Greater Cambridge Local Plan Preferred Options

In general, the Plan’s vision of Greater Cambridge being “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” is supported. This is considered to be in accordance with the purpose of the planning system (as defined by the NPPF, which is to contribute to the achievement of sustainable development. Which, at a high level, can be summarised as “meeting the needs for the present without compromising the ability of future generations to meet their own needs” (paragraph 7 of the NPPF).
Paragraph 8 of the NPPF emphasises that achieving sustainable development means that the planning system has three overarching objectives (economic, social and environmental), which are interdependent and should be pursued in mutually supportive ways.
The Greater Cambridge Plan’s aim to plan for enough housing to meet the area’s housing needs, (including affordable housing to rent and buy), and to plan for different homes to suit the needs of different communities; is considered to comply with both the social objective and economic objective. From a social perspective, paragraph 8b of the NPPF makes it clear that to support strong, vibrant and healthy communities it is important to ensure that a sufficient number and range of homes can be provided. NPPF paragraph 8a states that in order to build a strong, responsive and competitive economy, sufficient land of the right type is available in the right places and at the right time to support economic growth. Whilst this paragraph does relate to the supply of employment land, we believe that it is also crucial that the planned supply of housing for Greater Cambridge is sufficient to support the area’s considerable economic growth.
The aim of helping Greater Cambridge transition to net zero carbon by 2050 by ensuring development is sited in places that help to limit carbon emissions, and ensuring development is designed to the highest achievable standards for energy and water use is also supported and is considered to be in accordance with the environmental objective of sustainable development (as defined by NPPF paragraph 8c).

The Plan recognises that due to Greater Cambridge’s strong economy, over recent years, new jobs have been created faster than new homes have been built. This has led to higher house prices and increased commuting into the area.
We therefore consider that the Plan should be aiming to deliver enough homes to meet and boost the area’s housing delivery in order to help reduce these trends of high house prices and high levels of commuting as soon as possible.
In particular, we note that the Development Strategy Topic Paper outlines that both the Employment Land and Economic Development Evidence Study and the Greater Cambridge Housing and Employment Relationships Report show that should the Authority plan for the minimum housing figure set by the government’s standard method alone, this would not support the levels of employment provision expected to arise within Greater Cambridge between 2020 and 2041.
The Plan therefore proposes to deliver what is referred to as the “medium level of homes” which have been calculated in response to the “central employment scenario” or “medium level of jobs” as defined within the Council’s Employment Land Review. The medium level of jobs is considered to be the most likely outcome as it takes into account long term historic patters of employment including the fast growth of key sectors in the Greater Cambridge economy. It is therefore considered to be a broadly logical basis for setting a housing figure for Greater Cambridge. It is noted that this results in a need for 44,400 homes overall (an annual need of 2,111 dwellings), which is taken forward in Policy S/JH: New jobs and homes.
We do welcome the approach of setting a higher housing figure based on the area’s strong economic growth. However, we also believe the Plan should seek to accommodate further housing growth, should either the planned supply not come forward as anticipated or if other economic drivers (which are not currently known), such as growth of existing industries within the area occurring faster than currently anticipated during the plan period. This will ensure the Plan is responsive to changing circumstances during the Plan period.

We note that the wording for this policy is still be drafted in full. However, the proposal to encourage the delivery of 44,400 new homes over the plan period (2,111 homes per year), is broadly supported.
The plan outlines that it is necessary for the Local Plan to accommodate a sufficient number of new homes to ensure that the recent trends of higher house prices and in-commuting due to a lack of homes in the area, can be reversed.
However, we believe that when the policy is drafted, the number of new homes should be expressed as a minimum and that the policy should have flexibility to allow further homes to come forward in certain circumstances. Such as the planned supply of homes not coming forward during the currently anticipated timescales, or if growth in the number of jobs leads again to the current problems of higher house prices and higher in-commuting.

The proposed development strategy, in line with the Plan’s vision and aims, is to direct development to where it will have the least climate impact.
Alongside this, there is an aim to ensure that development is directed to areas where active and public transport is a “natural choice” and where new green infrastructure can be delivered alongside new development and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way. This proposed policy direction is supported and we consider that the sites we have previously submitted to the Council (land east of Cambridge Road, Sawston Ref: 531, and land east of Haverhill Road, Stapleford Ref: 530) are both capable of accommodating housing developments which would accord with the aims of Policy S/DS.
In terms of the rural area south of Cambridge, which Stapleford (with Shelford) and Sawston are a part, it is proposed that “some” development will occur within the area, where homes and jobs can be located close to each other and served by good quality public transport, cycling and walking links.
The proposed policy direction proposes that there will be “new smaller sites for housing and employment in villages that have very good public transport access and are close to jobs, some of which are through the release of land from the Green Belt”. In addition to this, allocations will be continued for existing sites allocated in previous plans.
We support the allocation of sites in villages with very good public transport access. This is particularly the case for Sawston and Stapleford. However, we consider the policy should also reflect on the merits of planned public transport provision also, as this further strengthens the sustainability of villages.
In the case of Stapleford and Sawston, both villages are proposed to be linked by Phase 2 of the Cambridge South East Transport project (which will run from Cambridge Biomedical Campus to a new travel hub near the A11, close to both Babraham Research Campus and Granta Park). This route will connect the villages with three existing strategic employment areas which are highly likely to continue growing and providing jobs throughout the plan period. We therefore believe the connections the Transport Project will provide to these villages, further emphasises why they should be considered appropriate locations of housing growth.

Development on land east of Cambridge Road, Sawston (Ref: 531) would achieve new development in close to jobs, either accessible via the new transport route, or within the village (the site adjoins an existing commercial unit and is within a 20-minute walk of the South Cambridge Business Park).
The release of Green Belt land in Sawston is supported. Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. We consider that the need to deliver new homes in sustainable locations, close to public transport routes and employment opportunities comprises an appropriate justification for Green Belt release.

We have no objection to the proposal to group similar settlements into categories that reflect their scale, characteristics and sustainability. This is a common approach adopted by Local Plans and reflects how settlements have different roles and levels of potential to accommodate growth.
The proposed levels of the settlement hierarchy comprise:
• Cambridge City
• Towns
• Rural Centres
• Minor Rural Centres
• Group Villages
• Infill Villages
Both Sawston and Great Shelford with Stapleford are proposed to be identified as Rural Centres.
Appendix 1H: Settlement Hierarchy Review of the Development Strategic Topic Paper, considered whether the existing hierarchy of settlements (within existing plans) continues to be relevant.
Regarding Rural Centres, the Review states that “Rural centres have been recognised as the largest and most sustainable villages in the district. They have good access to a secondary school (either within the village or accessible by good public transport), employment opportunities, and a variety of services and facilities, and have good public transport links to Cambridge or a market town. They stand out as having the larger populations than other villages. Rural Centres with their range of services play a role in serving the surrounding smaller villages and to meet their daily needs. It remains appropriate to recognise this small number of larger villages as a higher order than other settlements”.

We support the Councils recognition that villages such as Stapleford (with Great Shelford) and Sawston are two of the most sustainable villages in the area owing to their good access to employment opportunities, a variety of services and facilities and good transport links.

Regarding Great Shelford with Stapleford, we welcome that the Review identifies that the two villages act as one settlement. We also note that the regular Citi 7 route link to Cambridge has been recognised. However, it states that there will be “a stop” on Phase 2 of the South East Cambridge Transport Route within the village, for accuracy we consider this needs to be updated to reflect the planned route, which will have two stops at either end of the village. Nevertheless, we do support the classification of Stapleford and Great Shelford as a Rural Centre.
In terms of Sawston, we also appreciate that the Review notes its public transport connectivity due to the Citi 7 route and the South East Cambridge Transport Route. It is also welcomed that the employment locations within the village are noted and the settlement’s role as a ‘hub’ for surrounding rural group and infill villages is recognised.
In light of the above, we believe Great Shelford with Stapleford and Sawston’s roles as Rural Centres is entirely justified.

The drawing of settlement boundaries around settlements in order to identify areas that are considered to be part of the settlement for planning purposes is again a common approach adopted by most local plans.
We believe that any proposed development allocation sites should be included within the settlement boundaries and therefore we agree with the proposed policy direction to define the boundaries based on “the present extent of the built-up area as well as planned new development”.
As will be expanded on in our response to policy to S/RSC: Village allocations in the rural southern cluster, we believe the amended site areas we have put forward for the land east of Cambridge Road, Sawston SHLAA Ref: 531, and the land east of Haverhill Road, Stapleford SHLAA Ref: 530 are both capable of accommodating housing developments and therefore should be included within the settlement boundaries of their respective settlements.

This emerging policy will confirm that the three new settlements of Northstowe, the new town north of Waterbeach, and Bourn Airfield new village, will continue to be developed during the period of the new Local Plan and beyond.
We note that the consultation document states that there is evidence which means “it is reasonable to assume that annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on, meaning that more of the planned homes will be completed in the plan period, with less to follow after 2041”.
The evidence base supporting this approach is stated to lie within the Development Strategy Topic Paper. On reviewing the relevant section relating to emerging Policy S/NS: Existing new settlements, it is stated that the Authority “have not completed evidence focused on this topic”. Therefore, we are very concerned that there is no clear justification for the assumption that these new settlements will deliver more homes within the plan period.
In the ‘delivery of development’ section relating to the new settlement policy, it is states that the new settlement sites are:
• “anticipated to start delivering additional dwellings a year from 2026/2027 after adoption of the new Local Plan and current five year supply period (2021- 2026), with build out rates based on Housing Delivery Study assumptions for new settlements of maximum of 300 dwellings a year, therefore additional 50 dwellings a year to the 250 dwellings a year already including in the Greater Cambridge Housing Trajectory (April 2021)
• additional 750 dwellings anticipated in 2020-2041 for each of Northstowe and Waterbeach New Town”.
The above does not provide any reasoning for the basis behind these assumptions. For example, it is not clear if these delivery rates have been suggested by the new settlement’s promoters or if they have been assumed by the local planning authority.
Moreover, it is noted that even with the ‘higher delivery rates’ the new settlements will not be contributing to the area’s housing land supply within the first five years of the plan period.
Published evidence from Nathaniel Lichfield & Partners (Start to Finish, November 2016) outlines that the determination period of an application of 500+ dwellings (i.e. a new settlement) is circa 5.3 to 6.9 years. For the most part, this time period is due to complex planning issues. When an application is determined quicker than average, this is a result of matters being substantially addressed prior to submission which, when combined with the determination period, still adds up to the same amount of time; as the report states “there is rarely a way to short-circuit planning”. For new standing settlements, this is likely to be significantly longer given the greater difficulty in identifying and planning, then servicing and accessing such sites. This means the best way to plan for strategic sites is to do so well in advance. Whilst we do agree that the Greater Cambridge Plan should be planning for new settlements, what this evidence does demonstrate, is that in the short term, there is often a need for an Authority to place a greater reliance on small and medium sized sites, which can deliver homes in fewer than five years.
Delivering more new homes as soon as possible is especially pertinent in the Greater Cambridge area especially given the current issues with higher house prices and trends of in-commuting due to the number of jobs outstripping local housing supply.
The land east of Cambridge Road, Sawston SHLAA Ref: 531, and land east of Haverhill Road, Stapleford SHLAA Ref: 530 are both examples of sites that are capable of accommodating housing developments within the first five years of the plan. Therefore, in the absence of the clear evidence to justify why the new settlement sites should be attributed higher numbers of homes throughout the plan period, we believe the Local Plan should be allocating more homes to come forward within the initial five year period.

We support the Council’s aim to support growth within the southern rural cluster (in which Great Shelford with Stapleford and Sawston are located).
As the emerging plan recognises, the cluster is “home to a range of major business parks with world-leading facilities and has some excellent and improving public transport links”.
We also support the release of Green Belt within the cluster and consider the delivery of new housing growth next to established sustainable villages. This will mean that new residents are close to sources of employment as well as the facilities and services they will need.

The emerging Plan currently only identifies one proposed housing allocation at Sawston. The site, known as S/RSC/H/1 (c): land south of Babraham Road, Sawston, is an existing development allocation and is proposed to remain within the Plan. It is noted that the other former housing allocations within the village have gained planning permission and therefore the existing policies would no longer be required. In terms of site south of Babraham Road, this is described as being “at the start of the planning application process, and therefore a policy framework needs to be retained for this site. However, this will be kept under review as the plan progresses”.

In this regard, it is noted that a full planning application for 280 dwellings on the site south of Babraham Road is pending consideration (see App Ref: 21/03955/FUL). The determination deadline is 30th November 2021.
Consequently, it is reasonable to assume that the Babraham Road allocation will gain planning permission very soon and therefore it will no longer be appropriate to allocate it within the Plan.

As is evidenced by the status of the existing allocations in Sawston, it is clear that there is strong local demand for housing in the locality and therefore these allocations have come forward for development in a relatively short period of time.

As such, we believe the Council must consider allocating further sites within Sawston, to ensure that there is a supply of sites to help meet housing needs arising at the start of the emerging Greater Cambridge plan period.

*Land east of Cambridge Road, Sawston SHLAA Ref: 531*

We previously promoted a site known as land east of Cambridge Road, Sawston, SHLAA reference 531.
As part of the current representations, we wish to amend the site boundary, to reflect a parcel that is closer to the settlement (please see attached Site Location Plan).

It is considered that the site comprises a logical location for the future expansion of the village, and as evidenced by the existing commercial unit on the site, there is potential for it to deliver a mix of uses, if this was deemed acceptable by the Council. Alternatively, the site could come forward for residential development, with an appropriate buffer between the existing commercial unit and the new dwellings provided.

*Green Belt Assessment*
At present, the land east of Cambridge Road is designated as Green Belt land.
The Greater Cambridge Green Belt Assessment (2021) assessed the site as part of a larger parcel known as SA22.

The Green Belt Assessment has assessed the parcel against three ‘Cambridge Green Belt’ purposes. Which are:
• 1 - to preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
• 2 - to maintain and enhance the quality of Cambridge’s setting
• 3 - to prevent communities in the environs of Cambridge from merging into one another and with the city
Whilst the Assessment attempts to explain how these are linked to the five purposes of Green Belt as defined within the NPPF, we do not believe the assessment is robust as it does not clearly assess the sites against the five purposes.

As detailed by paragraph 138, the five purposes of the Green Belt are:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
We therefore request that the Authority update their Assessment to also assess the parcels against the NPPF Green Belt purposes.

Overall, Green Belt Parcel SA22 was assessed as having a ‘high’ harm rating by the Green Belt Assessment.
As we explained above, we do not believe the assessment is robust as it does not clearly assess the sites against the five purposes of the Green Belt as defined by paragraph 138 the NPPF.

In addition to this, we also believe the Assessment should be updated to assess the smaller parcels of land that have been proposed for housing.

In terms of the land east of Cambridge Road, we request that the Council assess the smaller parcel, put forward by these representations on its own, independent from the other land within parcel SA22.

To assist the Council with their assessment of this smaller parcel, we have completed our own assessment of the site against the NPPF’s five Green Belt purposes:
a) to check the unrestricted sprawl of large built-up areas;
A residential development on the land east of Cambridge Road will be contained by existing defensible boundaries, including woodland and trees to the north and east of the site and Cambridge Road to the south. It is proposed that a new green buffer comprising open space and landscape planting would contain the site to the west. Due to the defensible boundaries to the site, any development will not result in an area of ‘unrestricted’ sprawl to Sawston.

b) to prevent neighbouring towns merging into one another;
The proposed development parcel will result in a reduction in the gap between Sawston and Stapleford. However, the gap between the settlements would still extend to approx. 1.1km and therefore, with the establishment of a new green buffer on the western boundary of the site, the development will ensure that the two villages remain separate.

c) to assist in safeguarding the countryside from encroachment;
As noted above, the proposed development will be contained by existing and proposed defensible boundaries. As a result, it will not result in a significant encroachment into the countryside.

d) to preserve the setting and special character of historic towns; and
The site performs no function in preserving the setting and character of a historic town and or designated heritage asset.

e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
As is evidenced by the need to allocate land for housing on the edge of the settlement, there is no suitable derelict of urban land within the settlement which could be developed in preference to this site.