Greater Cambridge Local Plan Preferred Options

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

If this does not happen, Northwest Biotherapeutics (NW Bio) are concerned that this could result in severe difficulties recruiting talent for the knowledge based jobs that NW Bio is creating in the Cambridge area. NW Bio is already experiencing difficulty with recruitment due to the lack of housing availability in the Cambridge area and the necessity for long commutes to jobs in this area. In addition, the situation will lead to a drain companies from Cambridge and the wider region, not because of lack of interest or commitment but because they are forced to relocate in order to grow and thrive. At present, the growth of Cambridge is being constrained and this is limiting job creation and innovation. There is a lack of good quality specialised laboratory space, resources and housing to support expanding employment opportunities. This is in comparison to the new biotech and technology hubs that are being created or expanded in Oxford and Manchester, as well as elsewhere in the UK, Europe, US and China.

NW Bio’s experience is that cutting edge regenerative medicine companies are investing heavily in key areas such as manufacturing and product development, to build new manufacturing facilities and core competencies in the UK. However, most of the infrastructure and manufacturing facilities have been in geographic areas such as Oxford and the South East (London, Surrey etc).

Despite AstraZeneca choosing to invest in infrastructure investment for research in the Cambridge area, the number of other companies investing into Cambridge has been very limited, often starting in the UK but rapidly moving to the US. NW Bio consider that this is because of a perception that the US is a more favourable market for investment, new facilities and job creation, as well as innovation and embracing risk.

In order to reverse the talent and company drain described above, it is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH be based on the higher growth level option.

OBJECT

NW Bio is promoting the Mill Lane Site, Sawston for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster, and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Sawston and the decision to not release additional land from the Green Belt.

The overall development strategy proposed would be very reliant on the delivery of an extensions to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne are proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predicts high average annual housing delivery rates for the new settlements: Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum; and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon), which has the highest annual delivery rate of current new settlements, is delivering at 295 dwellings per annum. The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, and there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that more realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided, at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not, and will not, provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites, including the Mill Lane, Site, Sawston, that are capable of providing policy compliant levels of affordable housing.

The promoted development by NW Bio, the Mill Lane Site, Sawston, is located within the Green Belt. In these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation, and it is proposed that other land within the Rural Southern Cluster is released from the Green Belt for these reasons. The Mill Lane Site and Sawston generally are very well related to Addenbrooke’s Hospital, Royal Papworth Hospital, Cambridge Biomedical Campus and other employment opportunities within and on the edge of Cambridge.

Additionally, the Mill Lane Site is owned by Northwest Biotherapeutics (NW Bio), a biotechnology company developing novel immune therapies to treat cancer. NW Bio’s DCVax®-L immune therapy for Glioblastoma brain cancer is in the NIHR's Priority Portfolio, and was the first product to receive PIM designation as a Promising Innovative Medicine from the Medicines and Healthcare products Regulatory Agency (MRHA). NW Bio currently has offices in London and is developing an advanced manufacturing and technology development facility in Sawston, where they are working together with Advent BioServices to develop the Vision Centre on the former Spicers site. Advent is one of only a small number of companies in the world that specializes in technology/process development and advanced manufacturing for cell and tissue therapies for cancer and other diseases.

Since our previous submission, significant progress has been made in the physical development of the Vison Centre. Most importantly, it is expected within the next week or two that the Medicines and Healthcare products Regulatory Agency (MHRA) will be granting certification of Phase One of the production facility to ramp-up production to 45 self paying patients per month under their Specials/Compassionate Treatment Program. This milestone approval represents 7 months of testing and MHRA reviews and inspections involving all of the now 39 staff and growing. In turn, this major event for the entire area has been facilitated by the following developments at the plant itself over since our previous submission of representatives, including the following:

• Significant upgrade to two clean room suites to enable these to be Medicines and Healthcare product Regulatory Agency (MHRA) compliant
• Warehouse incorporating Goods in/quarantine and a temperature controlled store
• Two process development laboratories
• Quality control laboratory
• Freezer facility incorporating room for 60 x -80C freezers (currently 30 freezers in place)
• Construction of further office to support freezer facility
• State-of the-art Ultra cold Liquid Nitrogen facility with the capacity to store up to 3,000,000 samples at -196C for third party clients
• Installation of a nitrogen generator which removes and liquifies N2 from the atmosphere – removes the need for weekly deliveries of gas to site
• Cell therapy product goods in/out rooms
• Data management centre containing 3 towers loaded with processers and other essential IT equipment
• Installation of lift shafts and stairs to upper floor
• Fitting out of additional office space
• Creation of corridors for materials, staff and waste

The following infrastructure also has now been put in place to serve the Vision Centre:

• Installation of emergency generator, boiler, uninterrupted power supply, air handling units
• Installation of BT fibre network
• Installation of environmental monitoring equipment and software – monitors temperatures, pressures, air changes, humidity 24/7
• Installation and implementation of a quality management system and the writing of over 1000 regulatory documents
• Installation of electricity supply to futureproof the building and remove the VC from the larger site network
• Implementation of a laboratory information management system
• Development of website
• Awarded licences from the Human Tissue Authority for cell storage
• Underwent inspection from MHRA -awaiting licence to manufacture advanced therapy products for UK Specials programme and for clinical trials

The Vision Centre is located just across the A1301, a 5 or 10-minute walk from the proposed residential site on Mill Lane. The Vision Centre is an advanced manufacturing facility that will produce cell therapy products for the UK and for export to the European Union and other geographies. The development of the Vision Centre will involve the creation of up to 450 new high-value jobs across a wide range of skill levels in phases over the next few years.

Recruitment has also taken place since the submission of previous representations and the total number of employees at the Vision Centre is now 40. These include manufacturing scientists, QA and QC staff, facilities management, IT, clinical coordinator, administration, validation experts, HR and finance personnel. This also includes the recruitment of three apprentices as part of the national network ATAC scheme in cell and gene therapy, with a fourth apprentice to be taken on shortly.

Some of the staff that have been taken on to date are from the local area but other are from elsewhere in UK including London, Stevenage, Bedfordshire, Kent, Berkshire, and Suffolk. It is not possible for all staff to be recruited from the local area as a result of the need to recruit Qualified persons (for regulatory purposes).

A key factor which will affect the pace at which personnel can be hired for these jobs will be the availability of housing nearby to the Vision Centre. A proportion of Vision Centre employees will have to live close to the site because producing and managing living cell products requires unpredictable and varied hours (e.g., when tissues are received from hospitals for processing at any time of the day or evening). The jobs at the Vision Centre are and will continue to be for a range of employees, from school leavers through to PhD level. This will result in increased employment and learning opportunities within Sawston and South Cambridgeshire as a whole, which will have benefits for social inclusion.

The ability of other employees of the Vision Centre to live in close proximity to the site will also have clear benefits for their mental health and well-being, by avoiding the need for significant commuting and promoting opportunities for active forms of travel, such as walking and cycling. The residential development of the Mill Lane Site, Sawston would also provide additional housing that is much needed for nearby surrounding employment sites, including existing sites to the east and north of Sawston; Huawei’s emerging business and research campus at the former Spicers site; Granta Park; Cambridge Biomedical Campus; and the expanding Wellcome Genome Campus.

The Mill Lane Site is also in a location with extensive existing transport access by walking, cycling, bus and train and the Site has good accessibility (a 15 minute or so walk or a short cycle ride) to existing services and facilities within Sawston including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. Having all of these services and facilities within close proximity of the Site will allow future occupants to access these services using sustainable travel modes, thus reducing emissions associated with use of the private car, and will assist the development, and its occupants, in integrating into the wider Sawston community. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

There is also an identified need for affordable housing in Sawston that would not be met by the emerging GCLP.

Paragraph 141 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identified previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The Mill Lane Site, Sawston is well served by public transport (bus and rail) and is well connected with existing cycle routes, and there are future public transport improvements proposed in the surrounding area. Therefore, the release of the site from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

There are three other paragraphs in the NPPF that suggest additional allocations should be made in Sawston and the Rural Southern Cluster. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders.

Sawston contains a good range of services and facilities including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. The promoted development by NW Bio would support existing services and facilities. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

The nearest bus stops are located on Cambridge Road within an acceptable walking distance of the site via the existing footways on Mill Lane and New Road, and provide access to Bus Services Citi 7 and 7A, and are likely to be used by future residents of the site to access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance of the site, and likely to be used by future residents of the site to access existing services and facilities in Cambridge and the wider area surrounding the site.

Therefore, the promoted development by NW Bio at the Mill Lane Site, Sawston is accessible by a range of sustainable modes of transport, and it would be consistent with national policy to direct additional development to this site.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 115 affordable dwellings in Sawston for those with a local connection to the village. The emerging GCLP contains one allocation for residential development in Sawston that it is proposed will be carried forward from the South Cambridgeshire Local Plan (2018) (S/RSC/H/1 (c): land south of Babraham Road, Sawston) for 80 dwellings. Assuming that this site comes forward and delivers a policy compliant level of affordable housing (40%), it can be assumed that this site would deliver 32 affordable dwellings. Accordingly, there would be a residual need for 83 affordable dwellings within the village. The identified need for Sawston would not be met without an additional allocation. It is noted that a Sawston Neighbourhood Plan Area was designated in 2018, and it appears that there has been some evidence gathering since then but a draft plan has not yet been published. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Sawston should seek to accommodate district-wide affordable housing needs and not just those local needs arising in the village and the immediate surrounding area. The promoted development by NW Bio would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages in the Rural Southern Cluster including at Sawston, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is an identified need for affordable housing in the villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages including Sawston, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village.

As requested in NW Bio’s representations to Section 2.5 Rural Southern Cluster, the Mill Lane Site, Sawston should be released from the Green Belt and allocated in emerging GCLP for residential development.

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Sawston falls within this category.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The promoted development at the Mill Lane Site, Sawston would support the existing services and facilities in the village, including convenience stores, post office, library, banks, public houses and restaurants and bus services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire. It is requested that small sized sites such as the Mill Lane Site, Sawston are allocated to meet the requirement for a mix of sites including those that are easily deliverable.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. The nearest bus stops are located on Cambridge Road within an acceptable walking distance of the site via the existing footways on Mill Lane and New Road, and provide access to Bus Services Citi 7 and 7A, and are likely to be used by future residents of the site to access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance of the site, and likely to be used by future residents of the site to access existing services and facilities in Cambridge and the wider area surrounding the site.
Sawston and the Mill Lane Site are sustainable locations in transport terms, and additional development in this location would be consistent with Paragraph 104.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 115 affordable dwellings in Sawston for those with a local connection to the village. The emerging GCLP contains one allocation for residential development in Sawston that it is proposed will be carried forward from the South Cambridgeshire Local Plan (2018) (S/RSC/H/1 (c): land south of Babraham Road, Sawston) for 80 dwellings. Assuming that this site comes forward and delivers a policy compliant level of affordable housing (40%), it can be assumed that this site would deliver 32 affordable dwellings. Accordingly, there would be a residual need for 83 affordable dwellings within the village. The identified need for Sawston would not be met without an additional allocation. The promoted development by NW Bio at the Mill Lane Site, Sawston would include housing and affordable housing to meet local needs of the village, and there would be a policy requirement to include a proportion of self/custom build housing plots.

For all these reasons, additional small scale housing allocations should be made in the more sustainable villages within the Rural Southern Cluster, including Sawston, because it is already accessible by existing sustainable modes of transport, it is well related to employment opportunities (especially knowledge based employment), there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village which would not be met via other means. The affordable housing needs for Sawston would not be met by the preferred allocation identified in emerging GCLP (carried forward from the South Cambridgeshire Local Plan 2018).

NW Bio’s representations to the assessment of the Mill Lane Site, Sawston in the HELAA (Site Ref. 40341) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed.

Requested Change

It is requested that the development strategy for the Rural Southern Cluster includes an additional residential allocation at the Mill Lane Site, Sawston, as promoted by NW Bio, with the following policy requirements:

• Site Area of 7.17 Ha
• Capacity for approx. 225 dwellings, including affordable housing and self/custom build plots
• Retain and enhance existing trees on the site
• Provide open space and green infrastructure

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Sawston falls within this category.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The promoted development at the Mill Lane Site, Sawston would support the existing services and facilities in the village, including convenience stores, post office, library, banks, public houses and restaurants and bus services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire. It is requested that small sized sites such as the Mill Lane Site, Sawston are allocated to meet the requirement for a mix of sites including those that are easily deliverable.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. The nearest bus stops are located on Cambridge Road within an acceptable walking distance of the site via the existing footways on Mill Lane and New Road, and provide access to Bus Services Citi 7 and 7A, and are likely to be used by future residents of the site to access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance of the site, and likely to be used by future residents of the site to access existing services and facilities in Cambridge and the wider area surrounding the site.
Sawston and the Mill Lane Site are sustainable locations in transport terms, and additional development in this location would be consistent with Paragraph 104.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 115 affordable dwellings in Sawston for those with a local connection to the village. The emerging GCLP contains one allocation for residential development in Sawston that it is proposed will be carried forward from the South Cambridgeshire Local Plan (2018) (S/RSC/H/1 (c): land south of Babraham Road, Sawston) for 80 dwellings. Assuming that this site comes forward and delivers a policy compliant level of affordable housing (40%), it can be assumed that this site would deliver 32 affordable dwellings. Accordingly, there would be a residual need for 83 affordable dwellings within the village. The identified need for Sawston would not be met without an additional allocation. The promoted development by NW Bio at the Mill Lane Site, Sawston would include housing and affordable housing to meet local needs of the village, and there would be a policy requirement to include a proportion of self/custom build housing plots.

For all these reasons, additional small scale housing allocations should be made in the more sustainable villages within the Rural Southern Cluster, including Sawston, because it is already accessible by existing sustainable modes of transport, it is well related to employment opportunities (especially knowledge based employment), there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the village which would not be met via other means. The affordable housing needs for Sawston would not be met by the preferred allocation identified in emerging GCLP (carried forward from the South Cambridgeshire Local Plan 2018).

NW Bio’s representations to the assessment of the Mill Lane Site, Sawston in the HELAA (Site Ref. 40341) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed.

Requested Change

It is requested that the development strategy for the Rural Southern Cluster includes an additional residential allocation at the Mill Lane Site, Sawston, as promoted by NW Bio, with the following policy requirements:

• Site Area of 7.17 Ha
• Capacity for approx. 225 dwellings, including affordable housing and self/custom build plots
• Retain and enhance existing trees on the site
• Provide open space and green infrastructure

COMMENT

Policy I/ST: Sustainable Transport and Connectivity set out how the transport impacts of development should be managed, and how new development should be connected to the transport network. An aim of the policy is to reduce transport emissions. The preferred development strategy seeks to co-locate housing close to jobs, services and facilities in order to reduce the need to travel and support travel by walking, cycling and public transport. This approach is consistent with Paragraphs 104 and 105 of the NPPF and is supported. However, it is considered of the aim of Policy I/ST will only be fully implemented if all available opportunities to direct development to sustainable locations are taken, including additional development being directed to Sawston.

Additionally, the Mill Lane Site is owned by Northwest Biotherapeutics (NW Bio), a biotechnology company developing novel immune therapies to treat cancer. NW Bio’s DCVax®-L immune therapy for Glioblastoma brain cancer is in the NIHR's Priority Portfolio, and was the first product to receive PIM designation as a Promising Innovative Medicine from the Medicines and Healthcare products Regulatory Agency (MRHA). NW Bio currently has offices in London and is developing an advanced manufacturing and technology development facility in Sawston, where they are working together with Advent BioServices to develop the Vision Centre on the former Spicers site. Advent is one of only a small number of companies in the world that specializes in technology/process development and advanced manufacturing for cell and tissue therapies for cancer and other diseases.

Since our previous submission, significant progress has been made in the physical development of the Vison Centre. Most importantly, it is expected within the next week or two that the Medicines and Healthcare products Regulatory Agency (MHRA) will be granting certification of Phase One of the production facility to ramp-up production to 45 self paying patients per month under their Specials/Compassionate Treatment Program. This milestone approval represents 7 months of testing and MHRA reviews and inspections involving all of the now 39 staff and growing. In turn, this major event for the entire area has been facilitated by the following developments at the plant itself over since our previous submission of representatives, including the following:

• Significant upgrade to two clean room suites to enable these to be Medicines and Healthcare product Regulatory Agency (MHRA) compliant
• Warehouse incorporating Goods in/quarantine and a temperature controlled store
• Two process development laboratories
• Quality control laboratory
• Freezer facility incorporating room for 60 x -80C freezers (currently 30 freezers in place)
• Construction of further office to support freezer facility
• State-of the-art Ultra cold Liquid Nitrogen facility with the capacity to store up to 3,000,000 samples at -196C for third party clients
• Installation of a nitrogen generator which removes and liquifies N2 from the atmosphere – removes the need for weekly deliveries of gas to site
• Cell therapy product goods in/out rooms
• Data management centre containing 3 towers loaded with processers and other essential IT equipment
• Installation of lift shafts and stairs to upper floor
• Fitting out of additional office space
• Creation of corridors for materials, staff and waste

The following infrastructure also has now been put in place to serve the Vision Centre:

• Installation of emergency generator, boiler, uninterrupted power supply, air handling units
• Installation of BT fibre network
• Installation of environmental monitoring equipment and software – monitors temperatures, pressures, air changes, humidity 24/7
• Installation and implementation of a quality management system and the writing of over 1000 regulatory documents
• Installation of electricity supply to futureproof the building and remove the VC from the larger site network
• Implementation of a laboratory information management system
• Development of website
• Awarded licences from the Human Tissue Authority for cell storage
• Underwent inspection from MHRA -awaiting licence to manufacture advanced therapy products for UK Specials programme and for clinical trials

The Vision Centre is located just across the A1301, a 5 or 10-minute walk from the proposed residential site on Mill Lane. The Vision Centre is an advanced manufacturing facility that will produce cell therapy products for the UK and for export to the European Union and other geographies. The development of the Vision Centre will involve the creation of up to 450 new high-value jobs across a wide range of skill levels in phases over the next few years.

Recruitment has also taken place since the submission of previous representations and the total number of employees at the Vision Centre is now 40. These include manufacturing scientists, QA and QC staff, facilities management, IT, clinical coordinator, administration, validation experts, HR and finance personnel. This also includes the recruitment of three apprentices as part of the national network ATAC scheme in cell and gene therapy, with a fourth apprentice to be taken on shortly.

Some of the staff that have been taken on to date are from the local area but other are from elsewhere in UK including London, Stevenage, Bedfordshire, Kent, Berkshire, and Suffolk. It is not possible for all staff to be recruited from the local area as a result of the need to recruit Qualified persons (for regulatory purposes).

A key factor which will affect the pace at which personnel can be hired for these jobs will be the availability of housing nearby to the Vision Centre. A proportion of Vision Centre employees will have to live close to the site because producing and managing living cell products requires unpredictable and varied hours (e.g., when tissues are received from hospitals for processing at any time of the day or evening). The jobs at the Vision Centre are and will continue to be for a range of employees, from school leavers through to PhD level. This will result in increased employment and learning opportunities within Sawston and South Cambridgeshire as a whole, which will have benefits for social inclusion.

The ability of other employees of the Vision Centre to live in close proximity to the site will also have clear benefits for their mental health and well-being, by avoiding the need for significant commuting and promoting opportunities for active forms of travel, such as walking and cycling. The residential development of the Mill Lane Site, Sawston would also provide additional housing that is much needed for nearby surrounding employment sites, including existing sites to the east and north of Sawston; Huawei’s emerging business and research campus at the former Spicers site; Granta Park; Cambridge Biomedical Campus; and the expanding Wellcome Genome Campus.

The Mill Lane Site is also in a location with extensive existing transport access by walking, cycling, bus and train and the Site has good accessibility (a 15 minute or so walk or a short cycle ride) to existing services and facilities within Sawston including nurseries, schools, doctors, dentists, pharmacy, opticians, sports centre, pubs, convenience stores, hairdressers and beauticians. Having all of these services and facilities within close proximity of the Site will allow future occupants to access these services using sustainable travel modes, thus reducing emissions associated with use of the private car, and will assist the development, and its occupants, in integrating into the wider Sawston community. New residents at this site, and the associated increased spending power of the village and potential employees, could also encourage the creation of new businesses with Sawston.

The nearest bus stops are located on Cambridge Road within an acceptable walking distance of the site via the existing footways on Mill Lane and New Road, and provide access to Bus Services Citi 7 and 7A, and are likely to be used by future residents of the site to access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance of the site, and likely to be used by future residents of the site to access existing services and facilities in Cambridge and the wider area surrounding the site.

The promoted development by NW Bio in Sawston is accessible by walking, cycling and public transport to the services and facilities within the village and to existing employment opportunities. The development of the Mill Lane Site would also be beneficial to the pace at which new employment opportunities generated by the Vision Centre can be brought forward. Therefore, additional development at Sawston would be consistent with the aims of Policy I/ST.

Requested Change

It is requested that the promoted development by NW Bio at the Mill Lane Site, Sawston is allocated for residential development, in order to support the aims of Policy I/ST e.g. reduce transport emissions, reduce the need to travel, and encourage the use of sustainable modes of transport.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by NW Bio that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to NW Bio’s representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

NW Bio’s representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in NW Bio’s representations to Policy S/DS, identified needs for affordable housing in the villages, including Sawston, would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all village. That information is not reflected in the assessment contained in Table 5.4. The identified need for 115 affordable dwellings in Sawston will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. NW Bio has requested that the Mill Lane Site, Sawston is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in NW Bio’s representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Sawston is an example where there are very limited opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings, and the Green Belt restricts development outside the settlement boundary. As set out above there is an identified need for 115 affordable dwellings in Sawston. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Sawston, will not be met by the currently defined settlement boundaries.

• Table 5.20: Policy S/RSC: Village Allocations in the Rural Southern Cluster: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect / uncertain’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 115 affordable dwellings in Sawston, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Sawston, will not be met by the development strategy or the strategy for rural southern cluster. Sawston contains a good range of services and facilities, including a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses and restaurants. Sawston is also served by Bus Services Citi 7 and 7A, providing access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance, providing access to existing services and facilities in Cambridge and the wider area. The accessibility to services and facilities is excellent for Sawston and for land the Mill Lane Site, but this is not reflected in the assessment for this sustainability related objective, and additional development in this location would improve the sustainability outcomes and support the existing services and facilities. It is requested that the Mill Lane Site, Sawston is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.