Greater Cambridge Local Plan Preferred Options
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Greater Cambridge Local Plan Preferred Options
S/JH: New jobs and homes
Representation ID: 60509
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
Whilst Taylor Wimpey support that the Council have set a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth. This is particularly when considering the important strategic position of Greater Cambridge within the Oxford-Cambridge Arc and the clear aspirations for economic growth within the Arc. Clearly the Greater Cambridge Local Plan will also need to conform with the Spatial Framework for the Arc when prepared which will have the same status of National Policy.
The Council states that the new Local Plan will 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, which is rounded for the plan.
This figure equates to an average of 2,114 homes per annum, with a suggestion that this will meet an objectively assessed housing need for 2,111 homes per annum that has been rounded upwards in deriving the total figure. It is noted that the Plan seeks to provide for approximately 10% more homes than are calculated as being needed, a total of around 48,840 homes.
In justifying a housing need figure above the standard method, the First Proposals cite evidence assembled in the following two studies, with the higher need predicated on supporting anticipated economic growth within Greater Cambridge:
• Greater Cambridge Local Plan: Housing and Employment Relationships (November 2020), GL Hearn; and
• Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020), GL Hearn, SQW and Cambridge Econometrics.
The latter of these two studies presents two alternative forecasts of potential economic growth over the plan period:
• A Central Scenario under which 58,400 new jobs would be created, claimed to represent the ‘most likely outcome taking into account long term historic patterns of employment’ with the Housing and Employment Relationships study also describing it as ‘a ‘business as usual’ growth scenario’
• A Higher Scenario under which 78,700 new jobs would be created, with this ‘higher outcome placing greater weight on fast growth in the recent past, particularly in key sectors’ and the Housing and Employment Relationships study describing it as ‘a plausible but more aspirational growth outcome’.
The Housing and Employment Relationships study concludes that housing provision in line with the standard method will not support either of these economic growth scenarios. It estimates the housing need associated with supporting both as follows:
• Central scenario – 41,900 to 44,310 homes (1,996-2,110dpa) with the range reflecting alternative commuting assumptions, the upper end assuming that there is a 1:1 or balanced commuting ratio for new jobs and the lower end assuming continued in-commuting
• Higher scenario – 53,500 to 56,490 homes (2,549-2,690dpa) with the range again reflecting alternative commuting assumptions.
The proposed housing requirement evidently aligns with the Central scenario (58,400 jobs), with the First Proposals therefore not looking to provide the housing infrastructure that would appear to be needed to accommodate a more ambitious level of employment growth.
Whilst Taylor Wimpey support that the Council have set a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth. This is particularly when considering the important strategic position of Greater Cambridge within the Oxford-Cambridge Arc and the clear aspirations for economic growth within the Arc. Clearly the Greater Cambridge Local Plan will also need to conform with the Spatial Framework for the Arc when prepared which will have the same status of National Policy.
Comment
Greater Cambridge Local Plan Preferred Options
S/DS: Development strategy
Representation ID: 60510
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
Land north of Cambridge Road, Linton (HELAA site 51721)
As part of their strategy, the Council have stated that their 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. Whilst Taylor Wimpey do understand this approach by the Council, they do have some concerns in relation to how this strategy has been applied.
Firstly, many of the settlements within South Cambridgeshire are highly sustainable in their own right and benefit from excellent public transport links to Cambridge, and other destinations. Taylor Wimpey therefore consider that the Council should explore the option to deliver more housing in other sustainable settlements in order to provide a greater spread of housing distribution, provide a portfolio of types of sites to meet needs in a range of locations, ensure that there is a supply of housing that can be built out sooner within the plan period, and continue to support local services and facilities.
The proposed development strategy for Greater Cambridge directs the vast majority of growth to the Cambridge Urban Area, the edge of Cambridge and new settlements. Only a very small level of growth is directed to the Rural Southern Cluster and the Rest of the Rural Area. Of the allocations proposed, the vast majority of these are existing commitments (adopted allocations, sites with planning permission etc.). The Council are only proposing a need for an additional 11,640 homes to be allocated through the emerging Local Plan.
As part of their strategy, the Council have stated that their 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. Whilst Taylor Wimpey do understand this approach by the Council, they do have some concerns in relation to how this strategy has been applied.
Firstly, many of the settlements within South Cambridgeshire are highly sustainable in their own right and benefit from excellent public transport links to Cambridge, and other destinations. Linton is one such settlement, and further commentary on its position within the hierarchy is set out in the comments for Policy S/SH. Taylor Wimpey therefore consider that the Council should explore the option to deliver more housing in other sustainable settlements, including Linton, in order to provide a greater spread of housing distribution in the District and provide a portfolio of types of sites to meet needs in a range of locations. In doing so such housing distribution would still accord with the strategy presented by the Council, by providing housing in highly sustainable Linton.
Such housing delivery would help meet the needs of smaller settlements over the plan period, providing greater variety in the types and location of development delivered. It is important to highlight that the National Planning Policy Framework (NPPF) is clear in paragraph 69 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’ and that local planning authorities should ‘promote the development of a good mix of sites’. It is considered that the Council strategy focuses on the delivery of very large sites with a much lesser number of smaller allocations. Taylor Wimpey are therefore of the view that the Council should look to deliver a greater number of smaller allocations to ensure that there is a supply of housing that can be built out sooner within the plan period. The site in Linton is one such site that could be built-out relatively quickly.
Furthermore, paragraph 79 of the NPPF is clear that in order to ‘promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.’ By delivering more housing in settlements such as Linton, development will continue to support local services and facilities, supporting their retention and growth. This point is also recognised in the appraisal of spatial options set out within the Greater Cambridge Local Plan: First Proposals Sustainability Appraisal (October 2021).
Comment
Greater Cambridge Local Plan Preferred Options
S/SH: Settlement hierarchy
Representation ID: 60511
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
Land north of Cambridge Road (A1307), Linton (HELAA site 51721)
An assessment should be undertaken to support the emerging Local Plan to inform a review of the settlement hierarchy and it is considered such an assessment would conclude that Linton should be recognised for elevation in the hierarchy to a Rural Centre.
Linton benefits from a breadth of services and facilities. The village is also served by an excellent bus service.
Linton has also been subject to transport improvements through the Greater Cambridge Partnership Transport Projects. These works will therefore further enhance the sustainability of Linton.
Within the Sustainability Appraisal (October 2021) note is made of Linton benefitting from services and facilities, at a comparable level alongside Great Shelford and Sawston. Both of these settlements are Rural Centres, and it queried how Linton can be listed alongside these settlements, but at a lower position in the hierarchy. It is clear therefore that Linton should be classified as a Rural Centre.
Under this policy the Council set out a settlement hierarchy as follows:
• Cambridge
• Town
• Rural Centre
• Minor Rural Centre
• Group Village
• Infill Village.
This hierarchy is essentially the same as the adopted hierarchy in the South Cambridgeshire Local Plan (2018), with the addition of Cambridge and Town.
Within the First Proposals, Linton is identified as a Minor Rural Centre, which is again the same as adopted policy. This suggests that Linton is a mid-range settlement within the hierarchy.
Although an older document, the Village Classification Report (2012) sets out the review of the village hierarchy that informed the adopted Local Plan. This states that in the assessment ‘Cottenham, Bar Hill, Linton, Melbourn and Gamlingay perform significantly better in the scoring process than the other existing Minor Rural Centres.’ Given the time that has passed, with the intervening development and projected proposals through the emerging Local Plan, this only serves to further enhance the sustainability of Linton. An assessment should be undertaken to support the emerging Local Plan to inform a review of the settlement hierarchy and it is considered such an assessment would conclude that Linton should be recognised for elevation in the hierarchy to a Rural Centre.
Linton benefits from a breadth of services and facilities, which include but are not limited to, two primary schools, two secondary schools, doctors surgeries, a library, a bank, a Post Office, a pharmacy, a Co-op convenience store, several local shops and pubs/restaurants/takeaways, a village hall, a recreation ground with sports pitches and two churches. To the south of the A1307 there are also further services including a petrol station and various other premises at The Grip Industrial Estate including a gym and further shops, along with Linton Zoo. The village is also served by an excellent bus service providing services 7 days a week to Cambridge and Haverhill. On weekdays these services are approximately every half an hour.
All of these services and facilities would be accessible from the Land north of Cambridge Road, Linton site by foot or bicycle. The site is therefore a highly sustainable location for development.
Linton has also been subject to transport improvements through the Greater Cambridge Partnership Transport Projects. In particular, the Linton Greenway will ‘be an active travel route to make it easier for walkers, cyclists and horse riders to travel from Linton into Cambridge’. This work is ongoing and includes the following benefits to residents of Linton:
• Green active travel into and out of Cambridge for walkers, cyclists and horse-riders.
• Easy and safe travel to workplaces, local schools and colleges, shops and transport hubs.
• Links to the Cambridge Biomedical Campus, the Sawston and Melbourn Greenways and the Chisholm Trail.
• Wider existing footways and verges to provide a path for cyclists, pedestrians and horse riders (where feasible), separated from the carriageway.
• Improved footbridge and underpass on A11, including adding ramps and stud lights.
These works will therefore further enhance the sustainability of Linton, improving sustainable transport opportunities for residents, with the Land north of Cambridge Road, Linton site particularly well positioned to benefit from these enhancements.
Within the Greater Cambridge Local Plan: First Proposals Sustainability Appraisal (October 2021) appraisal of spatial options, note is made of Linton benefitting from services and facilities such as schools and doctors surgeries, at a comparable level alongside Great Shelford and Sawston. Both of these settlements are Rural Centres within the First Proposals, and it queried how Linton can be listed alongside these settlements as of equal service and facility provision, but at a lower position in the hierarchy. It is clear therefore that Linton should be classified as a Rural Centre.
Further commentary on this point is made in relation to the rural southern cluster below.
Furthermore, even as a Minor Rural Centre, Linton is not directed with any growth through allocations as part of the First Proposals. Despite the settlement hierarchy categorisation, Linton is clearly a highly sustainable settlement appropriate for growth. Taylor Wimpey suggest that the Council should reconsider their distribution of proposed allocation sites so that the best reflect the sustainability of settlements within the authority area. There should therefore be some housing delivery through the emerging Local Plan in sustainable villages such as Linton.
Comment
Greater Cambridge Local Plan Preferred Options
S/SB: Settlement boundaries
Representation ID: 60512
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
Land north of Cambridge Road (A1307), Linton (HELAA site 51721)
In line with their promotion of Land north of Cambridge Road, Linton, Taylor Wimpey advocate that the site should be included within the settlement boundary of Linton as part of the allocation of the site for residential development.
In line with their promotion of Land north of Cambridge Road, Linton, Taylor Wimpey advocate that the site should be included within the settlement boundary of Linton as part of the allocation of the site for residential development.
Comment
Greater Cambridge Local Plan Preferred Options
S/RSC: Village allocations in the rural southern cluster
Representation ID: 60513
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
Land north of Cambridge Road, Linton (HELAA site 51721)
This policy is considered to illustrate further that despite this Rural Southern Cluster Area having been identified by the Council as a growth area, there is in fact limited residential development proposed within this area to support the level of employment growth. Delivering more housing within this area will provide development with opportunities for sustainable travel to the Genome Campus and Babraham Research Campus.
Whilst we do not comment on the appropriateness of the proposed, it is notable that Duxford is a lower order settlement in the hierarchy than Linton however it receives an allocation whereas Linton does not.
The evidence base is clear that the Rural Southern Cluster is an appropriate location for focusing development as part of the Council strategy. It however appears that more limited growth has been directed to this area due to anticipated high carbon emissions due to dispersed village homes. It is considered that this conclusion is not representative of Linton.
It is therefore considered that the Council should look to deliver more homes in this important employment area.
This policy is considered to only illustrate further that despite this Rural Southern Cluster Area having been identified by the Council as a growth area, there is in fact limited residential development proposed within this area to support the level of employment growth. Delivering more housing within this area will provide development with opportunities for sustainable travel to the Genome Campus and Babraham Research Campus.
Residential allocations within the Rural Southern Cluster include a carried forward allocation in Sawston, along with new allocations S/RSC/HW in Great Shelford which will deliver no more than 100 homes and S/RSC/MF at Duxford which will deliver around 60 homes. For an area that is identified for growth to support significant employment development, 160 homes is a very small contribution. Linton is equidistant to the Babraham Research Campus compared to Great Shelford and Duxford, and Linton is closer to the Genome Campus than Great Shelford.
Whilst we do not comment on the appropriateness of the proposed allocations themselves at this juncture, it is notable that Duxford is a lower order settlement in the hierarchy than Linton however it receives an allocation whereas Linton does not.
The evidence base is clear that the Rural Southern Cluster is an appropriate location for focusing development as part of the Council strategy. The Greater Cambridge Local Plan: First Proposals Sustainability Appraisal (October 2021) states that development in this area ‘will help to ensure housing is well-located in relation to existing centres of employment’.
The Greater Cambridge Local Plan Development Strategy Options – Summary Report (November 2020) sets out work undertaken to assess further whether the spatial choices set out in the Greater Cambridge Local Plan: First Conversation consultation were indeed reasonable; and to identify whether there are any additional reasonable spatial options that should be added to the First Conversation choices. The assessment identified the following two options as being reasonable and substantively different to the six First Conversation options:
• Supporting a high-tech corridor by integrating homes and jobs (southern cluster); and
• Expanding a growth area around transport nodes (western cluster).
Consequently, eight choices were taken forward for testing as strategic options, which included:
‘Spatial Option 7: Supporting a high-tech corridor by integrating homes and jobs (southern cluster) - this approach would focus new homes close to existing and committed jobs within the life sciences cluster area around the south of Cambridge, including homes at existing villages and at new settlements.’
The assessment noted that opportunities for this area included a good relationship between jobs and homes. It however appears that more limited growth has been directed to this area due to anticipated high carbon emissions due to dispersed village homes. However, this is considered to be a rather general statement and does not focus in on specific settlements within the cluster that benefit from better sustainable travel opportunities.
As set out earlier, Linton offers highly sustainable travel opportunities for residents and these are being further enhanced through ongoing improvements. Residents within Linton are able to access Babraham Research Campus by regular bus service with a journey time of around 15 minutes. Whilst the Genome Campus is not directly accessible by bus, this is only a 10 minute drive. It is therefore considered that the conclusion that development in the southern cluster would result in high carbon emissions is not representative of Linton.
Furthermore, Taylor Wimpey launched their Environment Strategy in 2021. This sets out how they will help protect our environment for future generations, partner with suppliers to reduce the impact of the homes and developments built, and make it easier for their customers to live a sustainable lifestyle. The strategy focuses on the key environmental impacts for the business: climate change, nature, resources and waste. As such the development of Land north of Cambridge Road, Linton could be delivered sustainably, with reduced carbon impact.
It is therefore considered that the Council should look to deliver more homes in this important employment area, with the Land north of Cambridge Road, Linton providing a suitable site in a sustainable location for accessing jobs.
Comment
Greater Cambridge Local Plan Preferred Options
BG/BG: Biodiversity and geodiversity
Representation ID: 60514
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain. It is understood that this aspiration has stemmed from the Oxford-Cambridge Arc Environmental Principles and exceeds that in the Environment Act 2021. Whilst Taylor Wimpey are supportive of this approach to provide significant biodiversity improvements through development, this is clearly a high aspiration and it will be important to consider site specific requirements and the overall viability implications of all the Plan requirements considered collectively.
A suggestion to the wording is that this could be phrased as ‘the policy will require development to aim to achieve a 20% biodiversity net gain with a minimum 10% to be achieved’. By amending the wording in this way the onus is clearly on the applicant to meet the 20% wherever possible, but should there be a slight shortcoming (that would still result in an overall high net gain) this would not prevent otherwise acceptable development.
The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain. It is understood that this aspiration has stemmed from the Oxford-Cambridge Arc Environmental Principles and exceeds that in the Environment Act 2021. Whilst Taylor Wimpey are supportive of this approach to provide significant biodiversity improvements through development, this is clearly a high aspiration and it will be important to consider site specific requirements and the overall viability implications of all the Plan requirements considered collectively.
A suggestion to the wording is that this could be phrased as ‘the policy will require development to aim to achieve a 20% biodiversity net gain with a minimum 10% to be achieved’. By amending the wording in this way the onus is clearly on the applicant to meet the 20% wherever possible, but should there be a slight shortcoming (that would still result in an overall high net gain) this would not prevent otherwise acceptable development.
Comment
Greater Cambridge Local Plan Preferred Options
BG/GI: Green infrastructure
Representation ID: 60515
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
This policy wording sets out that ‘all development proposals – appropriate to its type, scale and location - to include green infrastructure, providing the following varied benefits for people, wildlife and planet’. It is suggested that further clarification should be provided within the wording of this policy as to what type, scale and location of development will be required to provide green infrastructure. This will avoid any ambiguity.
This policy wording sets out that ‘all development proposals – appropriate to its type, scale and location - to include green infrastructure, providing the following varied benefits for people, wildlife and planet’. It is suggested that further clarification should be provided within the wording of this policy as to what type, scale and location of development will be required to provide green infrastructure. This will avoid any ambiguity.
Comment
Greater Cambridge Local Plan Preferred Options
BG/TC: Improving Tree Canopy Cover and the Tree Population
Representation ID: 60516
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
The wording of this policy appears to contradict itself. It appears to suggest that all existing trees on sites should be protected and makes no allowance for instances where trees are required to be removed due to disease, age or safety concerns which renders their retention inappropriate. Furthermore, in some instances the removal of trees is required in order for the development to be brought forward. These could be trees of value. This would not make a development unacceptable, particularly where appropriate mitigation could be provided. It is therefore considered that the two bullet points could be merged into a single point that references ‘trees of value’ and for them to be protected ‘where possible’.
The same comment is raised in relation to the bullet point stating the need to ‘protect existing hedgerows and the surrounding land that supports them, and to require the planting of new ones where appropriate’.
Concerns are also raised to the reference of using ‘a recognised tool such as iTree’ to measure tree value. This would appear to make the role of many arboriculturalists redundant if they do not use such a tool. It is therefore suggested that this text be removed from the wording of the policy.
The wording of this policy appears to contradict itself currently. It states on one bullet point that development proposals need to ‘protect and enhance the tree population on site, including its diversity and distribution’ but then adds on the subsequent bullet point the need to ‘protect existing trees of value (including landscape, heritage, cultural, amenity, biodiversity, ecosystem service or aesthetic value) as measured by a recognised tool such as iTree’.
The first point appears to suggest that all existing trees on sites should be protected and makes no allowance for instances where trees are required to be removed due to disease, age or safety concerns which renders their retention inappropriate. Furthermore, in some instances the removal of trees, in whole or in part, is required in order for the development to be brought forward. These could be trees of value. For example, this could be to allow for access to a development. This would not make a development unacceptable, particularly where appropriate mitigation could be provided. It is therefore considered that the two bullet points could be merged into a single point that references ‘trees of value’ and for them to be protected ‘where possible’.
The same comment is raised in relation to the bullet point stating the need to ‘protect existing hedgerows and the surrounding land that supports them, and to require the planting of new ones where appropriate’. Again, it is suggested that ‘hedgerows of value’ is stated in this point.
Concerns are also raised to the reference of using ‘a recognised tool such as iTree’ to measure tree value. This would appear to make the role of many arboriculturalists redundant if they do not use such a tool, and it is also unclear from this policy wording what other such recognised tools may be. It is therefore suggested that this text be removed from the wording of the policy, which would otherwise appear to take a very restrictive and unnecessary approach to arboricultural assessments.
Comment
Greater Cambridge Local Plan Preferred Options
BG/RC: River Corridors
Representation ID: 60517
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
This policy relates to the impact of development on the River Cam and its tributaries. River Granta is such a tributary, which runs along the northern edge of the Land north of Cambridge Road, Linton. Taylor Wimpey are therefore supportive of the approach to protect, enhance and restore this natural feature, which the development of the site could help to achieve.
This policy relates to the impact of development on the River Cam and its tributaries. River Granta is such a tributary, which runs along the northern edge of the Land north of Cambridge Road, Linton. Taylor Wimpey are therefore supportive of the approach to protect, enhance and restore this natural feature, which the development of the site could help to achieve.
Comment
Greater Cambridge Local Plan Preferred Options
BG/EO: Providing and enhancing open spaces
Representation ID: 60520
Received: 13/12/2021
Respondent: Taylor Wimpey UK Ltd
Agent: Turley
Taylor Wimpey are supportive of the delivery of open space and recreational land through development. The proposed policy wording states however that ‘open space and recreation provision will be required to be provided by new development, appropriate to the scale and location of the development.’ It is suggested that further clarification should be provided within the wording of this policy as to what scale and location of development will be required to provide open space, and indeed what type and amount of open space contribution will need to be on and off site. This will avoid any ambiguity. The wording adds that ‘the type of provision sought will be guided by the needs and opportunities of the local area.’ Again this requires further clarification. It will be important for these requirements to inform site capacities for the proposed allocations and assessments of viability of the Plan as a whole.
It is understood that the Council are looking to review their current open space standards, which is supported as this will provide important clarification for development sites. It is also agreed that the standards should continue to differ between Cambridge and South Cambridgeshire to reflect the differences between these areas.
It is also suggested that the wording should be amended to state that ‘open space and recreation provision will be required to be provided by new development where justified’.
Taylor Wimpey are supportive of the delivery of open space and recreational land through development, with Land north of Cambridge Road, Linton having the ability to deliver a very significant amount of such space for both new and existing residents to enjoy.
The proposed policy wording states however that ‘open space and recreation provision will be required to be provided by new development, appropriate to the scale and location of the development.’ It is suggested that further clarification should be provided within the wording of this policy as to what scale and location of development will be required to provide open space, and indeed what type and amount of open space contribution will need to be on and off site. This will avoid any ambiguity. The wording adds that ‘the type of provision sought will be guided by the needs and opportunities of the local area.’ Again this requires further clarification. It will be important for these requirements to inform site capacities for the proposed allocations and assessments of viability of the Plan as a whole.
It is understood that the Council are looking to review their current open space standards, which is supported as this will provide important clarification for development sites. It is also agreed that the standards should continue to differ between Cambridge and South Cambridgeshire to reflect the differences between these areas.
It is also suggested that the wording should be amended to state that ‘open space and recreation provision will be required to be provided by new development where justified’. This is so as to reflect the requirements of national policy, which requires that planning obligations meet the following tests; that they are necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind to the development, as set out in the policy tests in paragraph 57 of the NPPF.