Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

How much development and where?

Representation ID: 58875

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

The broad strategy is supported but not on its own. To provide the necessary delivery rates, choice and to help sustain existing communities and the success of the Greater Cambridge economy, a broader mix of sites, including more allocations in the sustainable villages, is required. The allocations in the plan do not adequately reflect the recognitions and opportunities set out in the Plan.

Full text:

How much – The general approach whereby housing need is determined by reference to employment growth (and not just the standard methodology) is necessary and welcomed. The logic in using a ‘Medium Consume own smoke’ approach arriving at a need of 44,400 homes is also understood. To fully deliver on the stated vision for Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities, a proactive net zero approach would also seek to go some way towards remedying the existing pattern of commuting into the Greater Cambridge area for work.

Where – The general focus on strategic sites is logical but increases risks in terms of delivery rates and leverage in discussions with the Councils. As required by the NPPF (Paragraph 79), Planning policies should also identify opportunities for villages to grow and thrive, especially where this will support local services. It is incumbent on the Councils to reflect this in the strategy. The proposed allocation of only 6 new sites / 384 new homes across the 5 Rural Centres, 13 Minor Rural Centres, 33 Group Villages and 55 Infill Villages (equating to just 3.3% of the new housing allocations proposed) does not reflect this. Additional sites in sustainable village locations need to be included as part of a rounded strategy.


Detailed comments are provided on the relevant section on Climate Change. Ambitious requirements in these regards are supported in principle, but they need to be demonstrably deliverable in practice. Importantly, the preparation of proposals will inevitable take longer (at least initially) and this must be factored into assumed trajectories. Any reliance on faster delivery of homes at Northstowe and Waterbeach and delivery rates generally need to be justified, including in light of the requirements of the proposed policies (not just the existing policies and situation).

In short, the broad strategy is supported but not on its own. To provide the necessary delivery rates, choice and to help sustain existing communities and the success of the Greater Cambridge economy, a broader mix of sites, including more allocations in the sustainable villages, is required.

We support the conclusions in the Development Strategy Topic paper that the rural southern cluster area provides the opportunity to provide new homes that are close to the research parks and potentially in locations with sustainable transport opportunities, some villages in the Green Belt have the best access which may constitute exceptional circumstances to release sites from the Green Belt, and that evidence suggests that housing in the rest of the rural area outside the southern cluster can help support delivery of a range of smaller sites within the area, and support the vitality of our villages. We do not however consider that the allocations in the plan then adequately reflect these recognitions and opportunities, with more sites required to deliver on the Plan’s vision.

Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 58881

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

The general approach to identifying new rural allocations for housing is supported, but planning policies also need to identify opportunities for villages to grow and thrive (as required by the NPPF (Paragraph 79)) and detailed comments in this regard are made in relation to S/RSC and S/RRA.

Full text:

The general approach to identifying new rural allocations for housing is supported, but planning policies also need to identify opportunities for villages to grow and thrive (as required by the NPPF (Paragraph 79)) and detailed comments in this regard are made in relation to S/RSC and S/RRA.

Comment

Greater Cambridge Local Plan Preferred Options

S/NEC: North east Cambridge

Representation ID: 58891

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

Separate to the joint Local Plan, the councils are also preparing an Area Action Plan for North East Cambridge which will provide a detailed planning framework containing site specific policies and key requirements which will be of equal status to those in the Local Plan once adopted. St John’s College has welcomed the opportunity to engage throughout this process and looks forward to continuing engagement. It is important that developments that will not prejudice the ambitions of the plan continue to be considered on their own merits whilst the specific policies are evolving.

Full text:

Separate to the joint Local Plan, the councils are also preparing an Area Action Plan for North East Cambridge which will provide a detailed planning framework containing site specific policies and key requirements which will be of equal status to those in the Local Plan once adopted. St John’s College has welcomed the opportunity to engage throughout this process and looks forward to continuing engagement. It is important that developments that will not prejudice the ambitions of the plan continue to be considered on their own merits whilst the specific policies are evolving.

Comment

Greater Cambridge Local Plan Preferred Options

S/RSC: Village allocations in the rural southern cluster

Representation ID: 58906

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

Land west of Hinton Way, Great Shelford (HELAA site 40485)

The limited landscape impacts and exceptional accessibility credentials of Land west of Hinton Way, Great Shelford (40485) constitute the exceptional circumstances required to release the site from the Green Belt and allocate it for residential development.

Full text:

As the Development Strategy Topic Paper acknowledges, the rural southern cluster area provides the opportunity to provide new homes that are close to the research parks and potentially in locations with sustainable transport opportunities. The approach to identifying new rural allocations (Key criteria and Relative factors) is supported. This does make it critical that the ratings in the Housing and Employment Land Availability Assessment (HELAA) are robust. The recognition that some villages in the Green Belt have the best access, which may constitute exceptional circumstances to release sites from the Green Belt reflects the policy in the NPPF (paragraph 142) that when “..reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account”, and is welcomed. We would also concur with the Reasons for the proposed policy direction’ in the Local Plan – “The Councils consider that the carbon benefits of locating homes close to jobs in the research parks, where there are existing opportunities for very high quality sustainable travel, could provide the exceptional circumstances required to justify removing land from the Green Belt in this location but only if considered alongside the environmental impacts.” That recognition is not however then reflected in the identification of sites (with the exception of one green belt site in the Southern Cluster – S/RSC/HW).

As stated in representations on the Vision and development, additional sites in sustainable village locations also need to be included as part of a rounded strategy to provide opportunities for villages to grow and thrive as required by the NPPF (Paragraph 79).

St John’s College has put forward a number of sites which we continue to contend would deliver on these opportunities, but one site in particular sits squarely within the stated policy direction. Land west of Hinton Way, Great Shelford (40485) is uniquely placed with proposed plans showing the route of the new public transport route between the A11/Granta Park and the Cambridge Biomedical Campus via Sawston, Stapleford and Great Shelford (Cambridge South East Transport Phase 2) following the northeastern edge of the site with a stop adjacent to the site. An application for a Transport and Works Act Order for the scheme is due to be submitted in early 2022. The site also affords ready access to the Rail Station and services in Great Shelford and cycle links via National Cycle Network Route 11 to Addenbrookes/the Biomedical Campus and the City Centre. Whilst the whole site has been given a red assessment for Landscape and Townscape in the SHLAA, the SHLAA concludes that “A significantly reduced scheme may be possible with mitigation”. The assessments for proposed allocation S/RSC/HW in the HELAA are similarly red for Landscape and Townscape for the proposed wider sites. Moreover, the SHLAA conclusions do not take account of the alignment of the new public transport route. Taking account of that route, development on the southwestern/village side of the new route would not have a significant adverse impact adverse impact upon the existing landscape character nor would it be an encroachment into the rural countryside. Allocation of the site sits squarely with the statement that “The Councils consider that the carbon benefits of locating homes close to jobs in the research parks, where there are existing opportunities for very high quality sustainable travel, could provide the exceptional circumstances required to justify removing land from the Green Belt in this location but only if considered alongside the environmental impacts.” The limited landscape impacts and exceptional accessibility credentials of the site constitute the exceptional circumstances required to release the site from the Green Belt and allocate it for residential development.

Comment

Greater Cambridge Local Plan Preferred Options

S/RRA: Allocations in the rest of the rural area

Representation ID: 58925

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

Cockerton Road, Girton (HELAA site 40555)

The “negligible impacts to the settlement character” of development as categorised in the SHLAA, the contribution it would make towards the national planning policy requirement for at least 10% of the housing requirement to be accommodated on sites no larger than 1 hectare, the contribution it would make to supporting the vitality of the village and the accessibility credentials of the site constitute the exceptional circumstances required to release land at Cockerton Road, Girton (40555) from the Green Belt and allocate it for residential development.

Full text:

We strongly support the statement in the Development Strategy Topic paper that “Our (the Councils’) evidence suggests that housing in the rest of the rural area outside the southern cluster can help support delivery of a range of smaller sites within the area, and support the vitality of our villages”. Having reached this conclusion, to provide opportunities for villages to grow and thrive as required by the NPPF (Paragraph 79) and as stated in representations on the Vision and development, additional sites in sustainable village locations need to be included as part of a rounded strategy. The approach to identifying new rural allocations (Key criteria and Relative factors) is supported. This does make it critical that the ratings in the Housing and Employment Land Availability Assessment (HELAA) are robust. The recognition that some villages in the Green Belt have the best access, which may constitute exceptional circumstances to release sites from the Green Belt reflects the policy in the NPPF (paragraph 142) that when “..reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account”, and is also welcomed. This does then need to be translated into the allocation of additional sites at villages.

St John’s College has put forward a number of sites which we continue to contend would deliver on these opportunities, but one site in particular sits squarely within the stated policy direction. Cockerton Road, Girton (40555) has an amber assessment and importantly is well located in terms of the opportunities to cycle and use the bus to work and to services, as well as being less than 1 hectare in size and thereby contributing towards the national planning policy requirement for at least 10% of the housing requirement to be accommodated on sites no larger than 1 hectare. The Citi 6 bus service links Girton to Cambridge with the nearest stop being on High Street at the end of Cockerton Road – a 2 minute walk from the site. The Citi 6 provides twice hourly buses taking 20 minutes to the centre of Cambridge (Emmanuel Street) and thereby linking on to other services. The Citi 5 bus service links Girton Corner to Cambridge and also provides twice hourly buses to the centre of Cambridge (Emmanuel Street). The site/Girton also provides safe, convenient cycle links into Cambridge for work, leisure and services, with the city centre (Bridge Street) being a 17 minute cycle journey from the site. The “negligible impacts to the settlement character” of development as categorised in the SHLAA, the contribution it would make towards the national planning policy requirement for at least 10% of the housing requirement to be accommodated on sites no larger than 1 hectare, the contribution it would make to supporting the vitality of the village and the accessibility credentials of the site constitute the exceptional circumstances required to release the site from the Green Belt and allocate it for residential development.

Comment

Greater Cambridge Local Plan Preferred Options

Climate change

Representation ID: 58936

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

Climate change is one of, if not the, biggest challenges facing us all. The aim to “Help Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use, and is resilient to current and future climate risks” is supported.

Full text:

Climate change is one of, if not the, biggest challenges facing us all. The aim to “Help Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use, and is resilient to current and future climate risks” is supported.

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 58942

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

Policy requirements should be ambitious yet deliverable. It is important that the requirements are demonstrably deliverable in the context of new development In Greater Cambridge.

Full text:

Policy requirements should be ambitious yet deliverable. The proposals that all heating should be provided through low carbon fuels (not fossil fuels), and no new developments should be connected to the gas grid, are supported. The space heating requirements proposed in the Plan exceed Building Regulations and the Topic Paper states that the requirements included in the Plan are in line with the recommendations of the Committee on Climate Change and also align with those recommended by the London Energy Transformation Initiative. It is important that the requirements are demonstrably deliverable in the context of new development In Greater Cambridge. Likewise, an ambition for proposals to generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year is understood but also needs to be demonstrably deliverable in the context of new development In Greater Cambridge.

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 58953

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

The Topic Paper focusses on the benefits of a 20% requirement rather than its practical deliverability, and it acknowledges that “Given the widespread application of BNG is still emerging, there is clearly further site-specific viability testing required of alternative BNG percentage requirements”. At present, the College cannot support a requirement in excess of 10%.

Full text:

St John’s College has provided general support for ambitious targets in the Local Plan and made that clear in its responses to other sections of the Plan. From experience of recent proposals, biodiversity net gain is an area where it is particular important that requirements are demonstrably deliverable in Greater Cambridge. The Topic Paper on Biodiversity seeks to provide justification for the proposed minimum 20% biodiversity net gain requirement, above the 10% requirement in the Environment Act. That 10% is in itself a transformational change. The Topic Paper focusses on the benefits of a 20% requirement rather than its practical deliverability, and it acknowledges that “Given the widespread application of BNG is still emerging, there is clearly further site-specific viability testing required of alternative BNG percentage requirements”. At present, the College cannot support a requirement in excess of 10%.

Comment

Greater Cambridge Local Plan Preferred Options

BG/GI: Green infrastructure

Representation ID: 58959

Received: 13/12/2021

Respondent: St John's College Cambridge

Agent: Savills

Representation Summary:

Green infrastructure is a key part of a successful spatial strategy. The identification of Strategic Green Infrastructure Initiatives is welcome, as is the statement in the First Proposals that “Explicitly identifying these initiatives and their objectives in the Local Plan will not restrict development in the broad areas they cover.” Engagement with landowners in the identified areas as the initiative develops will also be essential as to as the initiative develops

Full text:

Green infrastructure is a key part of a successful spatial strategy. The identification of Strategic Green Infrastructure Initiatives is welcome, as is the statement in the First Proposals that “Explicitly identifying these initiatives and their objectives in the Local Plan will not restrict development in the broad areas they cover.” Engagement with landowners in the identified areas as the initiative develops will also be essential as to as the initiative develops

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