S/CB: Cambourne

The consultation proposes the identification of Cambourne as “a broad location for future growth in the 2030’s to respond to the opportunity that will be provided by the proposed East West Rail that includes a station at Cambourne” (page 99). It is proposed that 1,950 dwellings will be delivered, but the consultation document does not specify a location or clear timescale for delivery. This represents a significant risk in terms of housing land supply as it depends upon the EWR programme, which could easily slip.

We would question how a ‘broad location for future growth’ for this strategic-scale development can be allocated within a local plan without an identified site that can be assessed and appraised. This proposal is entirely dependent upon a station being identified by the EWR Company, and yet there is no commitment to consulting with them or the associated programme.

The EWR project involves many uncertainties regarding both the route and the proposed stations, in addition to a complex legal process that will be necessary to facilitate its delivery. Even assuming that matters will be resolved and the scheme will proceed, we consider that there is a limited prospect of achieving 1,950 dwelling completions during the period to 2041.

Any new allocations (in additions to the existing West Cambourne West) will need to be well integrated with the new E/W rail station location and vice versa so that the new station is integral with the development of the town. As part of this, the RSPB would have concerns about significant development north of the A428, which might put recreational pressure on SSSIs like Overhall Grove and Elsworth Wood. Any new development would need adequate green infrastructure provided on site to provide Suitable Alternative Natural Greenspace (SANGs).

As set out in our comments on Policy S/DS, we do not consider there to be sufficient certainty surrounding the proposed extension to Cambourne to justify an inclusion of 1,950 dwellings towards the housing supply within the Plan period. This is particularly as Annex I to Appendix E of the Sustainability Appraisal states in relation to growth in Cambourne, that ‘the allocation of a specific area or quantity of growth has been rejected.’ We question therefore the rationale for including 1,950 homes within the supply, and contending the Plan is capable of meeting the objectively assessed housing need.

As acknowledged by the Councils, the exact locations for the East West Rail route and station are unknown. Additionally, the timescales for the delivery are also unknown, which adds further uncertainty as to anticipated delivery of housing before 2041.

Whilst we do not disagree with Cambourne as a location for future growth, we dispute that there is sufficient certainty surrounding the delivery of a further 1,950 homes within the Plan period within Cambourne. We consider that additional sites should be identified to ensure greater certainty that the objectively assessed housing need can be met within the Plan period.

Axis Land Partnerships wish to object to the assumed housing trajectory lead in time and build out rates for site allocation S/CB. Please see Station Fields Representations Report December 2021 (submitted under response to Policy S/DS) - Section 2 Appendix 1 Tables 1 – 4 ID: 59040

There is currently no clarity from government on whether the full East West rail route will be funded following the Budget. Furthermore, there is no mention in the S/CB Policy commentary of consultation with the East West Rail Company or comfort around their timetable for delivery. In the absence of this and potential delay to approval of the both the routing of the railway and the new station, the Local Plan should look elsewhere in the plan area for a strategic growth location that can deliver more readily without dependency on upfront major infrastructure delivery.

Cambourne Town Council objects to the policy in its current state as there is so much uncertainty on the delivery of a station in Cambourne. any allocation should be tied to the delivery of the East West Rail station at Cambourne.

Cambourne Town Council objects to the policy in its current state and would make the following comments:
- Object to any allocation of new homes for Cambourne until a final decision has been made on East West Rail and funding committed to the project. The prospect of a railway station is the only reason that Cambourne is considered a sustainable location for growth and until this is secured, no allocation should be progressed.
- Given the inherent uncertainty of delivery largescale infrastructure, any allocation of new homes in Cambourne should specifically state that planning permission will not be granted until work commences on a Cambourne Station and no new homes will be allowed to be occupied until the station and East West Rail services are operational.
- Object to all potential development locations to the south, west and south-east of Cambourne. In all these locations there would be a major adverse impacts on existing road networks through the town, a major adverse impact on high-quality landscapes to the south of the town and a major impact on Cambourne’s country park and its value for people and nature.
- The only option for potential growth that is supported by Cambourne Town Council (with the caveat that it must be contingent on the delivery of a railway station) is to the north of A428. This is also the Town Council’s preferred location for a station.
- I would also raise a concern regarding the delivery of additional dwellings to the north of Cambourne within the proposed plan period to 2041. Cambourne currently comprises c.4,250 new homes which were delivered over approximately 22 years from 1998 to 2020. This gives an average delivery rate of just under 200 dwellings per annum (dpa). If the c.5,850 dwellings already allocated at West Cambourne and Bourn Airfield are to be delivered by 2041, a delivery rate of c.300 dpa will be required and if an additional 1,900 dwellings are expected to be delivered in Cambourne on top of this, an average delivery rate almost 400 dpa will be required. This is highly unrealistic as there is a limit on the number of dwellings the local market will be able to absorb annually.
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It is noted that this proposed allocation responds to the East West Rail proposal which includes a new station at Cambourne. However the preferred route for the new rail line has not been announced.

The National Trust supports the principle of improved access to green transport and is neither for nor against the proposal of EWR. However, any such growth and development could place additional recreation pressures on Wimpole Estate and have potential impacts on our nature conservation assets (notably SSSI/SAC but also priority habitat and species, and County Wildlife Sites (CWS)), infrastructure and visitor management of the site.

Located in South Cambridgeshire, the Wimpole Estate is owned and managed by the National Trust. It lies approximately 13 km to the west of Cambridge and prior to the pandemic attracted some 400,000 visitors per annum. Wimpole Hall is a Grade I Listed Building set within a Grade II* Registered Park and Garden which includes the farmed estate and extends over an area of 1,200 ha. The property as a whole contains 30 listed buildings and structures of which three, including the Gothic Tower (Folly Castle), are Grade II*, and a Scheduled Monument comprising the remains of the Romano British settlement at Arrington. The estate is the largest of its kind in Cambridgeshire and a key attraction is its landscape setting, including the 4 km long South Avenue, with extensive views to the Royston Hills.

Existing New settlements
26. CPRE objects strongly to Policy S/CB: Cambourne and the proposed further expansion of Cambourne West.
This is an object lesson in how urban sprawl occurs when there are no insurmountable natural barriers to
stop it. Cambourne was designed as a discrete ‘village’ development to take up overflow from Cambridge
in order that the City’s character could be retained. This policy will take up further productive farm land
and will lead to a never-ending cycle of demand for additional development. Our concern is that in the
longer term, the extension of Cambourne and proposed and current developments around St Neots
towards Bedford along the A428/A421 main route will generate further pressure for development until
Cambridge is joined to Bedford in one long urban sprawl.
27. CPRE understands Policy S/NS to carry forward the existing allocations for new settlements Northstowe,
Waterbeach and Bourn Airfield. However, CPRE is very concerned indeed by the poor building control, lack
of democratic control of detailed planning decisions, the damage to underground water bodies, increasing
flood risk, lack of engagement with local communities and lack of engagement with local expert and
statutory bodies such as the local Internal Drainage Boards which is occurring as development proceeds at
two of these sites, Northstowe and Waterbeach. This approach to planning is going to lead to disaster for
the planning authorities, for residents and for the custodians of the water resources. Before, any further
permissions are given within these allocations, CPRE considers it absolutely essential that these issues are
addressed and any problems resolved.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Need to explore how this will function with nearby existing villages. Concern about landscape and habitat harm associated with continuing expansion and risk of loss of identity of surrounding villages, as well as erosion of the green belt.

Representations to the Greater Cambridge Local Plan - The First Proposals Regulation 18 Consultation
West Cambourne,

On Behalf of MCA Developments Ltd November 2021

Contents
1. Introduction 3
2. Vision and Development Strategy 4
3. New Settlements – Cambourne 8

Nichola Traverse-Healy nichola.traverse-healy@turley.co.uk
Client
MCA Developments Ltd

1. Introduction

1.1 These representations are submitted by Turley on behalf of Taylor Wimpey UK Ltd and the Vistry Group (the applicants) who together comprise the consortium MCA Developments Ltd (MCA (herein referred to as MCA), in response to the Greater Cambridge Local Plan – First Proposals Regulation 18 Consultation (January 2020). MCA are the developers behind Cambourne, a maturing new settlement, located within the administrative area of South Cambridgeshire (SCDC) approximately 7 miles to the west of Cambridge. The aim of this document is to assist the Council in formulating their Local Plan.

1.2 We have set out below responses to the questions raised in the Draft Consultation Document in the order in which they appear.

1.3 The remaining part of this document is structured as follows:

• Chapter 2 – Vision and Development Strategy
• Chapter 3 – New Settlements: Cambourne
• Chapter 4 – Conclusion

1.7 MCA would be pleased to discuss any aspect of these representations in more detail if this would be of assistance to the Council and we look forward to engaging positively with the Council and other stakeholders in the ongoing preparation of the emerging Local Plan

2. Vision and Development Strategy

Vision

2.1 The proposed Vision for Greater Cambridge is set out at page 20 of the Draft Local Plan and states that:

“We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

2.2 Whilst MCA supports the Council’s objectives with regards to climate changes and protecting the environment, it is disappointing that the Vision as currently drafted makes no reference to the Oxford-Cambridge Arc.

2.3 The Oxford-Cambridge Arc is an area covering Oxford, Milton Keynes and Cambridge, identified by the Government as a unique opportunity to become an economic asset of international standing. In July the Government held a 12 week consultation which closed on 12 October 2021 seeking views on the vision for the Arc. The consultation document ‘Creating a vision for the Oxford-Cambridge Arc’ (July 2021) confirmed that it is still the Government’s intention to prepare a ‘Spatial Framework’, which will provide a national planning policy framework for the Arc.

2.4 As set out at paragraph 1.1 of the Government’s consultation document the Oxford- Cambridge Arc ‘is a national economic priority area’. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. As advised by the National Infrastructure Commission, without urgent action, a chronic under-supply of homes could jeopardise growth, limit access to labour and put prosperity at risk.

2.5 If the Arc to reach its full potential local authorities will need to plan positively in their areas to deliver the transformational growth required. On this basis we would suggest that the Vision is revised as follows:

“Greater Cambridge is a leading UK and global hub of innovation, which plays a key role in the internally recognised Oxford-Cambridge Arc. We want Greater Cambridge to be a place of great prosperity and innovation where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

Policy S/JH: New Jobs and Homes

2.6 Policy S/JH of the Draft Local Plan proposes to meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year

2.7 For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.

2.8 For Greater Cambridge the housing need using the Standard Method would equate to 1743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario, the modelling predicted that 78,700 jobs would be required over the plan period.

2.9 Whilst MCA is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.

2.10 We would strongly advise the Council to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.

2.11 As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

Policy S/DS: Development Strategy

2.12 At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.

2.13 To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:

• North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.

• Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.

• Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.

• Expansion of Cambourne to around 2,000 new homes; and
• Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.

2.14 MCA strongly supports the proposed expansion of Cambourne for circa 2000 homes, which aligns with the Councils’ objective to provide jobs and homes in close proximity to major public transport routes. As stated page 44 of the Draft Local Plan locating growth at Cambourne takes advantage of the proposed new East West Rail station at Cambourne and the Cambourne to Cambridge Public Transport Scheme being brought forward by the Greater Cambridge Partnership.

2.15 Notwithstanding these proposed new transport links, Cambourne is an established and successful new settlement which benefits from a range of services and facilities, including three primary schools, secondary school, library, health centre, Morrison’s superstore, pub, leisure centre, numerous restaurants and takeaways together with a number of retail uses and professional services within two parades of shops.

2.16 The development of Cambourne West, a fourth linked village will further enhance the range of services and facilities at Cambourne. In 2017 South Cambridge District Council (SCDC) granted planning permission for the development of 2350 homes at Cambourne West including a new retail and community hub, two primary schools and an extension to the existing secondary school.

2.17 Cambourne is one of the largest and most sustainable settlements in Greater Cambridge, which since development commenced in 1998 has continued to make an invaluable contribution to Greater Cambridge’s housing land supply. The settlement is not only well placed in terms of access to major transport corridors and new infrastructure, including

the new rail station as part of East West Rail but benefits from an extensive range of shops, services, facilities and recreational opportunities. For the reasons set out above, Cambourne is considered a logical location to accommodate additional growth to meet the needs of South Cambridgeshire and Cambridge City. The proposed expansion of Cambourne is considered a soundly based strategy, which is justified by the Councils’ supporting evidence base and will deliver sustainable development in accordance with the policies of the NPPF.

Policy S/SH: Settlement Hierarchy

2.18 The purpose of Policy S/SH is group together similar settlements into categories that reflect their scale, characteristics and sustainability. In view of its sustainable credentials MCA strongly supports the Councils decision to reclassify Cambourne from a rural centre to a town.

2.19 As set out at page 49 of the Draft Local Plan:

“Cambourne is a growing centre, with a growing level of services, facilities and transport opportunities. This has been recognised by it now having a town council, and it is considered that this should be recognised in the local plan”

2.20 Cambourne performs far beyond the role of a rural centre and MCA agrees that this should be recognised in the new Local Plan. Given the excellent range of services and facilities in Cambourne and the wider catchment it serves, the Councils’ are considered completely justified in the new Local Plan to include Cambourne in the ‘Towns’ category of the settlement hierarchy.

3. New Settlements – Cambourne

3.1 Policy S/CB: Cambourne of the Draft Local Plan seeks ‘to identify Cambourne as a broad location for longer term strategic scale growth’ and carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’.

3.2 As stated previously in our response to Policy S/DS: Development Strategy, given Cambourne’s position in the settlement hierarchy and proximity to new major public transport schemes, MCA strongly supports the Councils’ decision to identify Cambourne as a broad location for longer term strategic scale growth. Cambourne has been identified as the location for a new railway station as part of the East West Rail scheme to connect Oxford with Cambridge and potentially beyond, along with the Cambourne to Cambridge public transport scheme being brought forward by the Greater Cambridge Partnership. The Draft Local Plan recognises that these schemes ‘provides an opportunity to consider how further development could make the most of these connections, but also make the overall Cambourne area a more sustainable place’.

3.3 MCA is also supportive of the Councils’ decision to carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’. Policy SS8: Cambourne West in the adopted South Cambridgeshire Local Plan (2018) currently requires at part 12 (g) ‘Vehicular access to be provided through an enhanced route through the Business Park, one or more access points from the Caxton Bypass, and via Sheepfold Lane’

3.4 The outline planning application for Cambourne West, approved in 2017, did not include an access through the Business Park, as this land was under the control of a third party. As set out in the Committee Report, relating to the West Cambourne outline planning application, dated 11th January 2017, Officers were satisfied to approve the application without the business park access but on the basis that the ‘opportunity would still exist with any future application for the development of the business park land’. To provide the Council with comfort that the business park access could be delivered in the future, the site wide masterplan submitted by MCA as part of the planning application was designed to facilitate an access. In addition plans were submitted as part of the application, demonstrating how the business park road could be brought up to adoptable standards.

3.5 In May 2021, it was announced that the South Cambridgeshire Investment Partnership (SCIP) a 50:50 partnership between South Cambridgeshire District Council and the Hill Group, would be purchasing the remaining undeveloped land at the Business Park. It is our understanding that it is the intention of SCIP to submit an application for the development of the site to provide 275 homes.

3.6 As set out at paragraph 260 of the Committee Report, relating to the West Cambourne outline planning application, Officers stated that:

“…the council would continue to encourage the delivery of an all vehicle access through the business park due to the benefits through greater connectivity that it would bring for early Cambourne West residents”

3.7 A top priority of the Draft Local Plan is to minimise vehicular movements. It has always been the Councils’ aspiration that walking and cycling links through the business park would be delivered as part of any vehicular connection. This would mean greater permeability between Cambourne and Cambourne West for pedestrians and cyclists. Given that the legal impediments to the delivery of the road no longer exist and for the benefit of Cambourne residents, it should be a requirement in Policy S/CB: Cambourne of the new Local Plan that future planning applications for the development of land at the Business Park should be required to provide an enhanced access through the Business Park to the development at Cambourne West.

3.8 As has been the approach at North West Cambridge, when drafting Policy S/CB: Cambourne for the next stage of the Local Plan, the Councils’ should be seeking to maximise the opportunities for intensifying development within the existing boundary of Cambourne West. The updated policy should enable the development of additional dwellings on the site beyond those identified in the current outline planning permission at Cambourne West, provided through changes to the dwelling mix and appropriate intensification of development areas that have yet to be built. MCA are currently undertaking a detailed review of the site wide masterplan, and will advise in due course the likely increase in dwellings that could be achieved.

3.9 Under Policy SS/8 of the adopted Local Plan any future planning application would need to provide an equivalent quantity of employment land to that lost on the Business Park (8.1ha), to be delivered in the northern part of the Cambourne West site rather than its current location. The outline planning application submitted by MCA and approved by SCDC made for provision 6.25ha of employment space for offices. At the time the outline planning application was being determined, SCDC provided limited justification with regards to the need for this level of employment land at Cambourne West. As set out at paragraphs 208 and 209 of the Officer’s Committee Report dealing with the application:

“The history of Cambourne has shown that the employment and retail units are rarely built on a speculative basis and have only come forward when an occupier has been identified…. the reality is that the majority of employment in Cambourne is outside the business park and can be found in the schools, hotel, retail units etc. There are also a large number of residents who run successful companies out of their homes.”

3.10 Current lettings data from CoStar, the commercial property database, provides a more up to date indication of the role of Cambourne in accommodating demand for office space that arises throughout South Cambridgeshire on an annual basis.

3.11 CoStar has recorded some 1,125 lettings of office space throughout South Cambridgeshire over the last ten years to November 2021, but only 34 – or little more than three lettings per annum, on average – have been in Cambourne1. It has therefore been the location for only 3% of all such lettings in South Cambridgeshire, which is

1 Lettings have been assigned to Cambourne based on postcodes

notable where the town accommodates more than twice as much (7%) of the district’s population2.

3.12 While around three lettings have been recorded annually in Cambourne over the whole decade, this had been slowing even prior to the pandemic as shown by Figure 1 below which tracks the annual average over rolling three year periods. This shows, for instance, that there were more than four transactions per annum on average in the three years to November 2016, which remained relatively stable over the subsequent two years. This was followed, however, by the recording of less than three office lettings per annum over the three years to November 2019, which has fallen even further to the point where there have been only 1.7 lettings per annum over the past three years – equivalent to one office letting every seven months.

Figure 1: Office lettings per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.13 The amount of office space taken up in Cambourne has also been falling, averaging nearly 4,900sqm per annum over the three years to November 2016 before reducing by almost a fifth to a little under 4,000sqm per annum over a similar period to November 2019, predating the pandemic. This has since more than halved to the point where only 1,700sqm of office space has been taken up annually in Cambourne over the last three years, the reduction being far starker than seen across South Cambridgeshire where the rolling average has fallen by only a quarter.

2 ONS (2021) Population estimates, mid-2020. This is the number of residents living in the officially defined Built-up Area (BUA) of Cambourne, divided by the number of people living in South Cambridgeshire (10,544/160,904)


Figure 2: Office space leased per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.14 The above analysis indicates that there has long been relatively limited demand for office space in Cambourne, which appears to have reduced even further during the pandemic. On this basis, we do not consider it justified and appropriate under proposed Policy S/CB to reserve the entire 6.25ha of employment space at Cambourne West for the provision of further office space.

3.15 For the reasons stated above and to be considered sound, MCA request that in drafting Policy S/CB the Council ensures the following:

• There is an requirement as set out under Policy SS/8 of the adopted Local Plan, to provide an enhanced access through Cambourne Business Park to link with the development at Cambourne West;

• The Policy is not overly prescriptive and allows for the intensification of development areas that have yet to be built at Cambourne West; and

• The Policy promotes and allows for the development of residential uses on land previously identified for employment on the Cambourne West Masterplan. This is on the basis of clear evidence demonstrating that the market for employment floorspace in this location is limited.


Turley Office 8 Quy Court Colliers Lane Stow-cum-Quy Cambridge CB25 9AU

T 01223 810990

The Cambridgeshire Development Forum brings together a diverse range of organisations with a shared commitment to the delivery of high-quality developments in the Cambridgeshire region. We include promoters, developers, housebuilders, housing associations, planners, advisers, law firms, design companies, transport planners and related professionals in our membership. We do not promote individual sites and are focused on achieving more effective delivery of plans in our region. We value the engagement we receive from local planning authorities, the Combined Authority and Central Government. We welcome this opportunity to respond to the consultation on the Local Plan.

These representations reflect shared views among our members but should not be interpreted as representing the views of any individual member organisation in membership of the Forum.

Responses:

Q1: the additional 550 homes a year should be regarded as a minimum figure, which should be reviewed regularly in relation to the growth in jobs within the travel-to-work areas

Q2: the spatial strategy for development should focus the larger development sites in locations which offer public transport options to reach major employment centres. Development in rural locations of an appropriate scale should not be deterred as and when more sustainable personal transport options are available, eg EVS using renewable energy.

Q3: The Cambridge East Development should be connected directly to the City centre and the inner urban ring of development at the Biomedical campus, North Cambridge and the Science Park, Eddington and West Cambridge. But it should not be a wholly residential development. It should be a mixed development including commercial, residential and leisure/ retail options. It should be envisaged as a distinct place, with its own character. It could include high-rise apartments suitable for the younger workers who comprise many Cambridge area workforces.

Q4: North-East Cambridge should offer a residential opportunity for those employed in the technology sectors around Cambridge, including a significant component of affordable housing for market sale, market rent, shared ownership, and social housing.

Q5: development in and close to the biomedical campus should be prioritised for the healthcare, research, and technology cluster; significant adjacent sites should not be developed for large-scale residential purposes.

Q6: Cambourne should provide jobs near the new homes and include more employment space potentially including a commercial hub based on any new railway station above the A428.
Outside this commercial and retail hub, Cambourne should be focused on the large-scale offering of homes for families of those working across the Cambridge area.

Q7: in the southern rural cluster, opportunities for development on brownfield sites and for rural diversification, with small business-related developments should not be excluded.
Related residential development on smaller sites should also be accommodated, taking account of the Neighbourhood Plans. A priority should be given to sites in villages on rail routes, at public transport nodes and within public transport corridors. Subject to the decisions to be made concerning the East-West Rail Link, the option for significant growth and/or new settlement in appropriate locations that maximises the use of all forms of public transport should be considered as additions to the sites proposed.

[Q8-13 omitted]


We have welcomed the engagement with the Greater Cambridge Shared Planning team, and look forward to this continuing through this process in future discussions.

Cambridgeshire Development Forum December 2021

First Proposals Text: ‘What will this policy do? - Identify Cambourne as a broad location for longer term strategic scale growth as an expansion to Cambourne, and will provide continued guidance for the development of the existing allocation at Cambourne West’

Response: It was clear from the outset of the last Local Plan that it was the Planning Authority's intention to develop Cambourne into a ‘ new town by stealth'. StopBAD and Bourn Parish Council levelled this challenge during all stages of the consultation, and at the Examination in Public, and our objections were dismissed. It's now an irrefutable fact that we were right. It frustrates us that the Planning Authority misrepresented their intentions and it makes it difficult for us to have any faith in the public consultations undertaken by the Planning Authority. The term 'strategic scale growth' is unacceptably vague and suggests a licence to do whatever the Planning Authority pleases. As evidence of the lack of transparency for the development of Cambourne we reference https://www.scambs.gov.uk/planning/new-communities/cambourne/about-cambourne/ The conduct of the Planning Authority towards the existing historic villages of this area of South Cambridgeshire has been questionable since (and before) the initiation of the previous Local Plan process. The outcome of the Local Plan process makes this clear. The great majority of local residents in the affected villages around Bourn Airfield and West Cambourne objected to both settlements yet they went ahead. Policy S/CB marks a new low in the Planning Authority’s understanding of local concerns. In summary it shows that a new town of 25,000 inhabitants and nearly 12,000 houses can be built alongside villages that strongly object as long as the creeping, incremental nature of the development is concealed. It’s basically development 'death by a thousand cuts'.

First Proposals Text: ‘Proposed policy direction - The policy will set out the intention to identify Cambourne as a broad location for future growth in the 2030’s to respond to the opportunity that will be provided by the proposed East West Rail that includes a station at Cambourne. The overall aim for an expanded Cambourne is to provide sufficient critical mass to perform the following role as a:
• Well-connected place through high quality public transport, cycling and walking facilities
• South Cambridgeshire town for the 21st century
• Growing employment centre to provide local opportunities for its residents and nearby communities
• A place that meets the day to day needs of its residents.’

Response: This proposed Policy Direction is proof positive of the Planning Authority’s deception. Cambourne is expected to be a 'South Cambridgeshire town for the 21st century’; it needs to expand to provide critical mass. When did this become the aspiration? What involvement did local people have in setting this aspiration? Who is setting the agenda here? It certainly isn’t local people.

First Proposals Text: ‘Future development at Cambourne will need to consider:
• How to integrate with and maximise the opportunity provided by East West Rail.
• The role of the new development in Cambourne as a place, and how it can contribute towards the achievement of net zero carbon.
•The relationship with Cambourne and Bourn Airfield, and how to make the area more sustainable, through the mix of services, employment and transport opportunities offered by the area as whole.
• The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy.
• How the place will develop over time, and the infrastructure needed to support different stages during its development.
• Making effective connections within the new development and with Cambourne for public transport and active travel, as well as connections to surrounding villages so they can also benefit.
• Be structured around and have local and district centres that can meet people’s day to day needs within walking distance, including responding to changing retail and working patterns
• How it can help deliver the Western Gateway Green Infrastructure project, and in doing so positively engage with its landscape setting, as well as recreation and biodiversity enhancement opportunities such as woodland planting.
• Take opportunities to reduce flood risk to surrounding areas, that take innovative solutions to the management and reuse of water.

The following existing allocation for a new mixed-use development at Cambourne West is proposed to be carried forward, but to be expanded to include the full extent of the planning permission:
• SS/8: Cambourne West

A map showing the boundary of this allocation can be found at the end of this document.’

Response: We are concerned that the considerations for the future development of Cambourne make no mention whatsoever of mitigating the impact on landscape and the character of older, more established, communities. All the considerations relate to the future. There is nothing at all in this topic that talks about preservation, or sensitivity to what predates Cambourne. There are no comments about enhancing the existing setting. The no reference to the inevitable traffic generation that an-ever expanding Cambourne will generate. Are these not important considerations?

First Proposals Text: ‘Why is this policy needed? - Cambourne has been identified as the location for a new railway station as part of the East West Rail scheme to connect Oxford with Cambridge and potentially beyond. Along with the Cambourne to Cambridge public transport scheme being brought forward by the Greater Cambridge Partnership, it provides an opportunity to consider how further development could make the most of these connections, but also make the overall Cambourne area a more sustainable place. National planning policy says that plan making should look to the opportunities provided by major new infrastructure.

It is important to recognise that our evidence says that large scale development at Cambourne would have landscape impacts and that these would be hard to address. However, when considered in the context of the significant economic and carbon benefits of locating development at the proposed new rail station at Cambourne, it is considered that the benefits are likely to outweigh the level of landscape harm. This will be explored further as part of preparing the draft local plan, but the Councils are clear that development will need to be a landscape led scheme to minimise impacts in the wider landscape and to have a focus both on place making for the expanded town, and delivery of the wider vision for green infrastructure set out in the plan, including supporting the objectives for Strategic Green Infrastructure Initiative 8: Western gateway multifunctional Green Infrastructure corridors (see BG/GI Green Infrastructure).’

Response: The Policy finally acknowledges that 'It is important to recognise that our evidence says that large scale development at Cambourne would have landscape impacts and that these would be hard to address.’ But in the next sentence the Policy brushes aside these concerns and implies that landscape impacts are a necessary casualty that are trumped by carbon benefits. This is a particularly difficult pill for Bourn Parish Council to swallow given the levels of carbon generation that the Planning Authority caused when they conceived of Cambourne (but obliged its residents to travel to work by car). The double standards are clear. If we are now justifying development based on carbon benefits then there should be more development in the Green Belt where walking and cycling to Cambridge become real options for commuters.

We’re not blessed with a great deal of quality landscape in South Cambridgeshire. The Planning Authority now want to build over what little landscape of note we have. Bourn Valley, south of Cambourne, must surely be protected from development. The very notion that carbon benefits are preferred over landscape harm has to be the worst argument to justify development that we have ever heard and will have environmentalists pulling their hair out. In our opinion, this element of the Policy needs serious review.

First Proposals Text: ‘Identifying the area for additional development should not simply be about delivering more housing. It needs to explore how this area including Cambourne and Bourn Airfield and nearby villages will function as a place, and its relationship with Cambridge, in order to enhance its sustainability. This means looking at a mix of services, facilities and employment in the area, and planning new development to enhance the role of the place. It means looking at connections between places within the area, so these opportunities are shared and reliance on private car travel is reduced.’

Response: We’re not sure what point this section is trying to make. It sounds vaguely aspirational. What exactly does 'enhance the role of the place’ mean? This part of the Policy is far too vague.

First Proposals Text: National planning policy allows for longer term growth in plans to be identified as broad locations, where the exact quantity, locations and design will be defined through future plan reviews. Given that the East West Rail route and station location at Cambourne have yet to be confirmed, it Is too early to identify a specific development area and amount of development.

Response: This is the section of the policy that most concerns us. You say that the identification of broad locations is allowed by National Planning Policy. What is meant by broad locations? South Cambridgeshire is a broad location but we suspect you mean growth around Cambourne and, worryingly, in areas around Cambourne that would have landscape impacts. Why is the policy so vague?

You imply that the Policy is intentionally vague until the station location for Cambourne is determined by EWR. Several sites in the search for sites process would appear to be in play - sites to the north and south of Cambourne. Which of these is to be developed appears to be within the gift of EWR. Wherever the station is built will determine where 1950 houses will be built. The Policy is worryingly vague and Bourn Parish Council will object to the inclusion of this Policy in the new Local Plan until such time as there is clarity on where the 1950 houses are to be built.

First Proposals Text: What consultation have we done on this issue? - There was no specific consultation on this issue in the First Conversation consultation, but we did ask for views about focusing development on transport corridors. There was broad support for this approach, and focusing development at public transport nodes.

Response: We will expect there to be a consultation on this specify Policy. We do not accept that there is broad support for this Policy based on the broad support there was for focusing development on transport nodes in the First Conversation consultation. There are too many specific issues related to further development Cambourne to draw that conclusion.

First Proposals Text: ‘What alternatives did we consider? No Policy alternatives to allocating development around Cambourne were considered as part of consideration of alternative Strategic Spatial Options.

Response: Why was no consideration given to the alternatives to allocating development around Cambourne? This ommission must call into question the thoroughness of the process.

First Proposals Text: Supporting topic paper and evidence studies
Greater Cambridge Local Plan: Topic paper 1: Strategy


Response: We’d like draw the Team's attention to a quote from the Local Plan's Policy Direction. 'We propose to reinforce the distinctive character of our city, towns and villages through developing sites that can be well-integrated with existing communities. Using less land for development reduces our carbon emissions, and allows more space for nature and wildlife..’

We will be most interested in how these goals are applied to the proposed development around Cambourne. How will the Planning Authority reinforce the distinctive character of the villages around Cambourne? How will they develop sites that integrate with existing communities? How will they allow more space for wildlife and nature?

1.0 Introduction

1.1. Savills is instructed to act on behalf of Martin Grant Homes Ltd (MGH). MGH controls a substantial area of land to the north of (and adjoining) Cambourne (referred to as North Cambourne).
1.2. Our representations are structured to respond to relevant sections of the Greater Cambridge Local Plan (GCLP) ‘First Proposals’ consultation. This follows on from our representations to the ‘First Conversation’ in the previous stage of the Local Plan during 2020, and our earlier response to the Call for Sites in 2019.
1.3. This representation is accompanied by a vision document and illustrative masterplan (under separate cover), setting out the key strategies and proposals for North Cambourne, and by other technical reports on transport and landscape. The vision document and illustrative masterplan explain how new employment could be delivered together with new infrastructure, facilities and housing, creating a new sustainable community, that is well connected to Cambourne and to Cambridge as well as providing improved access to services and facilities for existing Cambourne residents.
1.4. Development at North Cambourne is a highly sustainable option for accommodating both new housing and new jobs in the Greater Cambridge area. There is significant opportunity for development here of a scale that can promote self-containment and consolidate the functions of the existing settlement. This will support internalised movements using active travel and sustainable modes, minimising carbon impacts as compared to other development options and thereby addressing the Climate Emergency that the Greater Cambridge local authorities have declared.
1.5. The Government has identified the Oxford-Cambridge Arc as a key corridor for growth in the country. This reflects the fact that the fundamentals of the economy in Cambridge are very strong, with certain key sectors clustered in the area including Life Sciences and Bio-Medical. The Arc therefore represents one of, if not the best, opportunity for delivering growth where the economy can sustain it, where productivity is high, and where there are huge opportunities to improve equality and sustainability .
1.6. The narrative as a whole indicates MGH’s general views, as well as indicating areas of support or objection in relation to the First Proposals emerging policies and general direction of travel for the Local Plan. The headings and sub-headings in the following sections relate to the main sections and policies in the First Proposals consultation.
1.7. MGH has already consulted widely among local communities on its proposals for North Cambourne and will continue to participate in the discussion about where growth should take place in Greater Cambridge in order to appreciate, advance and fully embed all of the benefits that development can deliver here, as well as understand and respond to local concerns.
 
2. Vision and Development Strategy

Vision and aims
2.1. Helping Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water efficiency, and is resilient to current and future climate risks, requires bold action - and promptly. MGH shares the Councils’ commitment to delivering homes, jobs and infrastructure in the most sustainable places that will secure this transition in a timely way.
2.2. We support the emerging Local Plan aims to;
• increase and improve networks of habitats for wildlife and green spaces for people;
• create new distinctive and inclusive places that will help people to lead healthier and happier lives, where there is less reliance on travel by unsustainable modes;
• encourage a flourishing mixed economy, providing a range of jobs whilst protecting the global reputation of Greater Cambridge for innovation;
• plan enough homes to meet the needs of the area, including affordable housing and a wide range of housing to suit the needs of the community;
• plan for transport, water, energy and digital networks; and health, education and cultural facilities; in the right places and built at the right times to serve the growing communities;
• help to tackle the climate emergency through proactive interventions to mitigate carbon emissions through sustainable design measures, eliminating the need to use fossil fuels within buildings and achieving net zero emissions through on-site measures.
2.3. In the current consultation the Greater Cambridge authorities have indicated that location is the single biggest factor in impacting on carbon, albeit recognising that it is not suitable to focus on any one broad location. In order to balance this, we understand that the combined authority is proposing;
1) a blended strategy – taking the most sustainable elements of the Western Cluster / Public Transport corridors (incorporating Cambourne) and including them, to meet a variety of needs; and
2) a focus on development at a range of the best performing locations in terms of minimising trips by car.
2.4. In addition, the Greater Cambridge authorities have indicated that mitigating carbon emissions from new buildings will be a key issue in delivering the authorities’ longer-term net zero carbon objectives. With South Cambridgeshire having declared a climate emergency in 2019, it now aiming to halve emissions by 2030 and reduce them to zero by 2050. In terms of the effect of these goals on emissions from new development, we understand that the combined authority is proposing;
1) a net zero carbon policy for new development; and
2) a focus on calculating whole life carbon emission from new development.
2.5. In the public feedback sessions held so far as part of this First Proposals consultation, a focus on public transport corridors and the densification of the Cambridge urban area were the top options preferred by respondents.
2.6. Importance was also given in the feedback sessions to the opportunity to deliver sufficient jobs as well as homes, and the particular recognition of the benefits that East West Rail (EWR) brings to Cambourne. The preference being to expand here, rather than create further new settlements.
How much development and where? - general comments
2.7. The NPPF, at paragraph 61, sets a requirement to determine minimum housing numbers using the standard method. At paragraph 81 the NPPF also states that significant weight should be placed on the need to support economic growth and productivity, and that policies should address the specific locational requirements of different sectors. The NPPF states that this is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential. This includes making provision for clusters or networks of knowledge and data-driven, creative or high-tech industries, but also recognising all of the supporting roles that employment and services need to provide to support communities. Paragraph 105 of the NPPF also sets out the requirement that the planning system should actively manage patterns of growth in support of sustainable transport objectives. Significant development, it states, should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes, which can help to reduce congestion and emissions, and improve air quality and public health.
2.8. The location of Greater Cambridge within the national economic priority area of the Oxford to Cambridge Arc lends even further weight to the need to support this growth. The Arc already supports two million jobs and brings £110 billion to the UK economy per annum, which is over 7% of England’s economic output (Gross Value Added) . The emerging Spatial Strategy and Vision for the Arc suggests that by 2050 the economic output could increase by between £80 billion and £160 billion per annum, and up to a further one million jobs generated.
2.9. MGH supports the strategic ambitions to deliver substantial growth in the GCLP plan period to 2041, and in the wider Arc Strategy to 2050, and we have set out our position in more detail in the following sections.
2.10. The timeframes associated with plan making also need to be realistic. Paragraph 22 of the NPPF states that “strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
2.11. The updated Planning Practice Guidance (PPG) states that where the new policy applies, “the authority will need to ensure that their vision reflects the long-term nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan.”
2.12. A recent Ministerial Letter to the Chief Executive of the Planning Inspectorate confirms that the changes to the NPPF are intended to ensure that local authority plan preparation can continue “at pace while also ensuring that the government’s objectives are delivered”
2.13. For the strategic sites contained in the Plan, MGH suggests that it sets out and indicative plan for ‘future Growth Areas’ for the period to 2050, which aligns with the timescale for the Oxford to Cambridge Arc Strategy.

To date, Cambourne has grown rapidly but with a lack of strategic planning, leading to a deficit in infrastructure. We therefore broadly welcome the policy direction set out here and look forward to the further development of plans to achieve the stated aims.