Greater Cambridge Local Plan Preferred Options
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Greater Cambridge Local Plan Preferred Options
STRATEGY
Representation ID: 57189
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
The delivery of environmental objectives should not be to the detriment of other elements of sustainable development. In respect of new homes and development of existing communities, it is vital that the new Plan includes sufficient land and sites to meet Greater Cambridge’s needs including housing that is affordable to rent and buy. This will require sites to be identified in the rural areas as well as Cambridge City and ensure that the plan positively addresses the needs of every community in Greater Cambridge.
It is considered that for the emerging Local Plan to provide an ambitious and positive approach to climate change and environmental issues, it is necessary to recognise that economic and social factors are required to inform development solutions. The delivery of environmental objectives should not be to the detriment of other elements of sustainable development. In respect of new homes and development of existing communities, it is vital that the new Plan includes sufficient land and sites to meet Greater Cambridge’s needs including housing that is affordable to rent and buy. This will require sites to be identified in the rural areas as well as Cambridge City and ensure that the plan positively addresses the needs of every community in Greater Cambridge.
Comment
Greater Cambridge Local Plan Preferred Options
How much development and where?
Representation ID: 57191
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
Greater Cambridge is experiencing unprecedented levels of economic growth, relating to an increase in jobs of over 32% across the plan period. This approach acknowledges the level of economic growth required and that the previous Local Plan Strategy severely underestimated the level of economic growth attainable. It must also be acknowledged that over recent years jobs have been created faster than new homes have been built. This has led to reliance on employee in-commuting from surrounding areas to fulfil the employment requirements, conflicting with the Council’s aspirations for sustainable communities and the aim to adopt an environmentally sensitive approach.
Greater Cambridge is experiencing unprecedented levels of economic growth, relating to an increase in jobs of over 32% across the plan period. This approach acknowledges the level of economic growth required and that the previous Local Plan Strategy severely underestimated the level of economic growth attainable. The recognition of this economic growth potential is supported, but it must also be acknowledged that over recent years jobs have been created faster than new homes have been built. This has led to reliance on employee in-commuting from surrounding areas to fulfil the employment requirements, conflicting with the Council’s aspirations for sustainable communities and the aim to adopt an environmentally sensitive approach. In reality this means that it is essential for the Plan to recognise these pressures and respond intuitively with regard to providing more supply into the local housing market area, at appropriate locations that meet the needs of the new employees and in-migration residents. The most effective way for the Council’s development strategy to respond to these influences is through a substantial increase in housing provision, which is recommended to be at least 15% above that currently proposed. Such a level of increase would be able to reflect the level of economic growth that has been experienced across Greater Cambridgeshire and will reflect the aspirations for further investment in job creation and industry that is envisaged through the emerging strategy. The correlation between economic growth and housing provision must be recognised for the strategy to be effective, positively prepared and aspirational.
The strategy of directing development to areas that have the least climate impact is recognised as a sustainable approach, however this approach ignores the requirements or rural communities and related economic production.
Nonetheless concern is raised in respect of the approach to dealing with villages in the emerging Local Plan where only low levels of new homes are proposed. This would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened.
Comment
Greater Cambridge Local Plan Preferred Options
S/JH: New jobs and homes
Representation ID: 57192
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
Policy S/JH should adequately address the housing and employment requirements for the plan area. Greater Cambridge should reconsider planning for a higher quantum of housing
Policy S/JH should adequately address the housing and employment requirements for the plan area. Greater Cambridge should reconsider planning for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) has recognised that the Combined Authority of Cambridgeshire and Peterborough has experienced a higher rate of economic growth than forecast. This is a significant factor that Greater Cambridge must consider and should therefore ensure that a significantly higher number of homes are planned for. If the economic trend is to continue within the Plan area as established in the CPIER report, it would be a failure of the plan’s statutory requirement to make sufficient provision of housing to address the increases in economic growth that is forecast.
Comment
Greater Cambridge Local Plan Preferred Options
S/DS: Development strategy
Representation ID: 57195
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
Summary: Land at Dry Drayton Road, Oakington (HELAA site 51617) & Land at Fen End, Willingham (HELAA site 40469)
Concern is raised that insufficient land is being allocated to the rural area overall and too much emphasis is being placed on Cambridge City and new settlements and this focus could lead to problems associated with infrastructure and housing delivery. Whilst it is recognised that the use of brownfield land is encouraged and this accords with the provisions of the Framework, this should not be at the expense of ensuring that the right sites are allocated in the right places
Given that the Greater Cambridge area includes vastly different spatial characteristics ranging from dense urban landscapes to rural village locations, Policy S/JH should ensure that housing is provided across the settlement hierarchies; so in larger settlements as well as smaller rural communities to ensure that the policy meets the objectives of supporting and promoting the provision of balanced and mixed communities. The current strategic approach to accommodating development is not considered to be in accordance with the principles outline in the National Planning policy Framework.
Concern is raised that insufficient land is being allocated to the rural area overall and too much emphasis is being placed on Cambridge City and new settlements and this focus could lead to problems associated with infrastructure and housing delivery.
Whilst it is recognised that the use of brownfield land is encouraged and this accords with the provisions of the Framework, this should not be at the expense of ensuring that the right sites are allocated in the right places. Not all brownfield land will be appropriate to allocate for development, as sites can be blighted by contamination, have complex ownership issues that affect delivery or be too small or inadequately accessed. There will be a need for greenfield development as well as consideration of Green Belt release to ensure that the demanding housing requirements for the LPA are met. Greenfield sites also offer the opportunity for good levels of affordable housing to be provided that often causes a viability issue in the development of brownfield sites. Furthermore, it is considered that a higher quantum of homes are allocated within the plan period. The current scale of growth is considered inadequate particularly within the rural area, the development strategy proposed is not effective and could threaten the long-term viability of villages.
The following sites have been promoted in earlier iterations of the plan and through the Call For Sites process and should be allocated for development:
Land at Dry Drayton Road, Oakington (ref 51617)
Land at Fen End Willingham (ref 40469)
Comment
Greater Cambridge Local Plan Preferred Options
S/SH: Settlement hierarchy
Representation ID: 57197
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
Objection is raised to the proposed changes to the settlement hierarchy in Policy S/SH. It is considered inappropriate and ineffective to identify just the ‘new town’ element of Waterbeach within this category in the settlement hierarchy the plan should make clear that the existing settlement will also be defined as a ‘Town.'
Objection is also raised to the re-categorisation of Cottenham from a ‘Rural Centre’ to a ‘Minor Rural Centre’. Both the existing settlement of Waterbeach and the village of Cottenham are capable of providing larger schemes of more than 30 dwellings given the sustainability credentials afforded to them.
Objection is raised to the proposed changes to the settlement hierarchy as set out in the emerging Policy S/SH. Whilst Waterbeach new town is proposed to be included within the ‘Towns’ category the Plan does not make it clear whether the existing settlement of Waterbeach will also be included within this category. It is considered inappropriate and ineffective to identify just the ‘new town’ element of Waterbeach within this category in the settlement hierarchy the plan should make clear that the existing settlement will also be defined as a ‘Town’. Within the adopted South Cambridgeshire Local Plan 2018 Waterbeach is identified as a ‘Minor Rural Centre’ this is now considered an inappropriate category for a settlement that has experienced such large growth to the north. This is particularly pertinent given the sustainable pedestrian and green links from the settlement to the new town and the linked trips associated with the facilities and services between the two areas.
Objection is also raised to the re-categorisation of Cottenham from a ‘Rural Centre’ to a ‘Minor Rural Centre’. The justification within the First proposals Local Plan states that this reflects the revision to the criteria for Rural Centres to have high quality public transport in the form of a segregated public transport route such as the Greater Cambridge Partnership schemes or the Cambridgeshire Guided Busway. It is considered that this should not be the only consideration in respect of categorising settlements within the hierarchy indeed other considerations including the size and levels of services and facilities afforded to a settlement should be a major and primary factor. Given the size of Cottenham, its population, the fact it has a good level of services and facilities afforded to it including a Primary School, GP surgery, pharmacy, library, Post Office, dentist, ATM/bank, community facility, public house and good level of shops and services the proposed re-categorisation to a ‘Minor Rural Centre’ is not appropriate. It is instead considered that more funding should be provided to the bus service in Cottenham and the increase in home-working and less reliance on travel for work should be a consideration in categorising settlements within the Settlement Hierarchy.
The First Proposals Local Plan identifies that within Rural Centres there is no limit on an individual scheme size but within Minor Rural centres there will be an indicative maximum scheme size of 30 dwellings. Both the existing settlement of Waterbeach and the village of Cottenham are capable of providing larger schemes of more than 30 dwellings given the sustainability credentials afforded to them.
Comment
Greater Cambridge Local Plan Preferred Options
S/SB: Settlement boundaries
Representation ID: 57198
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
t will be important to ensure that the Settlement Boundaries are not drawn too tightly around the built-up areas of settlements, as this could result in an inflexible approach to delivering housing sites. The Local Plan should provide a more flexible approach to housing delivery to ensure that a mix of development scales are provided for. This will help to sustain the delivery of homes if some of the larger sites allocated in the plan do not meet the housing delivery expectations then additional sites should be allowed to come forward for development.
It will be important to ensure that the Settlement Boundaries are not drawn too tightly around the built-up areas of settlements, as this could result in an inflexible approach to delivering housing sites. The Local Plan should provide a more flexible approach to housing delivery to ensure that a mix of development scales are provided for. This will help to sustain the delivery of homes if some of the larger sites allocated in the plan do not meet the housing delivery expectations then additional sites should be allowed to come forward for development. In order to ensure maximum flexibility is provided it will be necessary to ensure that a pragmatic approach is adopted in the drafting of settlement boundaries.
Comment
Greater Cambridge Local Plan Preferred Options
The city of Cambridge
Representation ID: 57201
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
Whilst it is recognised that locating development within the Cambridge urban area is a sustainable development option, it is considered that too much emphasis is placed on this as a location within the emerging Local Plan. This focus of providing larger sites in this location could lead to problems associated with infrastructure provision and housing delivery. There needs to be a better balance with more housing being apportioned to the rural area.
Whilst it is recognised that locating development within the Cambridge urban area is a sustainable development option, it is considered that too much emphasis is placed on this as a location within the emerging Local Plan. This focus of providing larger sites in this location could lead to problems associated with infrastructure provision and housing delivery. There needs to be a better balance with more housing being apportioned to the rural area. Without a redistribution of housing this would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened. In addition to this there is more of a focus on home working since the COVID19 pandemic and less reliance on needing to be close to larger cities; so there is not as much requirement or desire for housing to be located in city based urban locations.
Comment
Greater Cambridge Local Plan Preferred Options
S/NEC: North east Cambridge
Representation ID: 57204
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
Greater Cambridge is reliant on 8,350 new homes being provided at North-East Cambridge under Policy S/NEC. This is a significant level of housing to be provided on a brownfield site, part of which is contaminated and comprises a sewage works. There are likely to be significant costs associated with remediating the site and potential time delays on bringing development forward on the site. It is considered that the Council should look at providing more of a range of smaller and medium sites that have the ability to come forward at a faster rate than strategic sites of this size.
Greater Cambridge is reliant on 8,350 new homes being provided at North-East Cambridge under Policy S/NEC. This is a significant level of housing to be provided on a brownfield site, part of which is contaminated and comprises a sewage works. There are likely to be significant costs associated with remediating the site and potential time delays on bringing development forward on the site. It is considered that the Council should look at providing more of a range of smaller and medium sites that have the ability to come forward at a faster rate than strategic sites of this size.
Comment
Greater Cambridge Local Plan Preferred Options
S/LAC: Land allocations in Cambridge
Representation ID: 57206
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
The housing and mixed-use allocations that are being proposed to be carried forward from the Cambridge Local Plan 2018 and the South Cambridgeshire Local Plan 2018 should be reviewed and not automatically carried forward through this emerging plan. Where site allocations have been granted consent since the Local Plans were adopted, these allocations should not be repeated and instead the sites integrated within the urban area. On such occasions the emerging plan should seek to add to the allocations proposed and replace those sites from the 2018 Plans that have been delivered/ implemented.
The housing and mixed-use allocations that are being proposed to be carried forward from the Cambridge Local Plan 2018 and the South Cambridgeshire Local Plan 2018 should be reviewed and not automatically carried forward through this emerging plan. Where site allocations have been granted consent since the Local Plans were adopted, these allocations should not be repeated and instead the sites integrated within the urban area. On such occasions the emerging plan should seek to add to the allocations proposed and replace those sites from the 2018 Plans that have been delivered/ implemented.
Where these past allocations have not been progressed and delivery is therefore not certain, the opportunity should be taken to review their deliverability and viability to ensure the supply of sites is reliable and delivery sustained throughout the plan period. As such, the Local Planning Authority should not be reliant on these sites within their housing supply figures until their delivery can be confirmed. Claremont Planning recommends that the urban sites be supplemented by a mix of small to medium scale development opportunities within the surrounding larger settlements and villages to ensure that the provision of housing is not reliant on a single form of provision.
In order to maintain housing delivery the strategy should be widened to actively address the whole of the plan area. Claremont advises that the most robust approach to address this shortcoming would be to allow for growth of existing rural settlements.
Comment
Greater Cambridge Local Plan Preferred Options
The edge of Cambridge
Representation ID: 57213
Received: 10/12/2021
Respondent: European Property Ventures (Cambridgeshire)
Agent: Claremont Planning Consultancy
It is recognised that locating development on the edge of Cambridge is a sustainable development option it is considered that too much emphasis is placed on this as a location within the emerging Local Plan. This focus of providing larger sites in this location could lead to problems associated with infrastructure provision and housing delivery. There needs to be a better balance with more housing being apportioned to the rural area.
Whilst it is recognised that locating development on the edge of Cambridge is a sustainable development option it is considered that too much emphasis is placed on this as a location within the emerging Local Plan. This focus of providing larger sites in this location could lead to problems associated with infrastructure provision and housing delivery. There needs to be a better balance with more housing being apportioned to the rural area. Without a redistribution of housing this would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened. In addition to this there is more of a focus on home working since Covid and less reliance on needing to be close to larger cities so there is not as much need or desire for housing to be located in these types of locations.