Greater Cambridge Local Plan Issues & Options 2020

The land south of Old House Road in Balsham was promoted to the call for sites process in March 2019 on behalf of Endurance Estates. The representations to the Issues & Options consultation document will refer to that promoted site where relevant. Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. Although, in some instances, it should be acknowledged that net biodiversity gains would be more appropriately provided on alternative or existing sites rather than within a development site. It is suggested that the emerging GCLP should also include a policy mechanism that allows for net biodiversity gains to be delivered on alternative sites. For example, the emerging GCLP should identify suitable biodiversity projects across Greater Cambridge that development sites could make a biodiversity net gain contribution towards as an alternative to always providing on site. It is considered that in some circumstances a larger biodiversity net gain/ecological enhancement area would be more beneficial in preference to numerous smaller unconnected areas. A larger biodiversity/greenspace area would also be beneficial for recreation and health and wellbeing. A Preliminary Ecological Appraisal (prepared by Applied Ecology Ltd) has been undertaken for the site at land south of Old House Road in Balsham. The promoted development would include biodiversity measures and ecological enhancements. It would seek to retain, protect and enhance the existing hedgerows and trees on the site, or replace where removal is necessary. A lighting strategy will need to be prepared for the development in order to keep the hedgerows free from artificial lighting after dark. It would provide additional landscaping with native plants at peripheral areas of the site. It would incorporate bat and/or bird boxes into new buildings. Therefore, the promoted development would achieve a net gain in biodiversity.

It is considered that meeting housing and affordable housing needs is part of the well-being and social inclusion theme because housing falls within the social objective of sustainable development (as set out in Paragraph 8 of the NPPF). There are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer commuting. Paragraph 8 and Chapter 8 of the NPPF identifies the other factors that relate to the wellbeing and social inclusion theme, which are about creating well-designed and safe developments, providing access to services and facilities, and providing open space. It is suggested that to achieve ‘good growth’ the emerging GCLP will need to allocate suitable sites that deliver housing and affordable housing, are accessible to services and facilities, support existing communities in rural areas and include open space and recreation facilities. The promoted development at land south of Old House Road in Balsham includes market and affordable housing, and open space. The site is accessible to the services and facilities within Balsham by walking and cycling. It has been acknowledged at appeal that Balsham contains a level of services and facilities that evidences development in the village would be sustainable. The promoted development at land south of Old House Road in Balsham could support the existing services and facilities within the village and maintain its vitality and viability, which is consistent with Paragraph 78 of the NPPF. It is considered that the promoted development would contribute towards ‘good growth’ of Greater Cambridge.

Section 4.3.3 of the Issues & Options consultation document identifies the factors that are relevant to the creation of safe and inclusive communities. As set out in the response to Question 16, there are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer commuting. It is considered that the emerging GCLP should include a development strategy that seeks to meet housing and affordable housing needs and locate housing closer to employment opportunities to reduce in-commuting. Paragraph 61 of the NPPF expects a wide range of house types, sizes and tenures to be provided to meet a variety of housing needs including the full range of affordable housing tenures as defined in the Annex 2 Glossary of the NPPF. The promoted development at land south of Old House Road in Balsham would provide housing and affordable housing, and the site is accessible to employment opportunities.

Paragraph 91 of the NPPF seeks to deliver healthy, inclusive and safe places, and identifies a number of approaches to support healthy lifestyles. It promotes social interaction through mixed-use developments, strong neighbourhood centres, street layouts that include pedestrian and cycle connections, and active street frontages for example. It enables and supports healthy lifestyles, by providing green infrastructure, sports facilities, local shops, access to healthier food, allotments, and layouts that encourage walking and cycling for example. NHS England Healthy Towns Initiatives identified ten principles to deliver healthy places, which relate to the provision of health services, meeting local and community health needs, and development design matters. In terms of design matters it is suggested that compact neighbourhoods, active travel, healthy eating opportunities, play and leisure facilities would contribute towards the delivery of healthy places. It is considered that the promoted development at land south of Old House Road in Balsham would be consistent with guidance and initiatives to support healthy lifestyles. As set out the call for sites submission, the promoted development would include two areas of open space. The site is also is accessible to the services and facilities within Balsham by walking and cycling, including the playing fields.

The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs, and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: there is a growth strategy in place to promote and facilitate additional growth; strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and, an authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. In addition, it should be noted that Paragraph 61 of the NPPF expects affordable housing needs to be met. Paragraph 68 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. On this basis, the emerging GCLP should facilitate the delivery of the right homes in the right places. Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met. It is requested that housing needs should be met in the emerging GCLP by allocating sites in a variety of locations including the villages, of a variety of sizes including small and medium sized sites, and on sites where policy compliant levels of affordable housing can be provided.

Yes, strongly agree

Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. A Greater Housing Delivery Study (prepared by Barton Willmore on behalf of Endurance Estates) identifies the housing requirements for Greater Cambridge for the period to 2040 and implications for the future distribution of housing. The Study highlights the findings of the Cambridgeshire and Peterborough Independent Economic Review 2018 (CPIER) which demonstrate the imbalance between employment growth and housing delivery. Barton Willmore support, as a minimum, the indicative housing requirement figure for Greater Cambridge derived from the CPIER which is a total of 66,700 dwellings between 2017 to 2040, which equates to approximately 2,900 dwellings per annum. The Study also includes analysis of housing delivery, existing allocations and commitments and potential strategic allocations to inform how and where the housing requirements should be distributed.

Paragraph 61 of NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. It is noted that the existing and planned new settlements in South Cambridgeshire and some of the strategic sites are not delivering policy compliant levels of affordable housing. As such, it is considered that emerging GCLP should seek to allocate sites which are capable of delivering policy compliant levels of affordable housing. The promoted development at land south of Old House Road in Balsham would include market and affordable housing. It would provide affordable housing to meet local needs of the village; in 2018 there was an identified need for 32 affordable dwellings in Balsham for those with a local connection to the village – see South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2018).

Paragraph 103 of the NPPF seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. Therefore, the site selection process for potential allocations in emerging CGLP will be an important part of increasing travel by sustainable modes of transport. The promoted site at land south of Old House Road in Balsham is accessible by walking, cycling and public transport to the services and facilities within the village. Balsham is also on a bus route, with regular services to Haverhill and Linton and a daily service to Cambridge. Additional growth also has the potential to increase demand for public transport and therefore increase the level and quality of services provided.

Highly flexible

It is noted that the existing defined settlement boundaries for most villages in South Cambridgeshire have remained largely unchanged since the Local Plan 2004; although sites were allocated within and on the edge of some villages in the Site Specific Allocations DPD in 2010 and for the adopted South Cambridgeshire Local Plan 2018. It is very likely that most of the development opportunities within existing village boundaries would have been taken up by now. It is also likely that heritage assets within some villages, such as conservation areas and listed buildings, will constrain development opportunities. It is not clear whether the Councils have undertaken an assessment of the capacity of villages to accommodate additional development; it is likely that such an assessment would demonstrate that the capacity is limited. On the basis of the above, it is considered that the current site size threshold limits in the adopted South Cambridgeshire Local Plan 2018 are largely irrelevant and ineffective e.g. there are few outstanding development opportunities for up to 8 dwellings (or 15 dwellings on previously developed sites) within existing framework boundaries in Group Villages, and Balsham is an example where there are few opportunities within the boundary. In any event, there are numerous examples, including in Balsham, between 2014 and 2019 when planning applications were approved and appeals were allowed on sites within and on the edge of settlements that were contrary to the existing site size threshold limits. Paragraph 78 of the NPPF seeks to support sustainable development in rural areas. It is considered that additional development within and on the edge of villages to support the vitality and viability of those villages must be part of the strategy for the emerging GCLP. Paragraph 68 of the NPPF acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. It is expected that at least 10% of the overall housing requirement would be met on sites of less than 1 hectare. It is considered that the allocation of sites on the edge of villages would be consistent with the requirement to specifically allocate small and medium sized sites, and allow for the incremental growth of those villages. Therefore, it is considered that the emerging GCLP should seek to allocate suitable sites on the edge of existing sustainable villages, in conjunction with a general policy that supports development within existing framework boundaries but without specifying any size limits. This suggested approach would ensure that sufficient land is allocated for development at villages to support services and facilities and ensure that sufficient physical and community infrastructure can be planned, and would provide some flexibility about development within village boundaries so that the form and scale of development reflects site specific characteristics. Balsham is an example of a settlement that could accommodate additional development at sites on the edge of the village, as explained in the call for sites submission for land south of Old House Road.

Dispersal: Villages, Densification of existing urban areas, Public Transport Corridors, Edge of Cambridge: Green Belt, Edge of Cambridge: Outside Green Belt, Dispersal: New Settlements

It is considered that the development strategy for emerging GCLP must be based on a combination of spatial distribution options, including development in villages. The scale of development that occurs at individual villages will depend on the level of services and facilities. Balsham is an example of a settlement that could accommodate additional development, as explained in the call for sites submission for land south of Old House Road.