Greater Cambridge Local Plan Preferred Options

Hallam Land Management (HLM) support the Vision and aims set out in the First Proposals.

Hallam Land Management (HLM) have made comments in respect of the amount of development and its location in response to Policy S/JH and Policy S/DS respectively.

Hallam Land Management (HLM) consider the First Proposals do not plan for an appropriate quantum of new jobs and homes having regard to the available evidence.

A Review of Employment Needs Evidence has been undertaken and is submitted with these representations. The Plan should be planning for a minimum of 78,700 jobs and 56,900 new homes to 2041 (the higher growth scenario) for the reasons set out within the Review and summarised below.

In terms of the job growth target and employment floorspace requirement, the following comments are made:

1. In projecting past trends, the floorspace requirement will constrain jobs growth to levels below what has been forecast, particularly the level forecast by the Cambridge & Peterborough Independent Economic Review (2018) (CPIER);
2. The floorspace requirements do not take into account reductions in floorspace over the Plan period as older or lower quality employment land and buildings are redeveloped for alternative uses;
3. The implications of the growth in logistics arising from changes in the economy, including growth in online retailing, should be considered in light of the findings of the update to the Retail and Leisure Study; and,
4. The implications of the growth in Data Centres on the demand for employment floorspace over the Plan period should be considered.

In terms of the supply to meet the employment floorspace requirement, it is noted that a substantial proportion of the identified supply is not available until post 2041. It cannot therefore contribute to meeting the requirement and the jobs target. Additional supply is therefore required, in the form of new allocations.

In terms of the new homes target, HLM do not support the use of the ‘central scenario’ in planning for future population and housing growth. This level of housing growth in particular will constrain employment growth, and either limit Greater Cambridgeshire’s ability to achieve the ‘higher growth scenario’, or as a consequence place greater pressure on the local housing market, worsening affordability.

There is support for the higher growth scenario within the Council’s Employment Land Review (November 2020), and CPIER led by Kate Barker.

It is noted the Councils reject this level of growth on the basis they consider it is not the most likely future scenario. However, it is requested the Councils reconsider this matter in light of submissions made to this consultation, and look to plan to meet this higher growth requirement to ensure that economic growth is not out of kilter with the planned level of new homes.

In relation to the supply to meet the housing requirement, the Councils should be realistic as to the level of growth it considers can be delivered by 2041 on sites. Paragraph 73 criteria d) of the Framework requires the Councils to make a realistic assessment of likely rates of delivery, given the lead-in times for large sites.

This paragraph is particularly relevant to proposed allocations at North East Cambridge, Cambridge Airport, North West Cambridge, and Cambridge East where cumulatively 10,650 homes are planned to be delivered by 2041. This is in addition to existing commitments and assumptions related to windfalls in the City.

The rate of growth is ambitious, and the Councils will need to review its evidence on the issue of delivery prior to the submission of its Plan for Examination to ensure its assumptions are sound, and that the quantum of development is deliverable.

Similar comments are also made in relation to the changed assumptions around delivery rates at Northstowe and Waterbeach New Town which have not been evidenced (see representations made to Policy S/NS).

If the rate of delivery cannot be justified, the Councils should consider making further allocations to address any shortfall in meeting the housing requirement.

It is in this context that HLM consider the Plan should include a new settlement at Scotland Farm. This should either be in addition to the selected locations in order to bolster supply to meet the higher jobs and homes requirement, or as an alternative to those locations selected that are not taken forward in the Plan.

Hallam Land Management (HLM) request the Development strategy be amended in the following two respects.

Firstly, as a general point, whilst the proposed development strategy outlined under ‘Proposed policy direction’ is for the most part supported, it is generic and lacks any spatial interpretation.

It is acknowledged that the strategy goes on to identify areas of growth, and then specific locations. However, there isn’t an overarching spatial strategy that explains the rationale behind the distribution of future development, and why the areas and locations identified will help achieve the Vision and Aims.

There is significant planned investment in sustainable transport infrastructure to the west of Cambridge (Cambourne to Cambridge Better Public Transport Project (C2C) and East West Rail). This should be referenced in the strategy, with recognition that this investment should be shaping the future growth of the area in terms of homes and jobs to 2050.

Further, the strategy should be setting out how this investment will be used to benefit and connect with the wider Greater Cambridge area. The strategy appears on the Map at present as a number of distinct locations separate from each other with no inter-connectivity. Indeed, feedback from the public to earlier consultations highlighted the disconnect between the new settlements and major employment sites to the south.

The strategy should be setting out how these growth areas will be connected to each other, particularly the new towns of Northstowe, Waterbeach new town, Cambourne, and the rural southern cluster, and how these areas will connect with East West Rail and C2C. This is illustrated within the Emerging Vision submitted in support of the new settlement promoted by HLM at Scotland Farm (HELAA Site Reference 56252).

It is requested therefore the Councils consider adding a more specific spatial strategy that explains how Greater Cambridge will grow in the future, and why, and how its existing growth areas will benefit from the substantial investment of East West Rail and C2C

The second point made in respect of the strategy is that HLM consider the locations identified for accommodating growth should be amended to include a new settlement at Scotland Farm (HELAA Site Reference 56252).

Paragraph 11a of the Framework defines what sustainable development means in terms of plan-making, much of which is reflected in the proposed strategy.

One aspect of paragraph 11a that is particularly important is aligning growth and infrastructure. It is clearly vital to make the best use of public investment in infrastructure (existing and new), as well as using new development to support longer term viability. Moreover, utilising existing or planned infrastructure can reduce the financial burden on new development and improve its viability and speed of delivery. In the context of ever increasing pressure on public finances and the need to maximise benefits from development, these are important considerations.

The proposed strategy does recognise this where it states ‘the proposed strategy … responds to opportunities created by proposed major new infrastructure.’

However, the locations for growth identified do not reflect the opportunity created by C2C, and in particular the Scotland Farm Travel Hub.

C2C is a key part of the Greater Cambridge Partnership’s sustainable transport programme. Whilst this is responding in part to existing planned growth, it must also shape future growth given the level of investment.

Scotland Farm Travel Hub is a key element of the C2C route. Work is already underway in preparing the planning application, and the site is expected to be operational by 2024. It will transform the accessibility of this area in terms of its connectivity by sustainable modes of travel with a service every 10 minutes to Cambridge City Centre and Cambourne, and every 15 minutes to Cambridge Biomedical Campus. With a direct service to the City Centre and a likely journey time of less than 20 minutes, it will become one of the most accessible locations in Greater Cambridge outside of the urban area.

Further, there is the potential as illustrated above for this development to support connections between the Travel Hub with Northstowe and Waterbeach beyond by active and sustainable modes.

It is entirely appropriate therefore to align that investment in public transport infrastructure with new development. To do otherwise, would not be consistent with national policy and thereby not sound.

Through careful masterplanning as illustrated within the Emerging Vision submitted with these representations, active travel and public transport would be the natural choice for residents and workers within the new settlement.

It is in this context that HLM consider the proposed strategy should be amended to include a new settlement at Scotland Farm. This should either be in addition to the selected locations in order to bolster supply to meet the housing and employment requirement, or as an alternative to those selected that are not taken forward in the Plan.

Further information in support of the allocation of land at Scotland Farm (HELAA Ref: 56252) and in response to the assessment in the HELAA is provided under New Settlements – General Comments.

Hallam Land Management (HLM) support limiting growth in the rural centres and villages to meeting local needs. To do otherwise, would not achieve a more sustainable pattern of development.

Hallam Land Management (HLM) are promoting land at Scotland Farm (HELAA Ref: 56252) for a new settlement. As experienced land promoters, and with all of the land being under one ownership, the Councils can be confident the site can be delivered.

This is the first submission they have made to the Councils as the land had previously been put forward solely by the landowner through the ‘call for sites’.

HLM have undertaken a considerable amount of technical work to inform understanding of the potential of the site, its effects and how they might be mitigated, and its benefits. This work is submitted through the call for sites submission of additional information (ref ZWFMGZFM) and summarised below with reference to the HELAA assessment.

The land available amounts to circa 400ha. There is flexibility as to the quantum of development that can be delivered. An Emerging Vision is submitted with the representations that includes a masterplan (also submitted separately) that illustrates how circa 6,000 homes and 60,000 square metres of employment floorspace could be delivered alongside schools, district and local centres, travel hub, and substantial areas of green infrastructure.

One of the advantages of this site is that it is a suitable and attractive location for homes and jobs given its planned accessibility on the C2C route. The balance between homes and jobs is therefore variable, and an alternative masterplan with Expanded Employment Area (also submitted separately) is shown within the Emerging Vision which would provide a larger employment area alongside the A428 and Travel Hub. This could yield an increase to 265,000 square metres of employment floorspace with a reduction to circa 5,000 homes. Both alternatives are deliverable, and the final balance and mix would need to be informed by the needs and requirements of the Plan. The key point is that there is flexibility.

The majority of the land is outside of the Green Belt, but part of the site falls within the Green Belt as it straddles the outer edge of the designation. Again, there is flexibility as to whether the land is necessary to be removed from the Green Belt at this stage depending on the scale of growth required to meet the Plan requirement and whether exceptional circumstances exist at this stage. Its exclusion from the new settlement would only reduce the quantum of residential development capable of being accommodated from circa 6,000 homes to 5,000 homes (as shown on the submitted illustrative masterplan excluding Green Belt land).

In relation to the HELAA, and the suitability of the site, the following comments are made:

Flood Risk
The HELAA scores this as ‘amber’ due to the presence of small areas of flood zone 2 and 3. However, the vast majority of the site is flood zone 1 and having a very low risk of surface water flooding. A Preliminary Flood Risk Assessment is submitted through the call for sites to illustrate conceptually how drainage would be addressed to avoid flood risk in surrounding areas through the use of Sustainable Drainage Systems consistent with national policy. This work has informed a Masterplan within the Emerging Vision and the assessment of the capacity of the site.

Landscape and Townscape
The HELAA scores this as ‘red’ with a significant negative impact which cannot be mitigated, and this was the only reason for the site to be found ‘not suitable’. HLM strongly disagree with this conclusion for the following reasons.

It is noted that the HELAA commented that ‘it (Scotland Farm) would appear as an extension to the village of Dry Drayton and have a significant adverse impact on the settlement and landscape character’.

The red line boundary of the site merely illustrates the land available for development, but there would be no need for all of the land to be developed such that it might be considered an extension to the village. It is entirely appropriate for there to be a suitable buffer between the existing village and proposed new development in order to retain their separate identity and character.

The scale and location of that buffer needs to be informed by detailed landscape and visual assessment. A Landscape and Visual Appraisal has been submitted through the call for sites which considers the relationship and has informed the indicative buffer shown on the Masterplan within the Emerging Vision Document. This is proposed for discussion, and clearly is illustrative at this stage and not fixed.

The buffer can still form part of the allocation, but be designated within the policy to remain open. Further, it may be appropriate to consider whether the land between the existing village and new development to the west of Scotland Road should be designated as new Green Belt. A Green Belt Appraisal has been submitted through the call for sites which illustrates how this might be proposed in part as compensation for any loss of Green Belt arising from the proposals.

Therefore, in respect of impact on the existing village, any harm could reasonably be mitigated through the inclusion of a suitable buffer.

The Landscape and Visual Appraisal submitted also considers the impact of development on the landscape character of the area. This has been informed by site visits and with reference to published evidence.

The land sits between two ridgelines to the west and east, with the A428 forming a strong visual barrier to the south, and to a lesser extent Dry Drayton village to the north. Its effect on the wider landscape is therefore contained to an extent. Although there is an inevitable change in character, the few features of the landscape present would be retained and supplemented by new planting.

The harm is therefore not considered significant, and does not warrant the land being assessed as not suitable for development.

Biodiversity & Geodiversity
The HELAA scores this site as ‘green’ and no conflict with policy. An Ecology Representations Report is submitted through the call for sites to support this conclusion, including a version with confidential badger records.

Historic Environment & Archaeology
The HELAA scores this site as ‘amber’ due to the presence of a listed asset within 100m, with reference to the listed church within Dry Drayton, and evidence of archaeology in the area. An Historic Environment Desk Based Assessment has been undertaken and submitted through the call for sites. It concludes that the site does not fall within the setting of nearby designated assets, and use of landscaping and open space can further mitigate any potential for harm. The potential for archaeological remains exists, although these are considered likely to be of local or regional significance.

Accessibility to Services
The HELAA scores the site as ‘amber’ due to distances to services. However, the land available is of sufficient scale to deliver jobs (between 1,500 and 4,000 jobs depending on the scale of employment required), schools (secondary and primary), district and local centres, sports facilities, and park and ride, all accessible by active travel within the development as illustrated within the Emerging Vision.

Site Access, Transport and Roads
The HELAA scores the site as ‘amber’, with access being found to be acceptable in principle, and impacts on the trunk roads being capable of being mitigated. A Transport Appraisal has been undertaken and submitted through the call for sites. The Appraisal highlights the significance of C2C to changing the accessibility of the site, the potential for active travel linkages with Bourn Airfield, Cambourne, and Bar Hill, and demonstrates the suitability of access arrangements and the highway junction on the A428.

It is important to note that the site is served by existing and planned transport infrastructure. There is no requirement for significant upfront infrastructure that might delay delivery or affect viability.

Noise and Air Quality
The HELAA scores the site as ‘amber’ with reference to effects of noise from the A428 and potential for traffic to impact the AQMA.

A Preliminary Noise and Air Quality Assessment has been undertaken and is submitted through the call for sites. This identifies that the impact of noise from the A428 can be mitigated, particularly through the location of employment buildings along the boundary with the A428 which would act as a noise screen. The impact on proposed residential areas to the north would be avoided.

In respect of air quality, the site is not exposed to poor air quality. The effects of traffic generated by development on the AQMA’s within Greater Cambridge would also be mitigated by the inclusion of the Scotland Farm Travel Hub on the proposed C2C route.

Green Belt
As noted above, only part of the site falls within the Green Belt, and a new settlement could come forward excluding the Green Belt land.

The HELAA notes the Green Belt Assessment scores the harm of part of the site within the Green Belt as ‘very high’ or ‘high’. A Green Belt Appraisal has been undertaken and is submitted through the call for sites. As the land falls on the outer edge of the Green Belt, the Appraisal finds it contributes little to the factors which define the special character of Cambridge and its setting. Further, there is ample scope for compensatory improvements to a small adjustment to the Green Belt boundary, including potential for new Green Belt to protect the separate identity of Dry Drayton.

The HELAA therefore only finds the land at Scotland Farm not suitable with reference to its potential impacts on Dry Drayton and the landscape. HLM would request this assessment be revisited in light of the evidence now available and submitted through the call for sites.

The allocation of this land as a new settlement would be entirely consistent with the proposed development strategy as explained below:

1. Active and public transport will be the natural choice given the development will be in one of the most accessible locations outside of the urban area.

2. The land available is of sufficient scale to deliver substantial areas of green infrastructure (circa 120ha), plus a Country Park (circa 40ha), as illustrated within the Emerging Vision. This can make an important contribution to the adjacent West Cambridge GI buffer – Coton Corridor, extending it through the land to the north towards Bar Hill.

3. The land available is also of sufficient scale to deliver jobs (between 1,500 and 4,000 jobs depending on the scale of employment delivered), schools (secondary and primary), district and local centres, sports facilities, and travel hub.

4. Its location means it can be served by utilities in a sustainable way. A Preliminary Utilities Assessment has been undertaken and is submitted through the call for sites. This identifies that necessary services can be provided to serve development in this location.

5. The distinctive character of Hardwick and Dry Drayton can be retained through careful masterplanning, and ensuring an appropriate buffer is provided.

6. Development can ‘double nature’ and deliver more than a 20% net gain in biodiversity as illustrated within the Preliminary BIA Result within the Ecology Representations Report submitted through the call for sites.

7. The Emerging Vision and the masterplan within illustrates how the density, form, and pattern of development would be used to create a well-designed and characterful place.

Its allocation would also be entirely consistent with national planning policy, particularly paragraphs 11a, 73, and 104. Aligning new homes and jobs with C2C and the Scotland Farm Travel Hub, in an accessible location close to East West Rail and where the environment can be enhanced is entirely consistent with Government policy.

HLM therefore request the Plan include a new settlement at Scotland Farm. This should either be in addition to the selected locations in order to bolster supply to meet the housing and employment requirement, or as an alternative to those selected that are not carried forward into the Plan.

HLM recognise that the scale of growth possible at Scotland Farm could contribute to meeting needs up to, and beyond, 2041. There is therefore flexibility as to how much development might come forward within the Plan period to 2041 both in terms of homes and jobs to meet any residual requirements, and/or provide flexibility.

Although the land is put forward as a whole, HLM have also made separate representations in respect of the proposed employment and Travel Hub under J/NE and Infrastructure – general comments respectively.

Finally, HLM request an opportunity to present the option at Scotland Farm to Officers and Members of the Councils at an appropriate time prior to the next stage of the Plan process.

HLM request that the broad location identified for longer term strategic scale growth not be limited at this stage to an expansion of Cambourne, but be expanded to include other locations accessible to the East West Rail Station and the C2C public transport hub at Scotland Farm. The Councils should give themselves greater flexibility and options for how it delivers growth within this corridor for the following reasons.

There are a number of unknowns at this stage which will impact on the options available, such as the location of the Station and its relationship to Cambourne (existing and committed), and how East West Rail and C2C will be integrated and what implications that may have for improved connectivity with surrounding settlements and other options for growth.

Although proximity and journey time to the new Station is an important consideration in deciding where growth should be located, it is not the only consideration. Other factors and policies will need to be taken into consideration and weighed in the balance before selecting the most appropriate location.

The consultation acknowledges that large scale development at Cambourne would have landscape impacts that would be hard to address. These impacts will need to be weighed against the impacts of other alternative options. Further, mitigating impacts will have implications for the capacity of options around Cambourne, and this may have knock-on consequences for viability and delivery.

There are a wide range of factors to consider as set out in the consultation document. In the context therefore of a future plan review, and looking to plan for needs to 2050 or beyond which are yet to be defined, the Councils should not unnecessarily at this stage limit those options to sites solely around Cambourne.

Other options, such as Scotland Farm (HELAA Ref: 56252), are suitable and appropriate to play a role in the strategy for future growth of this corridor. It should not therefore be excluded from doing so at this early stage of the process.

Hallam Land Management (HLM) query whether the evidence is sufficiently robust to support an increase in the number of homes delivered at Northstowe and Waterbeach New Town to 2041. In the absence of seeing the evidence to justify completion rates averaging 300 dwellings per annum, it is not possible to comment further.

Hallam Land Management (HLM) support the Councils aims in respect of climate change.

Hallam Land Management (HLM) support the Councils aims in respect of biodiversity and green spaces.