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.

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 are based on delivering the higher growth level option.

OBJECT

Hill Residential do not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018. In Fulbourn, heritage assets, protected village amenity areas, local green space and important countryside frontage designations restrict development opportunities within the settlement boundary, and the Green Belt restricts development outside the settlement boundary. The proposed development at the Ida Darwin Hospital site was a longstanding allocation, the proposed development off Teversham Road was approved at a time when the Council could not demonstrate a five year housing land supply, and the proposed development to the west of Balsham Road was a rural housing exception scheme; as set out in the representations to Section 2.6/Policy S/RRA affordable housing needs have and will remain despite these developments. It is very likely that all other development opportunities that did exist within Fulbourn have been taken up by now, and any that do remain (other than the outstanding proposed developments) would be for one or two dwellings only that are not required to provide affordable housing.

The Councils have not undertaken an assessment of the capacity of land within the existing settlement boundaries of villages to accommodate additional development. It is likely that such an assessment would demonstrate that the capacity is limited.

It is considered that the emerging GCLP should seek to allocate suitable sites on the edge of existing sustainable villages and to adjust the settlement boundary to accommodate those allocations. The site promoted by Hill Residential at land east of Balsham Road in Fulbourn is suitable and available for housing, and should be allocated for development.

Requested Change

It is requested that a capacity assessment is undertaken of all villages in South Cambridgeshire to determine which potential housing sites might be deliverable or developable during the plan period to 2041 and the number of dwellings that might be delivered from each of those sites.

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs it is requested that additional allocations are made on the edge of those villages to deliver sufficient housing to meet those affordable housing needs.

Section 2.6: Rest of Rural Area

OBJECT

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. Fulbourn 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 land east of Balsham Road in Fulbourn would support the existing services and facilities in the village, including the supermarket and other small convenience stores, the library, and post office, and existing and future 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 land east of Balsham Road in Fulbourn is 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. There are regular bus services to Cambridge, Haverhill and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The Greater Cambridge Partnership has proposed a greenway (walking and cycling route) between Fulbourn and Cambridge. The Greater Cambridge Partnership’s Making Connections project seeks to improve the frequency of bus services from Fulbourn, including to Cambridge, Cambridge Station, Cambridge Biomedical Campus and the proposed Cambridge South Station. Fulbourn is a sustainable location 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 65 affordable dwellings in Fulbourn for those with a local connection to the village. This identified need would not be met without allocations in the village.

There are three current and recent major housing developments in Fulbourn, as follows:

• App Ref. S/3396/17/FL: A rural exception housing scheme off Balsham Road for 14 affordable dwellings. The s106 Agreement includes a planning obligation requiring the affordable housing to be occupied by those that can demonstrate a local connection to Fulbourn. The development is complete.
• App Ref. S/0202/17/OL: An application for 110 dwellings off Teversham Road, with 30% affordable housing which equates to 33 affordable dwellings. The s106 Agreement includes an affordable housing obligation requiring the first 8 affordable dwellings only to be offered to those that can demonstrate a local connection, with the remainder of the affordable housing available for district-wide housing needs. Reserved Matters Application S/3290/19/RM was refused in October 2021. This application can be appealed, however development may not come forward on this site.
• S/0670/17/OL: An application for 203 dwellings at the former Ida Darwin Hospital site, with 40% affordable housing which equates to 81 dwellings. The s106 Agreement does not include any obligations specifying that affordable housing must be offered to those with a local connection, and therefore the affordable housing is available for district-wide needs.
Therefore, all of the completed Balsham Road development was available to meet local housing needs, a small proportion of the Teversham Road development will be available for local housing (if a future appeal is submitted and subsequently allowed) needs, and none of the Ida Darwin Hospital development will be specifically allocated to meet local housing needs. It is acknowledged that those with a local connection to Fulbourn might apply for an affordable dwelling at the Teversham Road and Ida Darwin Hospital developments, but it is likely that the majority of affordable dwellings provided at these developments will be allocated to meet district-wide housing needs. Therefore, despite the existence of recent and current housing developments in Fulbourn it is very likely that the identified affordable housing needs of the village for those with a local connection will remain unmet during the plan period. In addition, as one of the more sustainable villages in South Cambridgeshire, Fulbourn should be meeting district-wide affordable housing needs and not just those needs generated in the village.

The promoted development by Hill Residential at land east of Balsham Road in Fulbourn would include housing and affordable housing to meet local needs of the village.

For all these reasons, additional small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Fulbourn, because it is accessible by sustainable modes of transport, it is well related to employment opportunities, 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 villages which would only be partially met by other developments.

Hill Residential’s representations to the assessment of the land east of Balsham Road in Fulbourn site in the HELAA (Site Ref. 40271) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed. In summary, it is noted that the site assessment identifies no ‘red’ scores for the site against suitability criteria, which indicates that the site is suitable subject to the implementation of mitigation measures. It is acknowledged in the assessment that development at the sites would make a negligible impact on landscape character. The existing trees and hedgerows at the site boundary would be retained as part of the promoted developments. It is considered that the site makes limited contribution to the purposes for including land within the Green Belt.

Requested Change

It is requested that the development strategy for the rest of the rural area includes an additional residential allocation at land east of Balsham Road in Fulbourn, with the following policy requirements:

• Site Area of 1.10 Ha
• Capacity for approx. 40 dwellings, including affordable housing
• Retain protected and other trees at site boundary
• Provide green infrastructure
• Facilitate an extension to the existing recreation ground

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 Hill Residential 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 Hill Residential representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

Hill Residential 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 Hill Residential’s representations to Policy S/DS for land east of Balsham Road in Fulbourn, there are no new housing allocations made in most villages, and the existing and recent major developments in Fulbourn would only partially meet identified affordable housing needs but unmet needs would remain. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 65 affordable dwellings in Fulbourn will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Hill Residential has requested that land east of Balsham Road in Fulbourn 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 Hill Residential’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. Fulbourn is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 65 affordable dwellings in Fulbourn. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fulbourn, will only be partially met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: 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’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 68 affordable dwellings in Fulbourn, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fulbourn, will not be met by the development strategy or the strategy for rural areas. Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. It contains a good range of services and facilities, including a primary school, doctor’s surgery, pharmacy, library, post office, supermarket and other small convenience stores, village hall, and outdoor recreation and play facilities. There are regular bus services to Cambridge, Haverhill and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The walking and cycling routes and bus services in Fulbourn are due to be improved in the future by Greater Cambridge Partnership projects. The accessibility to services and facilities is very good for Fulbourn, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land east of Balsham Road in Fulbourn is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

OBJECT

Hill Residential is promoting land east of Balsham Road in Fulbourn 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 rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Fulbourn and the decision to not release additional land from the Green Belt.

The overall development strategy is overly reliant on the delivery of extensions to an existing new settlement (Cambourne West + 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 is 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. There can be no certainty at all regarding East West Rail which is many years away and the abandonment of the East-West expressway and parts of HS2 must cast serious doubts over the prospect of it being funded.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict 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 Bourne 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, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach or at both at the same time. 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 is allocated in both Local Plans as a strategic site. It is acknowledged that this site involves 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. It is considered that the delivery of development at the site 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 realistic assumptions about delivery are applied for North East Cambridge.

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 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 is 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 and North East Cambridge the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The promoted development by Hill Residential at land east of Balsham Road in Fulbourn is located within the Green Belt, and 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 not just the Rural Southern Cluster as indicated in emerging GCLP. There are other villages in the Green Belt that are also well related to employment and are accessible by sustainable modes of transport, and the identified exceptional circumstances apply to these villages too. For example, Fulbourn is very well related to the employment opportunities within and on the edge of Cambridge including Peterhouse Technology Park and Capital Park and to the Southern cluster. In addition, it contains a very good range of services and facilities and is accessible by sustainable modes of transport, and there is an identified need for affordable housing which is not being addressed through the emerging neighbourhood plan or by the emerging GCLP.

Paragraph 141 of the NPPF 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. Fulbourn is well served by public transport and is well connected with existing cycle routes, and there are plans to improve the walking and cycling connections to Cambridge. Therefore, the release of suitable land from the Green Belt on the edge of Fulbourn would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport. As set out above, exceptional circumstances to release land from the Green Belt applies to other locations on the edge of Cambridge, and not just the Rural Southern Cluster. All of the larger villages on the edge of Cambridge are well related to employment and are accessible by non-car modes of transport, and are sustainable locations for additional development. It is requested that land on the edge of Fulbourn, including land east of Balsham Road promoted by Hill Residential, should be released from the Green Belt on the grounds that it is a sustainable location for development.

As set out in representations to Section 2.6: Rest of Rural Area and the HELAA Site Assessments (for Site Ref. 40271), the land east of Balsham Road in Fulbourn makes a limited contribution to openness and the purposes for including land within the Green Belt and should be released from the Green Belt in emerging GCLP.

The preferred development strategy for the rural area on the edge of Cambridge is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for Fulbourn, which is a sustainable village, hence its designation as a Minor Rural Centre.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. 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.

Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. It contains a good range of services and facilities, including a primary school, doctor’s surgery, pharmacy, library, post office, supermarket and other small convenience stores, village hall, and outdoor recreation and play facilities. The promoted development at land east of Balsham Road in Fulbourn would support the existing services and facilities within the village. There are regular bus services to Cambridge, Haverhill and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The Greater Cambridge Partnership has proposed a greenway (walking and cycling route) between Fulbourn and Cambridge. The Greater Cambridge Partnership’s Making Connections project seeks to improve the frequency of bus services from Fulbourn, including to Cambridge, Cambridge Station, Cambridge Biomedical Campus and the proposed Cambridge South Station. Therefore, there are numerous options for residents of Fulbourn to travel by sustainable modes of transport for most journeys to access employment, education and leisure.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 65 affordable dwellings in Fulbourn for those with a local connection to the village, and affordable housing needs in the neighbouring villages of Teversham (21 dwellings) and Great Wilbraham/Little Wilbraham (6 dwellings) – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without additional allocations in Fulbourn. It is noted that the emerging Fulbourn Neighbourhood Plan makes no new housing allocations despite the need for affordable housing being identified as an issue for the local community. There is no community land trust in Fulbourn. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Hill Residential at land east of Balsham Road in Fulbourn 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 area on the edge of Cambridge including at Fulbourn, 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 only partially be met by other developments.

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.

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.

It is requested that small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including Fulbourn, 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 Hill Residential’s representations to Section 2.6: Rest of Rural Area, the land east of Balsham Road in Fulbourn should be released from the Green Belt and allocated in emerging GCLP for residential development.