations across the plan area. Summary of Comments: Densification can contribute towards achieving a high level of sustainable development, but should complement other elements of a spatial strategy