Greater Cambridge Local Plan Issues & Options 2020

Land West of Dubbs Knoll Road, Guilden Morden, South Cambridgeshire, SG8 0LB

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The NPPF, in Annex 2, defines green infrastructure as ‘a network of multi-functional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities’. Our client considers the provision of green infrastructure to be vital in ensuring healthy communities and a distinctive sense of place within our built environment. Land to the West of Dubbs Knoll Road is a potential site which is a unique opportunity to provide public open space as a central feature of a wider residential development. There is an opportunity for the open space to be well-related to the existing green infrastructure in this part of the village – creating a new ‘heart’ of green space for the village. Chapter 15 of the NPPF places great emphasis on the conservation and enhancement of the natural environment and sets out that Plans should take ‘a strategic approach to maintaining and enhancing networks of habitats and green infrastructure’. In preparing Local Plans, it is our client’s view that local planning authorities should recognise the multifunctionality of green infrastructure and should recognise that it can be strengthened by development to provide a range of tangible benefits. These benefits in turn are linked to the higher level aims of the Greater Cambridge Local Plan around sustainability and health and well-being. Development can play a role in contributing to enhancing and protecting existing green infrastructure and providing new green infrastructure. Any future policy should recognise the contribution that sustainable greenfield sites, and infill sites, can have towards the goal of enhanced, accessible green infrastructure through effective layout and landscaping design. Though individual sites should not be expected to deliver green space improvements alone, and any future policy should recognise this fact, development of varying scales can deliver improvements to green infrastructure in the form of provision of or enhancements to existing habitats. The layout of housing sites can be considered to ensure the provision of gardens, inclusion of trees and shrubs which provide biodiversity value as well as maximising areas of green space to provide sustainable urban drainage systems and general open space. As such, the Plan should consider the flexibility and multi-functionality of the provision and should not underestimate the role of sustainable housing development. Summary of Comments: The Plan should ensure that sites which form part of the green infrastructure network deliver a variety of benefits to local communities. Development can deliver or enhance green infrastructure provision. Sites which are suitable for housing can also fall within the wider green infrastructure network to fulfil its multifunctional purpose.

The NPPF requires Local Authorities to plan positively, in a way that is aspirational but deliverable. The objectives stated in the Issues and Option document provide the right emphasis on the issues to be challenged the Plan period. The document is supported by the Greater Cambridge Housing Strategy 2019 - 2023, which identifies a need for more diverse provision of housing across the local authority areas. The population of Greater Cambridge is expected to increase by around 26% between 2011 and 2031. The current Government ‘Standard Method’ indicates a need for 1,800 homes a year, or 40,900 new homes over the proposed Plan period of 2017-2040. It should be noted that the ‘Standard Method’ provides a minimum starting point – there should be consideration during the plan-making process of whether other factors indicate that the target should be increased above the figure derived from the standard method. It is noted that South Cambridgeshire District Council has a track record of the under-delivery of housing generally. Whilst there is a 20% buffer applied as part of the Local Plan, it is considered that consistent under-delivery over the Plan period will affect the requirement for housing in the new Plan period. In terms of affordable housing more specifically, the 2019 Annual Monitoring Report shows that only 25% of housing delivered was affordable. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area. The Council will need to consider, as set out in paragraph 2a-024 of PPG, whether an increase in the total amount of housing is necessary to help deliver the required number of affordable homes. In terms of rural housing need, it is recognised in the Greater Cambridge Housing Strategy that, particularly for South Cambridgeshire, the Plan needs to ensure "its villages remain vibrant and sustainable, and working with local businesses to ensure homes are affordable and available to local workers are high priorities for the District". To meet the housing needs of the Local Plan area, it is considered a flexible approach to the allocation of sites across a number of locations across the boroughs will be required. This will require the allocation of larger sites in order to deliver large quantities of housing to meet significant need, but also in the allocation of smaller sites in rural towns and villages in order to ensure sustainable growth. When considering housing within rural areas, paragraph 77 of the NPPF requires planning polices to be relevant to local circumstances and that development which reflects these local needs should be supported. The NPPF requires 10% of housing need to be accommodated across the Plan area on ‘small sites’ of 1ha or under. It is acknowledged that a proportion of this requirement will be sought to be met through smaller scale allocations in towns or villages. Whilst this is a policy requirement it is considered that, particularly in villages, housing allocations should be flexible in this regard and should include sites over 1ha. Should only smaller scale sites be allocated in these locations this could stifle the sustainable growth of villages which would be contrary to paragraph 78 of the NPPF. Future policy in this area should take account of the potential opportunities that are available for housing, how these can be accommodated within the existing village forms, and above-all the benefits they will deliver. This approach is preferred rather than purely an arbitrary size threshold. Our client’s Site at Dubbs Knoll Road in Guilden Morden is a key example of a site which could offer a relatively small village a combination of much-needed affordable housing and upper market executive housing to assist in providing a balance of new development to help sustain the settlement. Sites which are over 1ha in rural locations can provide infrastructure and public benefits, such as affordable housing or public open space which cannot always be accommodated on smaller scale sites. Sites over 1ha can additionally assist in ensuring development delivers a range of housing and contributes to the vitality of rural areas and the creation of sustainable, balanced communities. Summary of Comments: The standard Method is a starting point and sets out a minimum target. To adhere to para 77 and 78 of the NPPF and maintain the vitality of rurla communities, a variety of sites should be allocated including sites such as the 1.2 hectare Land West of Dubbs Knoll Road in Guilden Morden which can have a key role to play in sustaining balanced communities.

Yes, strongly agree

Strongly agree. Our client’s site West of Dubbs Knoll Road in Guilden Morden is submitted for consideration. It is wellconnected village which can support an appropriate amount of development to fulfil the aims of the National Planning Policy Framework around promoting and maintaining the vitality of rural communities. As has been identified in the Issues and Options document, South Cambridgeshire and Cambridge Councils are currently planning for the delivery of 1,600 homes per year. The Issues and Options document identified that over the plan period of 2017-2040 there is a need for 1,800 homes per year using the government's calculations. In order to provide flexibility for a growing economy 2,900 homes per year will be required. As set out in Paragraph 010 (Id. 2a) of the Planning Practice Guidance, it should be noted that the ‘Standard Method’ provides a minimum starting point – there should be consideration during the planmaking process of whether other factors indicate that the target should be increased above the figure derived from the standard method. Furthermore, paragraph 60 of the NPPF states that the housing need figure should take into account any needs that cannot be met within a neighbouring area – past trends should be considered, and joint working guaranteed in forming housing targets. To achieve sustainable development the NPPF sets out 3 objectives: social, economic and environmental. In relation to the economic objective, this is focused on " ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure", which includes the delivery of homes. South Cambridgeshire Council has a track record of the under-delivery of housing, particularly affordable housing. The 2019 Annual Monitoring Report shows that only 25% of housing delivered was affordable. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area. Whilst there is an existing 20% buffer applied as part of the Local Plan, in accordance with the NPPF, it is considered that consistent under-delivery over the Plan period will affect the requirement for housing in the new Plan period. The forthcoming Plan will be required to ensure that an appropriate amount of housing, particularly affordable housing is delivered which also considers any historic under-delivery from the previous Plan period. The Greater Cambridge Issues and Options Document has identified that the economy of the area is growing. Paragraph 80 of the NPPF requires local authorities to allow the expansion and growth of business. Cambridge therefore requires relevant infrastructure, including the delivery of homes, to meet and deliver this growth. Providing the flexibility for growth will give confidence to investors that Cambridge continues to provide and invest in opportunities for business. Paragraph 73 of the NPPF makes it clear that a 5-year housing land supply is a minimum requirement to be delivered by the local authority and not a maximum number. The flexibility in the NPPF therefore allows local authorities to deliver more housing where it is required, such as in Cambridge where the growth of the economy is ongoing. Additionally, providing the flexibility for growth will also ensure that a diverse range of workers have employment opportunities and a choice of home across Greater Cambridge. If housing does not meet the needs of a variety of workers and families, there will be outward migration to areas which satisfy this need. This is of particular importance when considering the diverse nature of Greater Cambridge's towns and villages and the retention of the existing population. The NPPF aims to deliver balanced, mixed communities and the siting of sustainable housing development in these areas is essential in meeting the requirements of paragraph 78 of the NPPF in retaining the vitality of rural communities. Additional housing in villages would support other wider aims in Greater Cambridge, including the strengthening of rural businesses by providing housing for existing and potential employees. Summary of Comments: Paragraph 73 of the NPPF makes it clear that a 5-year housing land supply is a minimum requirement to be delivered by the local authority and not a maximum number. The flexibility in the NPPF therefore allows local authorities to deliver more housing where it is required, such as in Cambridge where the growth of the economy is ongoing. Additionally, providing the flexibility for growth will also ensure that a diverse range of workers have employment opportunities and a choice of home across Greater Cambridge. If housing does not meet the needs of a variety of workers and families, there will be outward migration to areas which satisfy this need. This is of particular importance when considering the diverse nature of Greater Cambridge's towns and villages and the retention of the existing population. The NPPF aims to deliver balanced, mixed communities and the siting of sustainable housing development in these areas is essential in meeting the requirements of paragraph 78 of the NPPF in retaining the vitality of rural communities. Additional housing in villages would support other wider aims in Greater Cambridge, including the strengthening of rural businesses by providing housing for existing and potential employees.

The NPPF aims to significantly boost the supply of housing by ensuring that sufficient land is available to meet the needs of the population. Paragraph 59 of the Framework states that ‘to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed, and that land with permission is developed without unnecessary delay’. As has been identified in the Issues and Options document, South Cambridge and Cambridge Councils are currently planning for the delivery of 1,600 homes per year. The Issues and Options document identified that over the plan period of 2017-2040 there is a need for 1,800 homes per year using the government's calculations. In order to provide flexibility for a growing economy 2,900 homes per year will be required. To achieve sustainable development the NPPF sets out 3 objectives: social, economic and environmental. In relation to the economic objective, this is focused on ‘ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure’, which includes the delivery of homes. South Cambridgeshire Council has a track record of the under-delivery of housing, particularly affordable and executive housing. The 2019 Annual Monitoring Report shows that only 25% of housing delivered was affordable. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area. Whilst there is an existing 20% buffer applied as part of the Local Plan, it is considered that consistent under-delivery over the Plan period will affect the requirement for housing in the new Plan period. The forthcoming Plan must ensure that an appropriate amount of housing, particularly affordable housing is delivered which also takes into account any historic under-delivery from the previous Plan period. Therefore, the Plan will be required to deliver affordable housing to meet the identified need within the Greater Cambridge area. It is considered this is of particular importance in relation to rural areas and villages such as Guilden Morden, which sustainably located with good public transport linkages and shops and services. Historic evidence in the form of the housing need study (SCDC, 2015) demonstrates there is a need for housing, especially affordable housing, which is greater than what the plan would have allowed previously. As such, careful consideration should be given to the allocation of sites, which can accommodate affordable housing in order to ensure the long-term vitality of rural areas in accordance with paragraph 78 of the NPPF. One such site is Land West of Dubbs Knoll Road, which is submitted on behalf of our client. The Economic Development Strategy demonstrates that there is an under-supply of executive homes in South Cambridge. It is noted in the strategy that the lack of executive housing means that the “mobility, retention and recruitment of managerial and professional staff problematic”. The forthcoming Plan should therefore ensure that adequate provision of executive homes is delivered across the Greater Cambridge area in order to ensure that managerial staff and business owners are retained within the local authority areas. The delivery of executive homes can also assist in the provision of affordable homes where there may be viability issues with a site and helps to create balanced and mixed communities. A variety of sites in urban and rural locations should be considered for executive housing in order to reflect the needs of higher income groups and provide a choice of location across the Greater Cambridge area. Some villages, such as Guilden Morden in South Cambridgshire, are sustainably located and are able to support development to fulfill the goals of the NPPF. There is a track record of under-delivery of affordable housing and executive housing. The plan should ensure there is an adequate variery of sites, in rural and urban locations.

Highly flexible

Highly flexible. The NPPF aims to significantly boost the supply of housing by ensuring that sufficient land is available to meet the needs of the population. Paragraph 59 of the Framework states that ‘to support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed, and that land with permission is developed without unnecessary delay’. South Cambridgeshire District Council (SCDC) has a track record of the under-delivery of housing, particularly affordable housing. The 2019 Annual Monitoring Report shows that only 25% of housing delivered was within the SCDC’s own definition of affordable housnig. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area including rural areas where the under-delivery of affordable housing felt acutely. With particular regard to rural housing, paragraph 77 of the NPPF states that planning policies should reflect the local housing need and support development which meets this need. Paragraph 78 of the NPPF sets out that to deliver sustainable development in rural areas, housing should be located where it will maintain or enhance the viability of the rural community. The Greater Cambridge Issues and Options report acknowledges that the villages in the Plan area have an ageing population and that retaining a wide variety of services and facilities for residents is challenging. Paragraph 78 of the NPPF states that sustainable housing evelopment within rural areas should be located where it helps to maintain or enhance the vitality of the rural community. As such, the allocation of land in villages is required in order to ensure compliance with paragraph 78 of the NPPF as it is acknowledged that villages in the Plan area are unsustainable and in decline due to their demographic. The existing South Cambridgeshire Local Plan which was adopted in 2018 is restrictive of development within rural areas. The current village frameworks are drawn tightly around the existing built landscape development and will stifle any development opportunties. Such strict and ‘tightly drawn’ development frameworks in villages do not provide adequate flexibility for villages to grow. It is considered the forthcoming plan is required to be more flexible to address the needs of villages to ensure accordance with paragraph 78 of the NPPF. For villages which are categorised as "Group Villages", these are identified as being capable of accommodating limited development, particularly affordable housing to meet local need. It is considered that the policies in the Greater Cambridge Plan need to be applied more flexibly applied to ensure housng which meets the needs of all groups in the locality can be met to ensure the delivery of sustainable development. Edge of village development, which may or may not be currently allocated within the village framework, can provide opportunities for sustainable development through infilling of vacant sites, and assists in the consolidation of settlements. Sites on the edge of villages can help to meet the demand for growth in a limited capacity whilst addressing the needs of the local population. Summary of Comments: The existing South Cambridgeshire Local Plan which was adopted in 2018 is restrictive of development within rural areas. The current village frameworks are drawn tightly around the existing built landscape development and will stifle any development opportunties. Such strict and ‘tightly drawn’ development frameworks in villages Such as Guilden Morden in South Cambridgeshire do not provide adequate flexibility for villages to grow. It is considered the forthcoming plan is required to be more flexible to address the needs of villages to ensure accordance with paragraph 78 of the NPPF. For villages which are categorised as "Group Villages", these are identified as being capable of accommodating limited development, particularly affordable housing to meet local need.

Highly flexible

Highly Flexible Village frameworks can be a useful and effective concept in relation to rural areas in order to ensure a clear distinction between settlements and the wider countryside or Green Belt. Notwithstanding this, it is imperative that village frameworks are imposed in a considered way, and in an appropriate capacity. The allocation of land in villages is required in order to ensure compliance with paragraph 78 of the NPPF as it is acknowledged that villages in the Plan area have an ageing population and there is a decline in the availability of amenities and local services. The existing South Cambridgeshire Local Plan is restrictive of development within rural areas. The current village frameworks are drawn very tightly around the existing built landscape development and do not provide adequate opportunity for rural communities to grow sustainably. It is considered the forthcoming plan is required to be more flexible to address the needs of villages to ensure accordance with paragraph 78 of the NPPF. Settlement boundaries which are implemented as part of Local Plan policies should accord with paragraph 78 of the NPPF which requires policies to provide opportunities for villages to grow and thrive. The boundaries of settlements, particularly rural villages, should provide opportunities for sustainable growth in order to ensure existing facilities and amenities in local communities are retained. The allocation of sites within villages should reflect the established housing need of the local area, particularly where there is a requirement for affordable housing to be delivered. The allocation of sites should take into account whether there is the opportunity for additional public benefits to be delivered as part of development, such as open space, affordable housing and contributions to education or other infrastructure. Where should we site new development? 1- Dispersal - Villages 2- Edge of Cambridge: Green Belt 3- Edge of Cambridge: Outside of Green Belt 4- Public Transport Corridors 5- Densification of existing urban areas 6 - New Settlements It is considered that new development should be dispersed across villages in the Greater Cambridge Area in order to provide sustainable growth. The siting of development across villages ensures that rural communities are afforded the opportunity to accommodate new housing and employment opportunities which would ensure their long-term sustainability. It is acknowledged in the Greater Cambridge Housing Strategy that there are issues with affordability of housing in the area and a need for more affordable housing to be delivered to meet the needs of local people. The Greater Cambridge Housing Strategy also notes that existing villages have an ageing population and there is a decline in the provision of amenities and services in rural communities. There is therefore a need to inject new market and affordable housing in rural areas to ensure balanced and mixed communities are established, which in turn ensures that local facilities and amenities continue to be retained. This is required by paragraph 78 of the NPPF which requires planning policy to consider housing to be in rural areas to support services and allow villages to grow sustainably. There is a clear and evidenced need for the provision of a range of housing, particularly Executive development and affordable housing. Indeed, in the South Cambridgeshire District Council 2019 Annual Monitoring Report only 25% of housing delivered during this period were affordable units. Summary of Comments: The Local Plan should be highly flexible when considering the size of development within village frameworks. Frameworks should be drawn appropriately to ensure villages and small settlements can be sustained.

The dispersal of development in the Greater Cambridge villages is considered to be a suitable option for accommodating the housing and employment needs of the Greater Cambridge area. The NPPF aims to significantly boost the supply of housing by ensuring that sufficient land is available to meet the needs of the population. Whilst there is an existing 20% buffer applied as part of the Local Plan in accordance with the NPPF, it is considered that consistent under-delivery over the Plan period will affect the requirement for housing in the new Plan period. The forthcoming Plan will be required to ensure that an appropriate amount of housing, particularly affordable housing is delivered which also takes into account any historic underdelivery from the previous Plan period. With particular regard to rural housing, paragraph 77 of the NPPF states that planning policies should reflect the local housing need and support development which meets this need. Paragraph 78 of the NPPF sets out that to deliver sustainable development in rural areas, housing should be located where it will maintain or enhance the viability of the rural community. The Greater Cambridge Issues and Options document acknowledges that there are problems with the long-term sustainability of its villages due to an ageing population and a decline in existing services and amenities. As such, para 78 of the NPPF is relevant, which requires planning policies to ensure that housing is delivered in rural communities to ensure they grow and thrive. South Cambridgeshire District Council has a track record of the under-delivery of housing, particularly affordable housing. The 2019 Annual Monitoring Report shows that only 25% of housing delivered was affordable. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area. This requires the allocation of a variety of sites to meet local needs and to ensure the sustainability of village settlements. The Greater Cambridge Issues and Options document states that smaller sites are unlikely to contribute to improvements to infrastructure. We therefore consider that the Plan should consider the allocation of sites larger than 1ha on sustainable sites within villages in order to provide opportunities for new homes and public benefits. The addition of new homes and employment opportunities into the rural communities in the borough would assist in diversifying the population and ensure that sustainable, balanced communities are delivered. Summary of Comments: Para 78 of the NPPF requires planning policies to ensure that housing is delivered in rural communities to ensure they grow and thrive. The Greater Cambridge Housing Strategy also notes that existing villages have an ageing population and there is a decline in the provision of amenities and services in rural communities. There is therefore a need to inject new market and affordable housing in rural areas to ensure balanced and mixed communities are established, which in turn ensures that local facilities and amenities continue to be retained.

Land to the West of Dubbs Knoll Road

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