Greater Cambridge Local Plan Issues & Options 2020

Yes, somewhat agree

5.16 Yes, however, with the right trees, in the right areas. A policy framework to seek tree cover increase, but allows for a planning balance within decision-making to enable the benefits and impacts of each development to be assessed. 5.17 This could be part of an on-site/off-site solution, which could generate notable s106 funds to achieve significant, meaningful and long-term planted and ecological areas. Ecological outcomes rather than an unconditional focus on native species should be considered in new planting. 5.18 Wates Group selected The Conservation Volunteers (TCV) as Charity of the Year 2018-2020. Wates Group work in partnership with TCV to help raise funds to create healthier and happier communities for everyone, and transform even more precious green spaces. The partnership fits well with Wates Developments’ ethos of sustainability and allows for employees of Wates to volunteer on projects across the country. We are currently looking to help the charity plant 15,000 native trees by 2022 as part of a ‘Treeathlon’.

5.19 The Local Plan should deliver a spatial strategy that connects homes with accessibility to good quality public transport, facilities and services and high-quality green spaces. 5.20 Good growth that promotes wellbeing (including health) should be inclusive and include antipoverty measures including: ● Energy efficient homes and employment space that deliver low energy and water bills; ● Promotion of commercial development and job creation that offers the Living Wage and opportunities for those on lower incomes to increase wages to easily access jobs; ● Allow for a wide range of social infrastructure and open space in new developments that provide pathways to free (i.e. no charge to the user) opportunities for improved health outcomes; ● Promotion of low-cost housing proportionate to income in the area; and ● Promotion of ‘fully accessible’ social housing. 5.21 The Local plan should ensure a policy framework is developed that is based on empirical evidence of how good growth is delivered, rather than rely on policies based on perceived, and sometimes unproven, determinants of wellbeing and social inclusion. Policies should focus on what really makes a difference. Housing in rural areas should be part of the council’s strategic response to the need for new homes.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59). 6.2 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. 6.3 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. 6.4 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 6.5 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. 6.6 Wates Developments are proposing a sustainable village extension along the western side of the village. The housing need across the district is well established and delivering new homes in the rural area is considered an important part of the Council response to meeting this need. Fowlmere is a sustainable location for residential development, development will help support local services and help provide employment opportunities. In assessing sustainability of a rural village, it is important to recognise the interconnection between villages and assess their suitability on this basis.

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6.7 Greater Cambridge is an area with strong economic growth and with an aspiration to maintain that growth. The affordability of housing is also a major issue. The new Local Plan must be able to address both of these concerns. 6.8 To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. 6.9 The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to being a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that if there is an insufficient supply of housing the economic growth plans will not be realised. The role of housing in attracting and retaining skilled employees is widely recognised and should be adequately addressed in the Plan. 6.10 Housing requirements are minimums, not maximums to stay under at all costs. There is a well evidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”1 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13

6.11 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. Consideration of individual site circumstances and the circumstances of a local area should be taken into account to determine the appropriate type of housing for development sites. Separate evidence-based housing needs assessments should be used to inform the appropriate size, type and tenure of housing needed for different sections of the community, as set out within the Greater Cambridge Housing Strategy 2019-2023. Flexibility will be key to a successful Local Plan; through market housing, low-cost and affordable housing. 6.12 The site Wates Developments are promoting provides the opportunity to deliver market and affordable homes of a range of size, type and tenures to meet needs of not only the local community but the wider district. The proposals would therefore respond adequately to the challenges and opportunities of the different components of the community.

6.13 Local Plan policies can require a high standard of design for new residential development, leading from Government policy and guidance. Appropriately worded design policies should require a high-quality design for new dwellings. This could include sustainable design principles including measures to improve the energy efficiency of new homes, water saving measures, use of efficient insultation material and heating systems, the reduction and recycling of construction materials, provision of appropriate amenity space and accessibility. Policy should not be prescriptive for precisely how it will be accomplished, it can set a policy-level, but developers should be able to use a host of options to achieve the target. Wates Developments is committed to providing sustainable development that delivers positive outcomes for local communities.

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7.1 The most effective approach to delivering the levels of development required is to ensure a wide variety of sites are allocated both in terms of size and location. This will ensure the consistent delivery across the plan period by not concentrating all development in a specific area or resulting in an over reliance on large strategic sites. 7.2 While a range of development scenarios are outlined, the Council should not rely on one strategy, a combination is required to ensure a sound plan. This should allow appropriate development outside of the settlement boundaries of villages, in particular, if development meets a particular local business or community need as set out within Para. 84 of the NPPF. Sustainable development in rural areas is also supported under Para. 78 of the NPPF, which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services. 7.3 Land west of High Street Fowlmere is considered a suitable location for a village extension. It will help support the local services of the village and importantly, the villages near it, to grow and thrive.

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7.4 There should be more flexibility when considering the scale and size of developments that are permitted within village boundaries. The Local Plan currently restricts the amount of development that is permitted in Minor Rural Centres (Policy S/9) to 30 dwellings; in Group Villages (Policy S10) to 8 dwellings and in exceptional circumstances to 15 dwellings; and in Infill Villages (Policy S/11) to 2 dwellings and in exceptional circumstances to 8 dwellings. These policies should not restrict development to a certain number of dwellings and should instead encourage an appropriate density depending on the context of the site that is being considered for development. Some sites might be capable of accommodating higher density development which can enable a more sustainable distribution of growth, particularly in the case of some villages within the district which are well connected in terms of being located on key transport corridors with access to rail, bus and cycleway links, thereby making them sustainable locations for development. A more flexible approach towards considering development in villages should therefore be used when allocating development sites and in the determination of planning applications. 7.5 There should also be more flexibility in terms of considering applications which are located outside village boundaries, provided the Site is suitable in other terms including its access to transport and village services and provided it is not overly constrained in terms of other environmental designations. The proposed village extension at Fowlmere is a suitable location for residential development and should therefore become a residential site allocation by extending the village boundary to include the Site location. The inclusion of the site would form an appropriate extension to the village.

7.7 The Local Plan should seek to allocate a component of its housing needs towards growth at existing villages. Sustainable development in rural areas is supported under paragraph 78 of the NPPF, which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services. Development within existing villages can help to sustain existing and deliver new facilities and infrastructure, support shops and business uses and meet both the market and affordable housing needs of the local community.

Response to SA 8.1 In reviewing the documentation prepared by the Council, we recognise that this is an early stage in the plan’s preparation and that an SA is an iterative process. At the outset, we would note that recent challenges at examination of local plans have included substantive criticisms of the SA which goes well beyond the legal tests and into professional planning judgement. For example, examiners in the North Uttlesford Local Plan, North Essex Local Plan and St Albans Local Plan have recently requested information on alternatives that goes beyond the legal position of “reasonable alternatives” selected by the local authority using broad questions of judgement. 8.2 The Issues and Options Report is assessed in a SA report dated November 2019. The Issues and Options Report is largely of general content without spatial or specific focus, and consequently much of the assessment is general commentary. 8.3 Six spatially discernible options are provided in the "Towards a Spatial Plan" Section, which are: ● Option 1: Densification; ● Option 2: Edge of Cambridge – Outside the Green Belt; ● Option 3: Edge of Cambridge – Green Belt; ● Option 4: Dispersal – new settlements; ● Option 5: Dispersal – villages; ● Option 6: Public transport corridors. 8.4 With only high-level options assessed at this stage, there is substantial uncertainty over the outcomes of these options. As such, the conclusions of the SA also are substantially uncertain, and more assessment is required with specific details provided on the deliverable projects which will make up these options. 8.5 There is a possibility that a preferred option will be advanced with an equally valid alternative discarded at this early stage due to lack of information. Additional assessment should take place at another local plan stage, with full assessments within the SA Framework, before any options are fully dismissed. Without a full consideration of all these options which considers substantive detail of deliverable sites, there is a risk of the plan's selected alternative not being properly justified, and the plan being found unsound at examination. 8.6 The options assessed in the issues and options report will likely only be achievable in combination with other options (e.g. some density within existing development, with some expansion to villages, etc). For transparency, the extent to which these options are likely to be combined in ultimate implementation should be made explicit in any future local plan documents which discuss these strategic options. 8.7 The significant negative or positive effects given within the SA report are at this stage based on the limited information available, misleading due to assumptions used and uncertainty attendant with such high level options. The SA Report notes a large number of points of uncertainty, but still identifies a number of significant effects (both positive and negative). However, there are assumptions for the significant effects identified which aren't clearly explained and which can be questioned. For example, Option 5 (Dispersal – villages) is attributed a significant negative effect to SA Objective 6 (distinctiveness of landscapes) as it is assumed that expansion of these Page 18 villages could have an adverse effect on the open countryside and landscape surrounding these villages, as well as village character. As recognised in paragraph 3.61 the actual effect will depend on the final design, scale and layout of the proposed development. 8.8 We recognise that SA is an iterative process which will evolve as a Local Plan progresses. More information should be provided on the approach to considering alternatives. The most substantive point we raise is that the options set out in the Issues and Options Report should all be taken forward to subsequent local plan stages, where deliverable options should be assessed in detail, and transparent and objective assessment of these options provided at a subsequent SA stage. This will help ensure the Local Plan process and SA would support a hybrid of development scenarios which would underpin all development proposals at this stage.

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