Greater Cambridge Local Plan Issues & Options 2020

Southern and Regional Developments (Waterbeach) consider the inclusion of the safeguarded site at Cambridge Airport within the emerging spatial strategy 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. Although development of the site would provide a significant boost in housing numbers on a site that would 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 for 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.

Greater Cambridge has experienced a high level of employment growth and the Cambridgeshire and Peterborough Independent Economic Review (CPIER) has shown that this growth has been faster than previously forecast. Accordingly, this will have significant pressure on the need to increase housing within Greater Cambridge. It is considered that exceptional circumstances exist to demonstrate Green Belt release. However, Greater Cambridge must be confident that they are releasing the most appropriate Green Belt across the area. The need to be confident that releasing Green Belt at the fringes of Cambridge city is appropriate. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving development outside the Green Belt. This should include other locations within the Green Belt that demonstrate lesser sensitivity than those locations at the urban-rural fringe, where the purpose of checking sprawl is demonstrably at its most significant. It is considered that the Local Plan should look to alternative locations within the Green Belt before assessing those sites to the outskirts of Cambridge. This includes sites such as that under the control of Southern and Regional Developments (Waterbeach) at Bannold Road, Waterbeach. This site falls within the Green Belt and is located to the eastern settlement limits of the village. It is well enclosed by built form of the settlement to the west, the Fen Line railway which forms its eastern boundary and highways which abut the site to the north and south. In this case, the release of the site from the Green Belt would not result in harm to the wider purposes of the Green Belt around Waterbeach, given that these enclosing elements can be utilised to produce tangible and defensible new boundaries to the Green Belt. As such, Green Belt sites beyond the edges of the South Cambridgeshire villages should be considered first before releasing sites at the fringes of Cambridge. These sites will certainly result in the sprawl of the urban form of the city and thus encroachment into the countryside that surrounds the city. This directly contravenes the fundamental purposes of the Green Belt as identified at paragraphs 134a and 134c of the National Planning Policy Framework. Given that it has been demonstrated that alternative opportunities exist elsewhere in the Plan area to secure more sensitive Green Belt release that will not contravene the fundamental requirements of it has recognised in national guidance. Summary of Comments: More suitable, alternative Green Belt sites exist for release that are more appropriate for the emerging Local Plan's consideration.

Given the historical success in the provision of new settlements in South Cambridgeshire, such as Cambourne, it is considered that the emerging Greater Cambridge Local Plan should capitalise on this experience and implement it through the new spatial strategy. Furthermore, as strategic allocations have been established at Northstowe and Waterbeach, it would be logical for these to be continued through into the new spatial strategy for the wider plan area. 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 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.

The adopted spatial strategy of the South Cambridgeshire Local Plan appropriately recognises the opportunity and potential that exists within the villages of the District to accommodate strategically significant numbers of housing which can make a material impact on meeting the residential need of the 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, contribute substantial numbers to meet the objectively identified needs of the Local Plan area. There are a number of sustainable and suitable villages within the Plan area identified in the recently adopted South Cambridgeshire Local Plan as Minor Rural Centres and Rural Centres. These include Waterbeach, established as a Minor Rural Centre in adopted policy, that is considered a sustainable location for development. It is Southern and Regional Development's (Waterbeach) position that Waterbeach could indeed accommodate further growth into the new Plan period and that its position within current policy does not reflect the true sustainability credentials of the settlement. The presence of a mainline railway station and delivery of a strategic allocation, which will include significant provision of new services, will contribute towards boosting the overall sustainability of the village and in turn, the suitability of the village to accommodate new residential development. This should be recognised in the emerging Local Plan and its new spatial strategy, specifically regarding Waterbeach, but also as a comprehensive re-assessment of the suitability of the other village settlements in the Plan area and their respective capacities. 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. Summary of Comments: Southern and Regional Developments strongly support a strategy in dispersing development to the villages.

Achieving development along transport corridors is a sustainable approach to development that complies with the guidance asserted in the National Planning Policy Framework. Directing growth towards these transport corridors encourages uptake of public transport over and above the use of private cars, which aids in reducing carbon emissions, improves air quality and alleviates highway congestion. Whilst not directly referenced by the Framework to implement housing development, it does however stress that where it is recognised that an area benefits from high levels of accessibility by way of public transport, Authorities are encouraged to seek increased densities. This should be interpreted so that higher residential densities should be achieved towards locations, such as transport corridors, which demonstrate good accessibility to public transport. Implementation of development at these locations should be regarded as sustainable development given that they will be less reliant on the use of heavily polluting private cars. Settlements located on transport corridors are sustainable locations for development within the new Plan period given that they are able to demonstrate better accessibility to public transport, encouraging shift away from use of private cars. Waterbeach is such a settlement which should be considered as an appropriate location for new growth given that it benefits from access to a mainline train station positioned on the Fen Line between Cambridge and Ely. This allows residents to access the rapidly expanding jobs market in Cambridge via public transport, rather than reaching it by car, which is considered to be a sustainable approach to commuter travel. Such means of access to employment should be encouraged and therefore directing new development towards these locations demonstrates a sound and appropriate strategy that needs to be incorporated into the emerging spatial strategy. The appropriateness of Waterbeach as a location for development is further reinforced by the strategic allocation made at the former RAF land to the north of the original village. Whilst the strategy includes relocation of the existing railway station to better serve the strategic growth area, the basis for this allocation recognises the benefits of the rail station in supporting such a degree of growth at the settlement. Whilst this strategic direction establishes the benefits of the rail station in terms of boosting the sustainability credentials of Waterbeach, it does not necessarily preclude other options for growth the village. It is considered that the land under the control of Southern and Regional Developments (Waterbeach) at Bannold Road, Waterbeach represents an opportunity to secure sustainable residential development that is able to complement the new town coming forward at the village. Given that strategic allocations have long lead-in times as a result of complex delivery requirements and infrastructure provision, smaller more rapidly deliverable sites should be identified to ensure the maintenance of a robust housing supply. The site at Bannold Road, Waterbeach is of a size that can demonstrate rapid lead-in and construction time and therefore support housing delivery at the settlement which has been recognised as an appropriate and sustainable location to achieve new housing growth. As such, by considering development at transport corridors, the emerging spatial strategy will be able to implement a robust approach that ensures that the objective identified need can be met. Summary of Comments: Identifying sites for development at transport corridors is a sustainable approach and should be considered for the new spatial strategy.

It is considered that the settlement hierarchy of the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Plan. Southern and Regional Developments (Waterbeach) believe that Waterbeach is inappropriately placed in the second tier of the hierarchy, which establishes that it is has lesser sustainability credentials than those villages placed in the highest tier. This downplays the impact that the railway station has on the accessibility of the village to public transport as well as the potential new services that will be delivered as part of the strategic New Town development. The emerging Greater Cambridge Plan therefore should review the position of Waterbeach within the settlement hierarchy and it is recommended that the settlement should be moved up within it, to better recognise that the village is a sustainable location for development. It is considered that if Waterbeach's position within the hierarchy is reviewed, it will allow suitable and appropriate opportunities to come forward at the village for residential development. This includes the site at Bannold Road, Waterbeach which is under control by Southern and Regional Developments (Waterbeach). Currently, the development potential of the site is limited by policy designations, including Green Belt, open countryside and the spatial strategy. However, if the Plan is to robustly review the new spatial strategy, including securing suitable and deliverable sites at sustainable settlement such as Waterbeach, a comprehensive re-assessment is required. Summary of Comments: A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

A review of all spatial options into include in the emerging Greater Cambridge Local Plan is required 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. The release of land from the Green Belt should also be a significant consideration of the emerging Greater Cambridge Plan. It is maintained that there are sites within the Green Belt that exist which do not contribute towards its wider strategic function. This includes the land at Bannold Road, Waterbeach which is a Green Belt site that is well enclosed by strong boundary features and therefore, its release from the Green Belt would not result in detrimental or significant impacts to it. The site is a sustainable location of growth which is able to capitalise on the strong accessibility credentials of the village as established by the train station, as well as the potential of new services being delivered nearby within the Waterbeach New Town strategic allocation. Opportunities such as the site at Bannold Road must be a consideration of the preparation of the new Plan, without any review of the Green Belt, such appropriate development opportunities will be missed and not contribute towards meeting the strategic need of the new Plan period. Given the significant development and housing pressures that are being experienced in the area, the emerging Plan cannot afford to inappropriately omit such deliverable and suitable strategies that can help achieve the objectives of the new Plan. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including review of the Cambridge Green Belt.

Nothing chosen

Southern & Regional Developments (Waterbeach) express caution in relation to the application of higher levels of design standards and construction requirements through development management policies. their concerns is that such requirements will result in restrictions that will impact on viability and deliverability of development within the Plan area at this time. 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.

Very important

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 (Waterbeach) 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. 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 (Waterbeach). As such 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.