Greater Cambridge Local Plan Preferred Options

1 These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2 The Development Strategy Topic Paper (DSTP) outlines the Council’s approach to establishing GCLP housing need figure. The housing need figure based on the Governments’ Standard Methodology is 36,600 dwellings, this figure would support the creation of 45,800 jobs in Greater Cambridge over the plan period. As recognised by paragraph 61 of the National Planning Policy Framework (NPPF) local planning authorities can plan for a housing number in excess of the standard method figures should market trends, underpinned by evidence, suggest otherwise.

3 Greater Cambridge is subject to significant growth initiatives and investment (public and private) some of which have already been implemented, with others coming on stream in the plan period. The aims and objectives of the Greater Cambridge City Deal, the Oxford-Cambridge Arc and the Cambridge and Peterborough Combined Authority in terms of job creation and housing growth provide important context in the preparation of the Greater Cambridge Local Plan (GCLP). Accordingly, the Councils have carried out employment forecasting to establish potential growth scenarios and the number of new houses needed to support new jobs in Greater Cambridge over plan period. In principle, this approach is supported by our client.

4 The Housing and Employment Relationship Report (November 2020) (HERR) suggests two scenarios in excess of the Standard Method as follows:

• Provide for 58,500 new jobs in the area over the plan period 2020-2041. To support this growth option a housing need of 44,400 dwellings is required over the over the plan period.

• Provide for 78,700 new jobs in the area over the plan period 2020-2041. To support this growth option a housing need of 56,500 dwellings is required over the over the plan period.

5 The GCLP First Proposals document seeks to support the delivery of 58,500 new jobs and 44,400 new dwellings over the plan period. Whilst the principle of exceeding the Standard Method housing target is agreed and welcomed by our client, given the significant momentum and political weight behind funding, infrastructure improvements and growth initiatives in Greater Cambridge it is considered that the GCLP should take a more positive approach to supporting the economic growth of the area. Indeed, the economy of Greater Cambridge and the Oxford-Cambridge Arc area is of national importance and the established education and innovation sectors are of international importance.

6 The differing outputs of the two economic growth scenarios is too vast for the Councils to conclude at this early stage of the plan preparation process that the GCLP should plan for the lower figure. Indeed, it is noted that the HERR states that the GCLP should plan for economic growth within the range of the two scenarios. The Councils should plan positively through the GCLP to meet the challenges and opportunities presented by the growth initiatives and funding which is focused on Greater Cambridge. Accordingly, it is strongly recommended that the Councils undertake further work to establish a housing requirement within the range stated in the HERR or plan for the higher figure. There is suitable housing land available at established sustainable settlements to support the economic growth of Greater Cambridgeshire.

Neighbourhood Planning

7 The First Proposals document confirms the Councils intended approach to facilitating sustainable housing growth through Neighbourhood Planning. The proposed approach would see Neighbourhood Plans meeting windfall housing numbers, with the Councils identifying an indicative housing requirement (on an informal basis) for a Neighbourhood Plan Area. Our client objects to this approach as paragraph 66 of the NPPF makes it clear that strategic policies should identify the housing requirement for a Neighbourhood Plan Area.

8 To allow rural settlements to thrive and sustain their service provision the GCLP should set the planning agenda by proactively allocating a proportionate housing requirement to established sustainable settlements such as Group Villages. This approach will allow Neighbourhood Plans to come forward with greater clarity and transparency; and also stimulate community planning which is supported by the NPPF. Without proportionate levels of housing growth sustainable rural settlements will stagnate over the plan period and communities run the risk of seeing important services becoming unviable.

9 The GCLP’s proposed approach to Neighbourhood Planning does not comply with paragraphs 66 and 67 of the NPPF and exposes wider shortcomings in the proposed development strategy put forward in the First Proposals document. The GCLP’s approach to promoting Neighbourhood Planning is in need of significant remedy as the plan preparation process continues.

1 These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2 The GCLP states that the proposed development strategy to guide the growth of Greater Cambridge over the plan period supports “rural communities to thrive and sustain services”. In rural areas of Greater Cambridge the development strategy proposes a “a very limited amount of development” at small sites at villages which have “very good public transport access”.

3 After accounting for existing committed housing supply, the First Proposals document states that new sites to deliver 11,640 additional dwellings are needed to meet the housing need target. To help meet this new need the proposed development strategy seeks the allocation of four new sites in the rural area of Greater Cambridge, two of which are located in the “Group Villages” Caldecote and Oakington. These four sites can deliver 224 dwellings. This equates to the rural area delivering only 1.9% of the new housing supply need. This figure rises to 3.2% if the housing delivery associated with supporting jobs at research parks to the south of Cambridge is included.

4 The development strategy is heavily reliant on the delivery of new settlements and strategic sites with 62% of the total supply over the plan period coming from these sources. Strategic sites and new settlements are often complex developments to bring forward and implement with significant investment in infrastructure often required before dwellings can be delivered. It is acknowledged that these types of sites have a role to play in meeting housing needs, however, it is clear that the proposed development strategy is heavily reliant on such sites coming forward, to a point where it risks the deliverability of the GCLP.

5 The development strategy and approach to making new allocations will not facilitate the delivery of thriving rural communities and risks the vitality of key services over the plan period. The rationale for proposing allocations in Caldecote and Oakington as opposed to other available and suitable sites at other Group Villages is not evidenced robustly. It would appear that the Councils development strategy for rural areas has been one which in the main restricts development, and where allocations are proposed, the process of making allocations has been site-led rather than being led by an objective process which compares the sustainability credentials of sustainable rural settlements.

6 The First Proposals document and accompanying evidence base aims to support rural communities and sustain their existing service provision, but its current approach to making new housing allocations and supporting Neighbourhood Planning will not deliver on this aim.

7 Planning policies are required to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to their objectively assessed housing need. The NPPF makes it clear that planning policies need to bring forward a mix and variety of housing land. The approach proposed through the GCLP does not represent a flexible and balanced approach capable of responding to changing circumstances or providing a mix and variety of sites. In addition, paragraph 69a) of the NPPF requires development plans to accommodate at least 10% of their housing requirement on sites no larger than one hectare. The development strategy proposes no new housing allocations on sites of less than 1ha. Instead, the GCLP relies on previous commitments to be delivered in the plan period and the potential for these smaller sites to come forward via windfall sites. Page 40 of the First Proposals document confirms that the new allocations of this type are not proposed as they would likely need to be directed to less sustainable locations, thus having a negative impact on climate change and requiring Green Belt releases. Our client strongly disagrees with the Councils justification in this regard as the content of the Housing Economic Land Availability Assessment (HELAA) demonstrates that there are a number of available sites for residential development, located outside of the Green Belt, at sustainable settlements such as Group Villages.

8 The GCLP’s focus on directing growth to New Settlements and strategic sites will significantly limit the supply of new housing sites being delivered by smaller and mid-sized (SME) housebuilders. Paragraph 69 of the NPPF makes it clear that small and medium sized sites can make an important contribution to meeting the housing requirement of an area. The Government is keen to see these types of sites come forward to boost supply, increase design quality, increase delivery rates and assist SME housebuilders generally. The lack of small and medium sized sites being delivered by the GCLP is contrary to paragraph 69 of the NPPF and will likely lead to a constrained housing land supply over the plan period and see less bespoke housing schemes being delivered at a time when there is national drive to boost design quality.

9 Over the current plan period and historically in Greater Cambridge there has been significant pressure placed upon the five-year housing land supply. This in part is due to the current over reliance on strategic sites and failure to allocate proportionate growth at established rural settlements which have fewer delivery constraints. Accordingly, promoting a development strategy which provides variety in making new allocations will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP and Neighbourhood Plans should take the lead by positively planning for new housing at established sustainable rural settlements, such as Group Villages, rather than being subject to future speculative development proposals at sites not allocated in a Local Plan when there is a deficit in supply across the plan area.

10 Alongside the total housing need requirement, the proposed development strategy should be reconsidered and amended to ensure that established settlements in the rural area benefit from sustainable levels of housing growth.

1. These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2. Orwell is located to the southwest of Cambridge within South Cambridgeshire. Adopted Policy S/8 of the adopted Local Plan (2018) identifies Orwell as a Group Village, this classification is to be carried forward through the GCLP. Group Villages are classed as the fourth most sustainable settlement type in the proposed GCLP Settlement Hierarchy behind Cambridge city, Towns, Rural Centres and Minor Rural Centres.

3. In the period 2015-2018 there has been a vast number of appeal decisions and decisions at a local level which has confirmed that Group Villages are capable of accommodating housing growth by virtue of their service provision and status in the settlement hierarchy.

4. Orwell village has access to a number of facilities enabling residents to access services for their day-to-day needs. The appeal decision associated with outline planning permission for 49 dwellings appeal scheme at Hurdleditch Road, Orwell concurs with our assessment in respect of Orwell being capable of supporting housing growth (of a similar scale put forward via this Call for Sites exercise). The Inspector concluded that future residents of the appeal scheme would be located closely to existing local facilities and services providing for some day to day needs of residents and that there was the opportunity for some journeys to be made by public transport to facilities and services located further afield.

5. Attached as a separate sheet is a detailed overview of the shops, services and transport links which would serve residents. Tables 1-3 (see attachment) also provide an approximate distance and travel time to each of the services from the land which is being promoted for residential development by our client.

7. In light of Tables 1-3 (see attachment) it is clear Orwell possesses a range of shops and services which can be reached via sustainable modes of transport. The village is served by a direct bus link to Cambridge which has services at peak times to allow a commute to and from the city centre (Monday – Saturday). Orwell also benefits from quick and convenient access to rail and park & ride connections which provide links to major centres.

8. Orwell is an established sustainable settlement capable of accommodating proportionate levels of new housing growth to assist in preparation of a balanced and varied housing supply which in turn will support the economic growth of Greater Cambridge.

In updating the new settlement boundary for Orwell, the Land at Hurdleditch Road as identified by approved Reserved Matters application S/3870/18/RM should be included in the settlement boundary. This residential development for 49 dwellings and community car park adjoins the existing settlement and forms part of the built up area of the village. The Councils latest Housing Trajectory states that 39 of of 49 approved dwellings had been delivered as of December 2020. It would not be logical or sound for this delivered/completed development to not be included within the settlement boundary.

In updating the new settlement boundary for Orwell, the Land south of Hurdleditch Road as identified by approved planning application S/2379/13/FL should be included in the settlement boundary. The residential development at 'Oatlands' was delivered many years ago and forms part of the built up area of the village. It would not be logical or sound for this delivered/completed development to not be included within the settlement boundary.

1. These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2. Our client is promoting two parcels of land for residential development at Orwell, South Cambridgeshire. The sites were both previously promoted through the March 2019 and February 2020 consultation stages associated with the preparation of the GCLP. The two sites are referenced in the HELAA as follows: Land to the north east of Hurdleditch Road, Orwell (Ref: 40383) and Land to the south west of Hurdleditch Road, Orwell (Ref: 40378).

3. Our client welcomes the publication of the HELAA review which appraises the development potential of the site. However, our client has noted a number of specific technical flaws in the published appraisals which should be remedied as the GCLP preparation continues.

4. As set out in our previous representations masterplanning and technical work has been prepared to support the promotion of both sites for residential development. This work very much remains valid and robust. At this time, we are now also able to provide further technical evidence to support the promotion of the Site 40383. Please find attached to these representations the following documents:

a. Transport – Technical Note (Cannon Consulting Engineers)
b. Flood Risk Assessment (Cannon Consulting Engineers)
c. Preliminary Ecological Assessment (James Blake Associates)

5. In light of our review of the HELAA appraisal and our client’s site specific technical work we attach as a separate sheet a schedule of the HELAA inaccuracies and recommended amendments.

6. This set of representations has demonstrated that the proposed GCLP Development Strategy is flawed in its approach to supporting economic growth, providing a robust housing supply and supporting the long-term vitality of established sustainable rural settlements.

(See attachment)

7. In reviewing and amending the GLCP’s overall housing need requirement and development strategy it is strongly recommended that our client’s sites are allocated for residential development. Both of our client’s site are suitable and deliverable with only very limited development constraints (which can be overcome through planning conditions and careful design). The sites are located at a settlement which has been found to be sustainable location for residential development by a Planning Inspector at Appeal in 2017.

1. These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2. Our client is promoting two parcels of land for residential development at Orwell, South Cambridgeshire. The sites were both previously promoted through the March 2019 and February 2020 consultation stages associated with the preparation of the GCLP. The two sites are referenced in the HELAA as follows: Land to the north east of Hurdleditch Road, Orwell (Ref: 40383) and Land to the south west of Hurdleditch Road, Orwell (Ref: 40378).

3. Our client welcomes the publication of the HELAA review which appraises the development potential of the site. However, our client has noted a number of specific technical flaws in the published appraisals which should be remedied as the GCLP preparation continues.

4. As set out in our previous representations masterplanning and technical work has been prepared to support the promotion of both sites for residential development. This work very much remains valid and robust. At this time, we are now also able to provide further technical evidence to support the promotion of the Site 40383. Please find attached to these representations the following documents:

a. Transport – Technical Note (Cannon Consulting Engineers)
b. Flood Risk Assessment (Cannon Consulting Engineers)
c. Preliminary Ecological Assessment (James Blake Associates)

5. In light of our review of the HELAA appraisal and our client’s site specific technical work we attach as a separate sheet a schedule of the HELAA inaccuracies and recommended amendments.

6. This set of representations has demonstrated that the proposed GCLP Development Strategy is flawed in its approach to supporting economic growth, providing a robust housing supply and supporting the long-term vitality of established sustainable rural settlements.

(See attachment)

7. In reviewing and amending the GLCP’s overall housing need requirement and development strategy it is strongly recommended that our client’s sites are allocated for residential development. Both of our client’s site are suitable and deliverable with only very limited development constraints (which can be overcome through planning conditions and careful design). The sites are located at a settlement which has been found to be sustainable location for residential development by a Planning Inspector at Appeal in 2017.