Greater Cambridge Local Plan Preferred Options

These representations are submitted by Pegasus Group on behalf of Clarendon Land and Development Ltd who has land interests in land west of Long Lane, Fowlmere (LPA ref: 40327). We have previously submitted responses to the Call for Sites exercise (March 2019) and Regulation 18 Consultation (February 2020). These representations should be read in conjunction with these previous comments.

Our client supports the broad principles which underpin the stated ‘vision’ and ‘aims’ of the GCLP. Indeed, reducing climate change and minimising carbon emissions are key considerations for the planning system and the wider world. Notwithstanding this in principle support, there is still a need for the GCLP to strike a sustainable balance between focussing on reducing climate change and safeguarding the vitality and vibrancy of existing sustainable villages in South Cambridgeshire.

The ‘vision’ and ‘aims’ of the GCLP are silent on supporting the long-term vitality and vibrancy of rural communities; of which there are many in South Cambridgeshire. The GCLP should encourage proportionate housing growth supported by investment in local infrastructure at established rural sustainable settlements.

The ‘vision’ and ‘aims’ should be amended to make reference to supporting rural communities and to ensure there is sufficient and proportionate growth to ensure they thrive in the future and are not left to stagnate.

These representations are submitted by Pegasus Group on behalf of Clarendon Land and Development Ltd who has land interests in land west of Long Lane, Fowlmere (LPA ref: 40327). We have previously submitted responses to the Call for Sites exercise (March 2019) and Regulation 18 Consultation (February 2020). These representations should be read in conjunction with these previous comments.

Policy S/DS: Development Strategy sets out where the homes and jobs identified in the Plan should be provided in order to meet the vision and aims of the Local Plan. It is considered that this development strategy is flawed as it concentrates a significant amount of development in new settlements and large edge of Cambridge sites. Less than 4% of the total additional homes planned for are to be located within existing villages. This is not an appropriate response to allow these villages to grow and thrive during the plan period. It is acknowledged that a sustainable strategy is required in relation to the location of new development. However, to define all villages in South Cambridgeshire as unsustainable and not allowing any new modest development to meet their needs will ensure that these villages will never grow, prosper or adapt to changing needs and they will stagnate.

The Plan acknowledges that affordability is a key concern in Great Cambridge and the area contains some of the least affordable areas in the country outside of London. It is likely that this pattern will continue to increase in villages if new development is not allowed and therefore people with connections to the area may not be able to afford to buy homes in villages and the choice of suitable accommodation will be limited. The provision of new housing has the ability to provide opportunities to create a more balanced local population by providing opportunities for young people to stay in the community they grew up in or for older people seeking to move within the community. This lack of housing and choice will have serious implications on the social-economic make-up of the villages.

A Local Plan objective is "Making Places better" but it is unclear how this objective will be achieved in rural communities with no housing growth allowed and no strategy included to improve the sustainability of these locations by improving public transport, facilities or services which will assist in the viability and vitality of these locations. It is not adequate to ignore the needs of these communities by cutting them off and stunting their growth. South Cambridgeshire District is a rural authority and a large proportion of the current population resides in rural areas. This population is anticipated to grow significantly in the plan period by 27.4% as set out table 9 in Housing & Employment Relationships (G L Hearn Nov 2020). This population growth and investment cannot all be directed to new settlements at the cost of the existing villages. Investment should also be directed towards improving public transport for rural communities to improve their sustainability and access to a range of services. Rural communities should be embraced rather than forcing all future needs to be met in an urban environment.

Sustainability

The Local Plan does not acknowledge the changing patterns to sustainable living and the basis of the Development Strategy is on an old-fashioned definition of sustainability whereby people need to travel to work, leisure or essential facilities from their home in a private car. The COVID-19 pandemic has acted as a catalyst to changing patterns of how people live and work. Increased working from home has resulted in differing commuter patterns and less reliance on car-borne journeys. Where car journeys are required, people have become more carbon conscious and more are choosing electric modes of transport (e-bikes, electric cars). With the increase in superfast broadband to these rural communities, a variety of options are available for ecommerce, online shopping, virtual GP appointments, prescription deliveries, supermarket essential shopping deliveries. These varied digital and e-commerce opportunities ensure that individuals no longer need to be within walking or cycling distance of these services and facilities to access them and the reliance on a private car will be reduced further. There is no assessment of these changing living/working/shopping patterns in the Local Plan and the consignment of these rural villages to a no-growth option is based on old-fashioned views on car ownership and use with no acknowledgement of these changing digital opportunities and how they can significantly improve sustainable rural living.

The National Planning Policy Framework ('Framework' 2021) sets out in paragraphs 78-79 that housing should be located where it will enhance or maintain the vitality of rural communities. Policy S/DS will not meet this objective of the Framework and the policy will significantly impact the vitality of these communities. Additional development in villages will help to sustain the available services by maintaining population numbers. New residential schemes will propose additional households, all of which can use the local services, facilities, clubs and societies within the village resulting in greater levels of patronage and custom. This will support the ongoing provision, vitality and viability of these services.

The Framework acknowledges that sustainable transport solutions will vary between rural and urban areas and this should be taken into account in both plan making and decision making. The Local Plan has declared that these communities are not sustainable and are therefore not suitable for any development (regardless of any existing need or to address catastrophic affordable issues) and has not offered a solution as to how to deal with this to improve this situation or to acknowledge the changing patterns of working/living and how this may result in allowing these communities to grow sustainably. The Sustainability Appraisal (SA) for the Local Plan does not adequately account for this change in sustainable characteristics as set out in our detailed comments on the SA.

Over-reliance on large sites

A further flaw in the Development Strategy is the over reliance on large complex schemes to meet the housing needs of the District which will impact on immediate housing delivery. South Cambridgeshire has previously relied on strategic sites for housing delivery; challenges and subsequent delays that have arisen with such schemes have resulted in a housing shortfall. This is evident from the numerous planning appeals which have been allowed in South Cambridgeshire Group Villages over recent years which have proven that development in these locations has been deemed sustainable and suitable to meet the needs of the District. It is evident therefore that the allocation of smaller sites within the Local Plan, such as those within Group Villages will ensure a more robust and flexible delivery strategy for the District in the short term. The NPPF requires local planning authorities to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to meet their objectively assessed housing need. Paragraphs 60 and 68 of the Framework make specific reference to the need for a mix and variety of land to be identified for housing. Paragraph 69 specifically sets out that development plans should identify land to accommodate at least 10% of their housing requirement on sites no larger than 1 hectare.

The First Proposals document sets out that 96.5% of new dwelling allocations are proposed at sites which have a capacity of 750 dwellings or more. New Settlements are proposed to provide 38% of the total housing growth over the plan period (existing and new allocations), this is a 15% rise on the current adopted Plans and a 20% rise on the old Structure Plan.

The Development Strategy Topic Paper provides the current Housing Trajectory as of April 2021. The existing Northstowe new settlement allocation delivers new housing at a range of 204-365 dwellings per annum between 2020/21 and 2025/26, before dropping to 250 dwellings per annum for the rest of the plan period. The existing Waterbeach new settlement allocation is scheduled to commence housing delivery in 2022/23 at 80 dwellings per annum before rising to 250 dwelling per annum for the rest of the plan period. The GCLP carries forward these existing new settlement allocations and seeks to increase housing delivery at both sites by an additional 50 dwellings per annum from 2026/27 all the way through to 2040/41. Accordingly, both new settlements will be required to deliver dwellings at 300 dwelling per annum for a 15-year period. This increased delivery accounts for 13% of new housing growth proposed to be allocated by the GCLP (1,500/11,596).

The four proposed new allocations in Cambridge urban area and the edge of Cambridge account for 67% (7,762/11,596 dwellings) of the new allocated growth through the GCLP.

It is acknowledged that the allocation of new settlements and large-scale strategic sites can form a key part of a balanced spatial strategy to bring forward sustainable growth in a district. However, the approach put forward by the Councils does not represent a flexible and balanced approach capable of responding to changing circumstances (Framework paragraph 33) or providing a mix and variety of sites. The 10% target set out in paragraph 69 of the Framework is not met.

Furthermore, the per annum housing delivery targets for the new settlements are very high, particularly at Waterbeach which is yet to deliver dwellings. Bringing forward new settlements and large strategic sites is a complex process which often requires the delivery of significant up-front infrastructure which can sometimes be subject to different funding mechanism and complex land ownership constraints. These issues often impact and delay the delivery of strategic sites, accordingly, the GCLP needs to allocate a variety of different types of sites. The delays in delivery of new settlements in the Greater Cambridge area, along with the necessary strategic infrastructure are well documented and there continues to be a significant lag in the delivery of new homes required at these locations. There is nothing within the proposed plan that provides comfort that these issues will be satisfactorily resolved.

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 more balanced development strategy will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP should take the lead by positively planning for new housing at established sustainable rural settlements 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.

Site Selection

It is also questionable as to how the small number of allocations which have been identified in Group Villages have been chosen in comparison with the sites which have been put forward during the Call for Sites exercise. The only proposed allocations in group villages are:
• Hunts Road, Duxford (S/RSC/MF) – 60 homes
• Land at Highfields, Caldecote (S/RRA/H) – 64 homes
• Station Road, Oakington (S/RRA/MF) – 20 homes

There is no assessment as to why these three sites have been chosen over the other available sites in group villages. Only Oakington group village is highlighted as having good sustainable links in Topic Paper 1: Strategy. Duxford and Highfields, Caldecote are identified as group villages with the same sustainability characteristics as Fowlmere, where any development has been deemed as unsustainable. It is not understood as to the rationale used to differentiate the settlements or development proposals. All of the proposed three allocations were also ranked as amber in the HELAA same as a number of sites in Fowlmere including our site at Long Lane, therefore it is unclear as to how they were selected for allocation over and above other amber-ranked sites.

The Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) (2021) listed a number of acceptable sites in Fowlmere which had been submitted as part of the Call for Sites exercise (5 were ranked amber and 9 were ranked red). There were no sites which were ranked green due to the preconceived judgement that the settlement (or any group village) is not a sustainable location. However, some amber-ranked sites have been selected for allocation (Oakington, Duxford and Caldecote). The accessibility to services and facilities criteria is heavily skewed to traditional access to facilities and services with no understanding or acknowledgement of digital ecommerce or changing patterns of living and working as set out above.

The site suitability appraisal for land off Long Lane, Fowlmere in the HELAA (LPA ref: 40327) has a number of positive factors including its relationship with existing development and that is available and achievable for development within the first 5 years of the plan period. It is considered that these are significant benefits which have not been adequately accounted for or taken into consideration.

The other comments in the HELAA appraisal for the Long Lane, Fowlmere site are summarised below:
• Not located with a flood risk area (green);
• Landscape impact can be mitigated by boundary planting, buffer planting on north and west boundaries, form
of development to reflect existing settlement and to have rural approach (amber);
• Any biodiversity/geodiversity impact can be mitigated or compensated (amber);
• Not an open space designation (green);
• 100m outside the Conservation Area (Green)
• Potential for archaeology as located on edge of historic village but can reasonably be mitigated (Amber);
• Site access constraints can be overcome (Amber)
• Any impact on functioning of trunk roads can be mitigated (Amber);
• The site is capable of being developed to provide healthy internal and external environments in relation to
noise/vibration/odour and light pollution (amber);
• Site is not located within an Air Quality Mitigation Area (AQMA) (green);
• There is potential for historic contamination which will require conditions (Amber)

It is considered that the technical aspects of developing this site are positive and any potential issues can be mitigated for. The site is well related to the settlement and is considered to be a logical extension to the built-up development. This site represents a good opportunity for modest residential development which is immediately available with limited environmental impact. It is deemed unreasonable to discount or rank a site amber due to the need for additional technical documents to further investigate issues such as contamination or archaeology which would be a requirement for all sites.

In Greater Cambridge, housing is less affordable than the national average and is getting worse. As such, it is imperative that housing delivery is a priority for the Council in an attempt to ease the affordability pressures in the District. Development of this site will widen the choice of different housing types in Fowlmere itself.

The development of this site will give rise to economic and social benefits. New residents will use the existing local community services, facilities, clubs and societies within the village. This will support the ongoing provision, vitality and viability of these services. As part of the development proposals, financial contributions could be made, if required, towards these local facilities including education, health and public transport provision to enhance these facilities further; in line with paragraph 79 of the Framework and the intention of supporting local services through development in rural areas.

As such it is considered that modest development in the group villages, including Fowlmere, should be permitted to allow for immediate housing delivery, flexibility within the Plan and to allow these villages to meet their future housing needs whilst maintaining and enhancing their existing services.

These representations are submitted by Pegasus Group on behalf of Clarendon Land and Development Ltd who has land interests in land west of Long Lane, Fowlmere (LPA ref: 40327). We have previously submitted responses to the Call for Sites exercise (March 2019) and Regulation 18 Consultation (February 2020). These representations should be read in conjunction with these previous comments.

The Sustainability Appraisal (SA) for the Local Plan First Proposals (Oct 2021) is flawed as it is based on the preconceived judgement that development in villages is unsustainable due to car dependency. It is acknowledged in the SA that affordability is a key issue in Greater Cambridge (Chapter 3) but this does not form a key measure to rate sustainability.

The SA is an unwieldy document and difficult to understand the methodology and processes used. It is a 473-page document with numerous tables and colour coding and symbols which are not easily referenced.

Spatial Option 5 refers to the total development need of Greater Cambridge being dispersed to villages which results in:
• 40% located in rural centres
• 40% located to minor rural centres
• 17% located in group villages
• 3% located in infill villages.

This option was deemed unsustainable in the SA. It is clear that this level of growth solely directed at rural areas would cause sustainability issues and impact the area. However, this option should not be discounted on this skewed assessment alone. A sensible approach would be a blend of all options which results in some growth in villages not the entire growth for the whole District. It is unclear if the SA has assessed this blend of options or if it has discounted growth in villages based on this assessment.

The SA concludes that development may help to support viability of existing services and facilities at these villages and will improve access to these services. This point is reiterated in the Framework and it is important to ensure that these services and facilities have an adequate customer base to safeguard their survival. If modest development is not allowed in these communities, these services will fail and disappear during the plan period. The SA supports growth in more rural locations which is likely to help support services and facilities and may even help provide new facilities or build a business case for improved public transport. This would help to achieve the social, inclusion and equality objective of the SA. However, this objective is not carried through to the proposed Development Strategy within the Local Plan and no explanation is provided as to how the services and facilities in these communities are likely to survive with no housing or economic growth.

In its assessment of villages, the SA is unclear as to why all sites put forward as part of the Call for Sites exercise are not listed and assessed (Table 4.23). The ranking used and assessment of points is unclear and very confusing. There is no weighting of factors. It is considered that the impact on housing delivery in these areas, the impact on affordability and the benefit to the vitality of these communities are considerable and should be assessed as such. It is considered that these factors are not given enough significance in the planning balance.

The SA is a lengthy and unwieldy document but is concluded in paragraph 6.2 very simply by stating that "the proposed direction of the Local Plan performs well in sustainable terms." This brief conclusion of a document which runs to 473 pages is not considered adequate to summarise such a complex document and subject and has not provided a full analysis of all the differing factors which relate to a complicated spatial strategy with a multitude of development options.