Greater Cambridge Local Plan Issues & Options 2020

Yes, somewhat agree

Southern and Regional Developments (Waterbeach) 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 (Waterbeach) consider that it is important for the Plan to deliver a varied range of housing, particularly with respect to bedroom size and tenure mix that reflects 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 (Swavesey) 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. Claremont Planning 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 & Regionsal (swavesey) consider that a Local Plan must demonstrate that it has discharged its statutory Duty to Co-Operate with neighbouring authorities and other relevant organisations to ensure that it is sound. Without due consideration of cross-boundary issues, including housing requirements and economic functions, a Plan will not have demonstrated its requirements as contained within the Duty to Co-Operate. Although the Greater Cambridge Local Plan is at an early stage of its preparation, it is vital that is able to demonstrate that it has engaged and taken into appropriate consideration of cross-boundary issues. These issues should influence the strategies of the new Plan, including the approach in achieving residential and other types of development across the Local Plan area. Those issues which have been identified within the Issues and Options document address significant considerations that will inform the trajectory of the Plan during the preparation process. It is considered that the areas of concern relating to cross-boundary factors are appropriate. However, engagement with housing need and the cross-boundary influences that impact on this need should be strongly considered as a central component of the spatial strategy prepared as part of the new Greater Cambridge Local Plan. Although it is recognised that the Cambridge HMA is relatively self-contained, with a travel to work area similar in size and pattern to the housing market area itself, this should not result in a Plan which reduces the significance in cross-boundary impacts on the ability of the Planning Authorities in delivering their housing needs. For instance, given that the neighbouring Authorities are generally unconstrained, with no Green Belt, it is likely that they will be able to meet their own needs within their own jurisdiction. As such, there may be lesser need for Greater Cambridge to assist in accommodating cross-boundary housing numbers. However, it is considered that the emerging Local Plan must take into account the impacts that a rapidly growing local economy will have on these cross-boundary issues. This includes the result of strategic infrastructure projects, such as East-West Rail and the Oxford-Cambridge Expressway which will open the housing market up further to additional influxes of people commuting to the expanding job market within Cambridge. This in turn will have a material impact on strategic residential need as a result of increase demand and exacerbation of housing costs. A careful approach to cross-boundary considerations is therefore required, to ensure that the new Plan remains responsive to these issues given that they arise from outside the Local Plan area and are beyond the control of the Local Authorities. Summary of Comments: The list of cross-boundary considerations is appropriate, however the Local Plan should acknowledge the degree of importance and significance to each.

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Southern & Regional Developments (Swavesey) 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

Southern & Regional Developments (Swavesey) consider that 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: 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, Southern & Regional Developments (Swavesey) consider that this is not a realistic objective at this time. 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.

Southern & Regional Developments (Swavesey) consider 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 land onners, Agents, 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 - ADDITIONAL INFORMATION Claremont Planning are instructed on behalf of Southern and Regional Developments (Swavesey) to promote the Dairy Farm site at Boxworth End, Swavesey for residential development to the Greater Cambridge Issues and Options Consultation. Although the site was previously submitted to the Councils March 2019 Call for Sites exercise, Southern and Regional Developments (Swavesey) are now promoting the site so provide an update on site details to establish that the site as available, suitable and viable for residential development. Notwithstanding the promotion of the site through the Issues and Options Consultation, the site is also submitted to the Call for Sites exercise alongside this consultation. This is to ensure that the availability and suitability of the site is made as clear as possible to the Councils. THE SITE The Dairy Farm site is located towards the south of the village of Swavesey, within an area locally known as Boxworth End. Although the site is technically identified as outside the current village development framework it is located at the fringes of the settlement where development has been recently consented on the opposite side of the road. As such, it is considered that the site's context is already heavily influenced by existing built form to the north and south, demonstrating the location as being an edge of settlement site. New residential development has been approved on the opposite side of the road, which will further enclose the context. The site is situated in a highly accessible location, within walking distance of a number of amenities available in the village, including a medical clinic, secondary school, post office and village shop. It is considered that this service base reinforces the suitability of the site for residential development and demonstrates that Swavesey is a sustainable location to accommodate new levels of growth into the new Plan period. Extending over an area of approximately 4ha in size, the site is currently used for pastural farming purposes with a number of agricultural buildings (one of which has been converted to residential use), alongside the original farmhouse. The farmhouse and converted barn establish a residential presence on the site already, reinforcing the suitability of the site for consieration of a senstively designed development. To the north, the site's boundary is partly formed by residential curtilages of properties fronting Ramper Road, with the highway delineating the rest of the boundary. To the south, the site abuts Pine Grove and further residential properties along the Grove, which accomodates permanent static caravans and their related gardens. The easter boundary is open to pasture fields with clearly defined limits formed by mature hedgerows. Given the existing built form located to the north along Ramper Road and to the south at Pine Grove, it is considered that the site is well enclosed by development and so should be considered to provide a natural development extension at Boxworth End. The site would reflect the linear built pattern of Swavesey and deliver new built form coherently, which would be positioned sympathetically within the village. Although it is recognised that views along Boxworth End and Bucking Way Road offer glimpses across the site towards the Fens, it is maintained that through a considered layout and comprehensive landscaping scheme, such views could be preserved and enhanced. DEVELOPMENT POTENTIAL Southern and Regional Developments (Swavesey) maintain that the site represents an appropriate location for development. It is recognised that the western aspect of the site has been recognised locally as providing open views across the countryside, and although these are not identified by any statutory designation or development plan allocation they will be taken into account through the delivery of the site by providing a considered and sympathetic layout, incorporating green corridors and landscape zones to retain these visual aspects of the site. Planning permission S/1531/15/FL was granted at the dairy farm for the conversion of a number of the existing barns to a large dwelling with contemporary styling. This permission has been implemented on site and helps to establish the suitability of the location for further housing development. Demonstration of this is also established through the approval of two residential developments at Boxworth End, on the opposite side of Bucking Way Road to the site. These consents (S/1605/16/OL and S/1605/16/OL) identify the suitability of Swavesey to accommodate growth and the sustainability of the Boxworth End area. The related appeal decisions described the Boxworth End location as being within only a short distance of Swavesey’s facilities, whilst development would not give rise to notable harm to the countryside when the presumption in favour of sustainable development is applied. Planning permission S/3391/16/OL was also considered for residential development of the site, through which the location was assessed as being suitable to accommodate residential development with a sensitive layout capable of being achieved without an adverse impact on the character of the surrounding landscape, with the site’s suitable for housing considered to outweigh the limited harm that would arise in relation to the Important Countryside Frontage designation along the roadside frontage. No technical concerns were identified through this proposal’s consideration, with the Highway Authority, Ecology Officer, Environment Agency, Lead Local Flood Authority, Urban Design. District Landscape Officer and Planning Department considering the site as suitable to accommodate new homes. In relation to secondary school provision, an extension to increase capacity at the Village College by 150 pupils has been completed, as a result of an identified shortfall in capacity in 2012. Following other residential consents at Swavesey any development at the village would enable the expansion of the Village College further, which would assist in ensuring capacity over the extended plan period. It is Southern and Regional Developments (Swavesey) position that the approach to be taken by Greater Cambridge Councils should identify a spatial strategy that is comprehensive across all of the sustainable settlement tiers; considering a number of avenues to achieve the requisite levels of housing development. Swavesey’s settlement status as a Minor Rural Centre should be recognised through the allocation of further housing growth proportionate to the facilities it provides. Previous consideration of development proposals on the Dairy Farm site by South Cambs Council Planning Authority considered that the site was suitable for housing development. The Council considered that it was possible for an illustrative layout for 90 dwellings could be achieved without having an adverse impact on the character of the surrounding landscape, with the need for housing and site suitbaility considered to outweigh the limited harm that would arise in relation to the Important Countryside Frontage designation along the roadside frontage. Southern & Regional Developments (Swavesey) consdier that a lower density and scale of development is more appropriate, with a development of 50 dwellings considered most suited to addressing local affordable housing needs whilst refletingt the significance of Swavesey in the settlement hierarchy. None of the disbenefits arising through the site's development would result in significant and demonstrable harm and therefore, the site should be considered as a location that would acheive sustainable development as set out in the NPPF. Southern & Regional's proposals for the site will also involve a revised scale of density at a lower density than the previously considered scheme, further mitigating the impacts of built form on the local landscape setting. The lack of objection of the Council's Landscape Design Officer to the previous proposal and the pricniple of the site's development is demonstration of this. Any development of the site will incorproate design themes that are advanced by the Swavesey Design SPD, relating to the landscaping of the resulting residential development and the appearance of the dwellings. Summary of Comments: The Dairy Farm site , Swavesey is suitable and appropriate to extend a sustainable settlement that is appropriate for residential allocation.

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On behalf of Southern & Regional Developments (Swavesey) 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. 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 Boxworth End 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. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing for beyond this period too.

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 (Swavesey). 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 artifically 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.