Greater Cambridge Local Plan Issues & Options 2020

According to the NPPF, the Planning Practice Guidance (PPG) and the Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through the development of a range of housing sites. While the existing strategic allocations and new settlements are an important componant of housing delivery, paragraph 68 of the NPPF advises that “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” The existing planning strategy places a significant reliance on the strategic alloactions around the City and also the development of new settlements which the local plan inspectors raised concerns about. The new local plan should signifcantly increase the allocation of small to medium sized sites in the rural areas, helping to speed up the delivery of homes and allowing more flexibility. It is important that the rural areas are not left behind but allowed to prosper and thrive. It will be necessary for the new local plan to identify at least 10% of the housing allocations on sites no larger than one hectare (NPPF para 68 (a)). This coupled with medium sized allocations will provide greater potential to deliver a more diverse range of sites, better suited to local need, and better able to respond to market conditions. It will ensure that not all the growth is focused on the City but also supports the parallel growth of the rural economy. In terms of housing numbers the Cambridge & Peterborough Independent Economic Review identified that the recent growth in employment has not been matched by corresponding house-building and that ‘We are rapidly approaching the point where even high-value businesses may decide that being based in Cambridge is no longer attractive. If nothing is done, the damage to society from the continuing drift away of less well-paid workers may become irreparable’. To support the job growth, around 2,900 homes would need to be built each year to deliver a total of 66,700 homes between 2017 – 2040 rather than the 1,800 homes per year using the Government’s standard methodology. The PPG (paragraph 10) makes it clear that the standard method is only a minimum starting point. This higher level of growth is supported and necessary to help deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over 25 years. Increased allocations on small and medium sized sites will increase delivery and help improve affordability through increased supply. A wider range of sites will also allow more flexibility in the mix, type and tenure of homes delivered. It will be important to take a flexibile approach to development proposals designed to meet the needs of an aging population, a growing demographic group who’s needs will need to be accommodated over the plan period. The allocation of Scott properties site in Fen Ditton would fulfil all the above objectives and while the sites individual contribution to the total housing need referred to above would be modest, it would make an effective and proportionate contribution to a specific need at the local level. Summary of Comments: The new Local Plan will need to allocate a significant number of new small and medium sized sites, to support prosperous rural economy.

Yes, strongly agree

The question asks whether or not the Greater Cambridge Shared Planning Service should plan for a higher number of homes than the minimum required by government to provide flexibility and support the growing economy. The standard methodology indicates a need for 1,800 homes per year, or 40,900 homes for the suggested plan period of 2017-2040. However, as the draft Local Plan acknowledges, the Cambridgeshire & Peterborough Independent Economic Review (CPIER) 'showed that our recent growth has been faster than expected, and that growth is likely to continue. As a result, demand for new housing in this area has been exceptionally high and housebuilding has not kept up'. CPIER recommends that 'There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast in the EEFM'. It states that 'No economy can achieve its potential without an adequate supply of housing, which must offer a range of types and price points for all society' and adds that it 'is concerned that Cambridgeshire & Peterborough is already running a very significant risk in this regard' and that risk is most acute in the Greater Cambridge area'. CPIER continues, stating that 'There has been insufficient housing development to meet demand. Average house prices and commuting have risen, choking labour supply while reducing the well-being of those forced to commute longer and longer distances [from more affordable areas]'. CPIER concludes that 'we believe the accumulated deficit in Cambridgeshire & Peterborough is so acute that the local authorities should re-examine their assessments of housing need, setting higher numbers, which at least reflect previous under-delivery'. To support the job growth around 2,900 homes would need to be built each year to deliver a total of 66,700 homes between 2017 – 2040 rather than the 1,800 homes per year using the Government’s standard methodology. This higher level of growth is supported and necessary to help deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over 25 years. For these reasons, we strongly agrees that the Greater Cambridge Shared Planning Service 'should plan for a higher number of homes than the minimum required by government, to provide flexibility to support the growing economy'. Summary of Comments: Strongly agree that 'we should plan for a higher number of homes than the minimum required…, to provide flexibility…for the growing economy'.

Question 37. How should we encourage a shift away from car use and towards more sustainable modes of transport such as public transport, cycling and walking? The spatial strategy approach is a key way of encouraging shifts away from car use towards more sustainable modes of transport by focusing development in locations with good existing public transport or with potential for improved public transport. However, this needs to be balanced in the rural areas where the NPPF recognises that the opportunities will vary between urban and rural areas. The need to identify a high number of small and medium sized sites in the rural areas means that sites which are well located in relation to existing services and facilities such as Scott Properties' site at Land at the West side of South Street, Comberton should be preferred over more remote and isolated locations in the rural areas. Summary of Comments: The spatial strategy will need to recognise the different opportunities available between urban and rural areas.

Nothing chosen

It is known that the Government attaches great importance to Green Belts, the fundamental aim of which is to prevent urban sprawl and keep land permanently open. The anticipated forthcoming Planning White Paper may make some changes to this situation with potentially some relaxation. However, until it is published, current national planning policy remains that the Green Belt serves five purposes: a. To check the unrestricted sprawl of built up areas; b. To prevent neighbouring towns merging into one another; c. To assist in safeguarding the countryside from encroachment; d. To preserve the setting and special character of historic towns; and e. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Green Belt boundaries are established through Local Plans and should only be altered where exceptional circumstances are fully evidenced and justified. As part of the preparation of the currently adopted Local Plans, minimal changes to the Green Belt were proposed. These were limited to a number of small scale changes to allow the expansion of some existing urban extension allocations and a small number of new allocations. The new Local Plan should undertake a fundamental review of the entire Cambridge Green Belt to understand whether it still serves a relevant function in planning terms for the City, or is stifling sustainable development. Potentially, it is promoting unsustainable patterns of development which simply leapfrog the Green Belt and result in development in less sustainable locations, increasing the need to travel between Cambridge and outlying areas that as such, are less connected to public transport routes. It is clear that given the geography of Greater Cambridge in which many of the most sustainable parts of the spatial planning area are located within the Green Belt, that some Green Belt release should form part of the overall spatial strategy. In this way, the area can help to reduce travel distances and help faciliate sustainability through the provision of sustainable transport infrastructure. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time Green Belts were introduced, the need to promote sustainable development which meets today’s needs including housing, employment and environmental considerations were very different. Today’s issues of climate change, congestion, pollution, water security, food production and fuel poverty suggest that a more radical approach to planning policy is required. At the time the Green Belts were established, the tools available to planners were more limited and the ability to analyse opportunities and constraints and develop robust evidence and justification, were at best very basic. A blanket protection of large swathes of land was therefore considered appropriate. At the time the pressures for growth and essential need for development were considerably less than they are today. Greater Cambridge is an exceptional area, both in its contribution to the national economy and its international reputation. In order to sustain its natural growth in a sustainable way, a wholesale review of the Cambridge Green Belt should be undertaken. This should be a balanced review, not simply an assessment of the performance of various parcels of land against the purposes of Green Belt. It should be a challenging assessment balancing the scale of development required to support the growth necessary to deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over the next 25 years. To support this level of job growth around 2,900 homes will need to be built each year to deliver a total of 66,700 homes between 2017 – 2040. It is imperative both locally and at the national level that Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. Cambridge as a city is also exceptional and as such a radical review of Green Belt policy is clearly justified to facilitate its growth. The tools available today to analyse and inform plan making decisions are highly sophisticated and should be used to undertake a challenging and balanced review of the existing Green Belt. Summary of Comments: A radical review of the Cambridge green belt is required to facilitate growth within the Greater Cambridge area and sites need to be released.

Nothing chosen

Question 40. How flexible should the Local Plan be towards development of both jobs and homes on the edge of villages? The acknowledgment of the important role that villages play is strongly welcomed. It is critical that villages are provide with opportunities to grow in a sustainable way to meet the significant growth needs of the plan area and to promote a prosperous rural economy. As stated within the Issues and Options document at paragraph 5.2.5, the currently adopted 2018 South Cambridgeshire Local Plan sets a development framework for each village, outside which development is heavily restricted. In addition, villages within the Local Plan 2018 have been categorised dependant on their ‘sustainability’. Comberton is identified in the current South Cambridgeshire Local Plan as a Minor Rural Centre (Policy S/9). This is the second tier in the settlement hierarchy below Rural Centres (Policy S/8). Minor Rural Centres are described as ‘having a lower level of services, facilities, and employment than Rural Centres, but a greater level than most other villages in South Cambridgeshire, and often perform a role in terms of providing services and facilities for a small rural hinterland’. The current policy (Policy S/9) permits ‘Residential development and redevelopment up to an indicative maximum scheme size of 30 dwellings…within the development frameworks of Minor Rural Centres’. While the Rural Centres are more appropriately unlimited, our clients site would be below the 30 unit threshold, although currently outside the development framework. We encourage the next Local Plan to re-examine the approach currently taken to village growth and explore the re-grouping of village categories and flexibility on the scale of development within and beyond newer more specific village groups. It is clear that all the villages vary significantly in terms of the services provided. However, the scale of growth required, and in particular small sites of 1 Ha or less, means that there will need to be a significant number of small and medium sized sites allocated across all of the settlements in the rural area. Summary of Comments: The new Plan should be highly flexible towards development of jobs/homes on the edge of villages to be able support the significant development needs.

Q45: What do you think about developing around the edge of Cambridge in the Green Belt? The focus on growing our villages throughout South Cambridgeshire District would, as paragraph 5.4.3 of the consultation document outlines, maximise the potential for sustainable transport. Paragraph 136 of the NPPF is clear that Green Belt boundaries should only be altered where exceptional circumstances can be evidenced and justified through the preparation or updating of plans. In respect of M Scott Properties site, Land west side of South Street, Comberton, it is located outside the development framework of Comberton, which is a settlement located to the south west of Cambridge and has good public transport links into the centre. We are of the view that a strategic case for the allocation of all three site can be made which would provide additional housing and employment space within compatible sites and in a sustainable location. Paragraph 138 of the NPPF states promoting sustainable patterns of development should be taken into account when reviewing Green Belt boundaries. It goes on to state that Local Planning Authorities should channel sustainable development towards urban areas within the Green Belt boundaries and the impact of removing land from the Green Belt should be offset through compensatory improvements. The site is located within the Green Belt and therefore the Council will need to amend the boundary to accommodate their allocation. Paragraph 136 of the NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation and updating of plans. The preparation of the new Local Plan therefore represents an opportunity to review the Green Belt boundary for the sites being put forward by M Scott Properties. We believe the site is suitable for a sympathetic, sustainable and proportionate extension to the existing settlement of Comberton for additional housing. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time Green Belts were introduced, the need to promote sustainable development which meets today’s needs including housing, employment and environmental considerations were very different. Today’s issues of climate change, congestion, pollution, water security, food production and fuel poverty suggest that a more radical approach to planning policy is required. At the time the Green Belts were established, the tools available to planners were more limited and the ability to analyse opportunities and constraints and develop robust evidence and justification, were at best very basic. A blanket protection of large swathes of land was therefore considered appropriate. At the time the pressures for growth and essential need for development were considerably less. Greater Cambridge is an exceptional area, both in its contribution to the national economy and its international reputation. In order to sustain its natural growth in a sustainable way, a wholesale review of the Cambridge Green Belt should be undertaken. This should be a balanced review, not simply an assessment of the performance of various parcels of land against the purposes of Green Belt. It should be a challenging assessment balancing the scale of development required to support the growth necessary to deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over the next 25 years. To support this level of job growth around 2,900 homes will need to be built each year to deliver a total of 66,700 homes between 2017 – 2040. It is imperative both locally and at the national level that Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. Cambridge as a city is also exceptional and as such a radical review of Green Belt policy is clearly justified to facilitate its growth. The tools available today to analyse and inform plan making decisions are highly sophisticated and should be used to undertake a challenging and balanced review of the existing Green Belt. Summary of Comments: Development needs to take place within the Cambridge Green Belt, a radical review of the Green Belt is required to facilitate growth in the area.

Question 47. What do you think about growing our villages? While villages may not be the entire focus for all growth, it is critical that they play a significant contribution to the overall mix of development. In particular as locations for small and medium sized sites. Moreover it is important to understand that there are several different types of villages within the Greater Cambridge area ranging from large villages with a large range of shops, services, and services, to smaller villages with fewer facilities. The level of growth being attributed to each settlement should take into account a wide range of factors and it is important that the role of new development, which is rightly identified in the Greater Cambridge Local Plan as an advantage, should not be underplayed or underestimated. Growth in villages is essential to enable them to grow and thrive and to support existing services and infrastrcuture such as public transport, schools, and shops. The growth is also essential to support a prosperous rural economy. It should also be noted that some of the challenges identified within the Greater Cambridge Local Plan may not necessarily be applicable to all villages. For example, under section 5.3.3 of the Plan, it identifies that spreading homes to villages 'Can result in increased commuting by car, and travel to access…services and facilities, particularly if the village is away from main transport corridors'. In this instance, Scott Propoerties' site to the West side of South Street, Comberton is located within close proiximity to local shops and services with regular bus services. Accordingly, we consider that the site is in a highly sustainable rural location within the South Cambridgeshire District. Summary of Comments: Support for a strategy that includes growth in villages at a level that is commensurate with their size and scale and enables sustainable growth.

Focussing homes and jobs along key public transport corridors and around transport hubs extending out from Cambridge could be achieved by focussing growth around the towns and villages located along these routes and this is strongly supported. Siting development along these corridors would capitalise on improved connectivity and transport networks and in some cases, reduce the need for travel by private car. Summary of Comments: Growth should be focussed within transport corridors to enable growth.

Agree

Q4: Do you agree that planning to 2040 is an appropriate date in the future to plan for? If not, what would be a more appropriate date and why? The Greater Cambridge Planning Authority’s ambition is to submit a new Local Plan for examination by 2022. Given the complexities of the planning issues associated with Greater Cambridge and its future development, it is reasonable to assume that the examination process will not be straightforward. The original Local Plans were submitted in 2014 and were not adopted until 2018 and even then, were subject to a commitment to an immediate review. While the new Local Plan will be based on a lot of the adopted Local Plan work, a pragmatic time table for adoption from submission would be a minimum two year period resulting in adoption in 2024 at the earliest rather than 2023 as suggested. Paragraph 67 of the NPPF requires planning policies to identify specific deliverable sites for the first five years of the plan period and specific, developable sites (or broad locations for growth) for years 6 to 10 and where possible for years 11 to 15 of the plan period. The plan should therefore cover a minimum period of 15 years from adoption, if future development is to be based on a genuinely plan lead approach. While the currently adopted Local Plans may provide some certainty, subject to housing delivery and five year housing land supply issues, for the first five years, i.e. 2018 to 2023, the new Local Plans should follow on for the next 15 years, i.e. up to 2038 as a minimum. If as set out above the reality is that the new Local Plan is not adopted until at least 2024, 15 years on would take it to 2039. It is therefore concluded that a plan period to 2040 is an appropriate plan period, in particular having regard to climate change and the imperative to take action now. However, the plan needs to be visionary looking forward beyond 2040 in particular having regard to the Greater Cambridgeshire non statutory plan which covers the period to 2050 and the Government’s commitment to reach Net Zero Carbon by 2050. The plan needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the plan area. Summary of Comments: We agree that the plan period to 2040 is appropriate although the plans vision should be beyond 2050.

Agree

Q6: Do you agree with the potential big themes for the Local Plan? As outlined within the Local Plan Issues and Options document, the future Local Plan must aim to ensure sustainable development. In order to achieve this, competing priorities and issues need to be balanced. Greater Cambridge Planning has grouped these into the following themes: - Climate Change; - Biodiversity and Green Spaces; - Wellbeing and Social Inclusion; and - Great Places. We agree with these ‘big themes’ that have been proposed for the Local Plan, in particular ‘Climate Change’ and how the plan should contribute to achieving net zero carbon. Chapter 14 of the National Planning Policy Framework (NPPF) focusses on ‘Meeting the challenge of climate change, flooding and coastal change’. “The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.” (Paragraph 148 – NPPF, 2019) Scott Properties feel passionately about the need to address Climate Change. It is agreed that this is one of the most important factors to our future and as such should be a key consideration in the preparation of the new Local Plan. New policies should support appropriate measures to ensure the resilience of communities and infrastructure to climate change impacts such as floods, heatwaves and droughts which are considered likely to the Cambridge area. On the 21st February 2019, Cambridge City Council declared a ‘climate emergency’ and called on the Government, industry and regulators to implement the necessary changes to enable Cambridge and the rest of the UK to reach net zero carbon by 2030. Furthermore, we believe that my client’s sites can help address these themes, particularly in response to Green Spaces, Wellbeing and Social Inclusion and Great Places. A scheme at my clients site to the south of Comberton could comprise market and affordable dwellings suitable for those aged 55 and over as well as those with or supporting someone with a disability, with associated site infrastructure and public open space. The provision of specialist accommodation for older people allows people to downsize while remaining in the local area and close to friends and family. New family housing also comes to the market as a result, reducing the pressure to provide additional family housing sites in the local area. This in turn allows new families to move to the area helping to redress the demographic in balance and increase support for the continuance of demand for existing services and facilities. It is considered that the site previously promoted through the Call for Sites exercise reflects the themes and aims of the emerging Local Plan. Summary of Comments: We support the key themes.