Greater Cambridge Local Plan Preferred Options

We support the Plan’s broad vision for the future of Greater Cambridge, ensuring sustainable development. We support the seven aims for the Plan, namely: climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes and infrastructure.

We note the following statement in the consultation document (page 22):
“Greater Cambridge has a strong and nationally important economy. Over recent years, jobs have been created faster than new homes have been built, and this has contributed to higher house prices and increased commuting into the area.”

This summarises our key concerns, namely:
• Cambridge City and the surrounding area are unique, and of national and international significance.
• The Planning vision for Greater Cambridge must embrace the growth potential that the area possesses, and plan for that growth to the greater benefit of the local economy and UK PLC, whilst ensuring that economic growth is harnessed in a sustainable way for the good of all.
• The life science, biomedical and tech-based sectors are particularly fast-paced and market trends and demands over the next two decades will evolve and cannot be entirely foreseen. As a result, adequate flexibility is needed within the Local Plan; this needs to be factored into both the growth projections (jobs and housing numbers) and the spatial strategy.
• As referenced in the above quotation, a past failure to deliver a sufficient supply of new housing alongside economic/jobs growth has resulted in problems including lack of affordability and increased commuting distances, with associated issues such as traffic congestion, environmental concerns and social/community fragmentation. The new Local Plan must not allow these past mistakes to be repeated, as the impact will be negative in terms of economic, social and environmental effects.

We have three broad comments:
• The Plan should embrace the maximum economic benefits that can sustainably be accommodated within the Greater Cambridge area. Life sciences, biomedical and technology sectors are key areas to the UK economy, asserted heightened importance as a result of the Pandemic. These sectors rely on knowledge clusters and Cambridge is alongside Oxford as one of two UK locations able to offer such a cluster that is sufficiently attractive to compete with major global economies such as Silicon Valley in California. Its importance to UK growth is essential and the Plan needs to accommodate the needs of these sectors – and ensure that the supporting infrastructure (including a wide choice of new homes) is available for existing and new employees.
• The Plan is proposing too few homes to support the ambitious and aspirational economic growth of Greater Cambridge.
• The spatial strategy is placing an over-reliance on a limited number of strategic sites within the City and depends upon the intensification of existing strategic sites to deliver additional homes. A broader development strategy is required to ensure a more flexible and responsive approach. There is a danger that if development on the strategic sites stalls or delivery timescales slip, then housing completions will be negatively impacted, potentially leading to unplanned speculative development.

It is proposed in the consultation that the new Local Plan should meet the following objectively assessed needs for development in the period 2020-2041:
• 58,500 jobs; and
• 44,400 homes (2,111 homes per year).
The consultation document explains that the Councils have chosen to plan for the ‘medium’ or ‘central’ growth levels from the strategic options set out in 2020 and within the Employment Land and Economic Development Evidence Study (November 2020). However, we would note that this Study (paragraph 5.22) itself recommends a preferred range “between a central and higher growth scenario”, rather than just the central growth scenario. Further, the Economic Development Evidence Study should be updated to reflect the response to the Pandemic – which in the case of life science, biomedical and technology has been directed affected since the Study was prepared – to ensure the needs of these sectors are met.

The Cambridgeshire and Peterborough Independent Economic Review (CPIER, 2018) reported (page 9) that:
“Growth in employment has not been matched by corresponding house-building, or developments in infrastructure. Consequently, house prices have soared and journey times have increased as congestion has intensified. This has meant that many have been forced to endure unpleasant commutes, or been priced away from the city altogether due to the unaffordability of rents. This is bad for both people and business, and we believe is an unsustainable approach to growth.”

The Greater Cambridge Local Plan provides a key opportunity to redress the balance between economic growth and housing delivery, to ensure that growth is sustainable and achieves the stated objectives.

We are strongly of the view that a higher objectively assessed need (OAN) figure should be used for the Greater Cambridge area during the plan period 2020-2041 than is currently proposed through the First Proposals, and should reflect at the very least a medium-high economic scenario as recommended, accounting for an updated assessment of need for the reasons set out above.

The consultation document acknowledges the findings of the Greater Cambridge Housing and Employment Relationships Report (November 2020), namely that planning for the ‘standard method’ housing figure would not support the number of jobs expected to arise and that a higher OAN should therefore be chosen. However, we are concerned that planning for the “most likely level of new jobs” (page 25, First Proposals consultation document) and adopting the ‘medium +’ OAN figure does not include adequate contingency for a higher growth scenario – particularly if updated evidence in the light of the Pandemic were to suggest greater need for economic development than currently reported. A key risk is that by not planning for growth, the Local Plan will inhibit growth.

We are of the view that by adopting a higher OAN, informed by up-to-date economic needs for both jobs and homes, the Local Plan would allow for proactive and purposeful forward planning, facilitating and enabling the aspirational growth targets that could potentially be achieved.

We would highlight paragraph 81 of the NPPF in full:
“Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.”

We consider it to be essential that the vision for the future of the Greater Cambridge area embraces and harnesses the growth potential that it possesses. In land use planning terms, there is a fundamental need to plan for growth and to ensure that sites are allocated to support the development that is integrally linked to this growth.

We would note the conclusions of the Greater Cambridge Local Plan Strategic Spatial Options Assessment Sustainability Appraisal (November 2020) in relation to the growth scenarios (paragraph 4.4):
“…the maximum growth scenario tends to have more significant positive effects, particularly within the plan period, as larger individual developments are likely to be built within the plan period under this option. These have greater scope for providing new services and facilities and being designed in a way that encourages healthy lifestyles. In addition, a higher level of development may be able to provide the critical mass for provision of substantial new infrastructure and environmental enhancements, such as new green infrastructure and provide a greater diversity of homes and jobs.”

In a similar vein, we would also highlight the importance of supporting the delivery of affordable housing. A significant amount of affordable housing is provided alongside market housing in new residential developments. This provides an essential supply to assist in meeting local needs. However, as noted in the NPPF, a range of housing is required to offer choice, rather than an over-reliance on a certain type of housing in certain areas, in order to ensure that mixed and sustainable communities are created and maintained. This approach should include a range of medium and large sites within existing settlements such as villages. Whilst the strategy of focusing growth on new settlements will provide for emerging affordable housing needs, it will not necessarily address the existing local housing needs within the rural areas and villages, nor would it offer sufficient choice. People with local connections are often unable to afford market prices (either sale or rent) and have to move away from their local area and support network. The need to provide for a range of housing needs should be carefully considered in respect of both the OAN and the related spatial strategy.

Our promoted Site at ‘land east of Cambridge Road, Hardwick’ (Site No. 40414) provides the opportunity to deliver a mix of market and affordable housing within a sustainable extension to the existing village. The Site occupies a sustainable location adjacent to the functional village centre, and its development would deliver a range of benefits to the existing settlement and local population.

The NECAAP Area is expected to deliver a total of up to 8,350 dwellings, including around 4,000 during the Local Plan Period to 2041.

This is a strategic-scale residential allocation which is focused on a relatively small and highly constrained development site. High densities and high building heights would be required to enable the capacities that are envisaged, and we are of the view that the stated numbers will not be deliverable, particularly within the timescales that are envisaged. The relocation of the existing sewage works and associated site remediation works, which are subject of a Development Consent Order (DCO)(unlikely to be determined until 2023 at the earliest), are just one of a number of factors which could negatively impact on timescales and reduce the delivery of housing completions within the plan period.

We consider that the Councils should review both the overall quantum of residential development to be allocated to the NECAAP Area, and the ability of the site to deliver within the Local Plan Period to 2041. This should take into account the likely lead-in times of recent strategic-scale developments in the Greater Cambridge area (e.g. Waterbeach) and both local and national housebuilding rates, to inform what the site can realistically deliver within the period to 2041. The site’s contribution to the housing trajectory should be revised downwards, accordingly.

The consultation proposes the identification of Cambourne as “a broad location for future growth in the 2030’s to respond to the opportunity that will be provided by the proposed East West Rail that includes a station at Cambourne” (page 99). It is proposed that 1,950 dwellings will be delivered, but the consultation document does not specify a location or clear timescale for delivery. This represents a significant risk in terms of housing land supply as it depends upon the EWR programme, which could easily slip.

We would question how a ‘broad location for future growth’ for this strategic-scale development can be allocated within a local plan without an identified site that can be assessed and appraised. This proposal is entirely dependent upon a station being identified by the EWR Company, and yet there is no commitment to consulting with them or the associated programme.

The EWR project involves many uncertainties regarding both the route and the proposed stations, in addition to a complex legal process that will be necessary to facilitate its delivery. Even assuming that matters will be resolved and the scheme will proceed, we consider that there is a limited prospect of achieving 1,950 dwelling completions during the period to 2041.

The consultation document proposes that the three new settlements of Northstowe, Waterbeach New Town and Bourn Airfield New Village will continue to be developed during the new Local Plan Period and beyond.

The policy approach assumes that the annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on, meaning that more of the homes will be completed during the period to 2041.

We object to this assumption, as there are significant questions over the timings of the infrastructure required at both Waterbeach and Bourn Airfield. Where triggers are in place, requiring off-site highway, transport and infrastructure works before a certain threshold of development can be passed, we consider that this poses a genuine risk to delivery.

A realistic review of the timeframes for development and impacts on the trajectory is required.

We strongly object to the proposed development strategy, and in particular the lack of site allocations for the rural areas. We consider that the suggested approach represents a lack of forward planning for existing village settlements, some of which are highly sustainable and represent excellent locations for growth. Existing village settlements make up a significant proportion of the Greater Cambridge area, and form the majority of South Cambridgeshire District. By adopting a reactive-only approach (windfalls-led), the Councils are restricting the opportunities for a genuinely plan-led approach to the development of these villages. We believe that this is in direct conflict with the policy set out in NPPF (paragraph 79), which sets out the following approach in relation to rural housing:
“To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”

In the context of the NPPF, we urge the Councils to review their policy approach in relation to the rural area.

Directing growth to villages that are well-located and have the potential to accommodate and benefit from growth should be a key element of the Local Plan’s spatial strategy for the period to 2041. The planned expansion of villages such as Hardwick could provide new housing whilst also boosting the local economy, creating the critical mass for improved services and facilities which in turn will assist in rejuvenation and creating an improved sense of place. This will also reduce the need to travel, promoting sustainable lifestyles and reducing the impact of development on the environment.

Identifying and allocating village extensions to well-located settlements such as Hardwick would serve to encourage the use of sustainable transport options without impacting on the Green Belt areas of greatest value. Hardwick benefits from existing bus services, cycling and walking routes. Accessibility will be further improved through the implementation of the Cambourne-to-Cambridge public transport project and potential linkages into the Greenways cycle network.

As set out in the NPPF (as above), sustainable development in rural areas is about locating housing where it will enhance or maintain the vitality of rural communities. The sustainable growth of villages through additional housing development can contribute to the footfall needed to support village services and facilities, reaching a critical mass that can support a vibrant village economy. This reduces the need to travel by private vehicle and also rejuvenates local areas and their communities. In addition, the allocation of medium- and large-scale residential sites ensures the delivery of much-needed affordable housing within villages, promoting mixed communities and providing for emerging housing needs. A lack of market housing in villages, or permitting only small-scale development, will perpetuate problems of restricted housing supply, increasing house prices and lack of provision for genuine local needs.

Likewise, the co-location of different land uses is another important consideration in making strategic policy decisions to shape travel choices. For example, where new residential developments in villages provide a mix of uses (employment, shops and cafes, community facilities and recreational spaces) or are located adjacent to existing services, this will facilitate residents to live, work and socialise within their own local area and community. This will reduce the need to travel into Cambridge or one of the towns for work, shopping, and other facilities. It will also have a positive impact in terms of sense of place, community, and wellbeing.

The proposed requirement for 20% biodiversity net gain compares with the recently passed Environment Act 2021 which requires 10% BNG. Whilst we support the concept of creating BNG on development sites, it is important that viability is carefully considered. We are concerned that off-site mitigation is likely to be required to achieve 20% BNG on many sites, resulting in considerably higher costs for developers. This could negatively impact on the viability and deliverability of sites. In addition, in some cases there would be an impact on land-take, reducing the developable area of the site and potentially the quantum of development.

Our proposed development site at ‘Land east of Cambridge Road, Hardwick’ (Site No. 40414) should be allocated within this section of the emerging Local Plan.

The Site is situated directly adjacent to St Neots Road, with a regular bus service (Citi 4) into Cambridge (east) and Cambourne (west). Public transport provision along the corridor will be further enhanced by the Cambourne-to-Cambridge public transport project and future infrastructure improvements associated with East West Rail. Whilst enjoying the same level of public transport provision as Cambourne (and in the future, Bourn Airfield), the Site benefits from being significantly closer to Cambridge, with safe cycle routes making sustainable modes a realistic alternative.

The Greater Cambridge Housing and Economic Land Availability Assessment (HELAA)(September 2021) assesses the circa 700 potential development sites put forward by landowners and developers through the local plan review process. The HELAA provides an assessment of the various sites in terms of their suitability, availability and achievability. With respect to Land east of Cambridge Road, Hardwick (Site No. 40414), the assessment concludes that the Site is suitable (amber rating), available (green rating) and achievable (green rating). We would note that under ‘Suitable’ there are a mix of green and amber-rated items; none of the items are assessed with a red rating. We would reassure the Councils that all of the amber-rated matters can be addressed and necessary mitigated where necessary, through the design of the proposed development. Site No. 40414 is confirmed to be suitable, available and achievable.

A range of assessments have been undertaken to inform the development concept for the Site. The Development Framework (Vision) Document and other technical documents submitted in support of the Site’s allocation are as follows:
• Development Framework (Vision) Document, December 2021 (Terence O’Rourke);
• Landscape and Visual Appraisal (LVA), December 2021 (Terence O’Rourke);
• Green Belt Review, December 2021 (Terence O’Rourke);
• Heritage Assessment, December 2021 (Barton Willmore);
• Archaeology Desk-Based Assessment, October 2019 (Landpro);
• Preliminary Ecological Appraisal, February 2020 (MKA Ecology);
• Phase 1 Geoenvironmental Assessment, September 2019 (Enzygo).
These documents supplement those previously submitted, including Transport and Drainage.

As illustrated in the Development Framework Document, the Site presents the opportunity to create a high-quality and sustainable residential-led extension to the settlement of Hardwick, commensurate to its scale, in a manner that can sustain, grow and underpin local services and needs, through significant improvements to the village and its community.

The vision for the Site is to create a place that enlivens and enriches the existing village and has a strong emphasis on place-quality, the highest sustainability credentials, community infrastructure and a mixed and balanced demographic. The proposed development includes sustainable transport links; a new local centre with retail, employment space and community facilities; new low-carbon homes; significant biodiversity net gain; a new country park and a range of green infrastructure improvements. The masterplan incorporates accessible woodland, additional sports facilities, community gardens and allotments, informal open space/semi-natural greenspace and extensive playable landscapes.

As set out in the Development Framework Document (page 38):
“The site is perfectly located to address many of [the] community needs including the delivery of new community facilities, improvement to Cambridge Road and diversification and expansion of the recreation offer in the village. Importantly, the development reaches a critical mass, sufficient to support and deliver new facilities and open space which will address the current and significant deficiencies in the village. The development will therefore be transformational, turning an existing commuter settlement into a vibrant and cohesive community.”

A Landscape and Visual Appraisal (LVA) of the Site has helped inform a comprehensive Green Belt Review. The findings are summarised at page 26 of the Development Framework Document. In short, it is concluded that the Site des not contribute to the Cambridge Green Belt purpose 1 and provides a relatively limited contribution for purposes 2 and 3. The development strategy will ensure that a new defensible boundary prevents any further growth eastwards and preserves the remaining and substantial gap from further future development.

The consultation document proposes that Policy GP/GB will reiterate the importance that the NPPF places on Green Belt. It states that:
“The Greater Cambridge Local Plan will include the established local purposes of the
Cambridge Green Belt, which are to:
• preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre;
• maintain and enhance the quality of its setting;
• prevent communities in the environs of Cambridge from merging into one another and with the city.
Enhancement of the Green Belt, such as for recreation and biodiversity, will also be supported.”

This section of the consultation document and the associated Great Places Topic Paper refers to the previous ‘First Conversation’ discussions regarding whether or not land should be released from the Green Belt to allow for development in sustainable locations. We note that the ‘First Proposals’ consultation is proposing land for release from the Green Belt through the local plan review. This includes Green Belt land in villages such as Gt Shelford, Sawston and Oakington. It should also include the release of land at our proposed development site at ‘Land east of Cambridge Road, Hardwick’ (Site No. 40414).

Terence O’Rourke has undertaken a Green Belt Review (December 2021) which is submitted in support of the above proposed site allocation and the land’s release from the outer edge of the Cambridge Green Belt. The Terence O’Rourke report sets out the following important evidence:

• Stage 1 - a general commentary on the LUC Green Belt Assessment that has been undertaken on behalf of the Councils. It identifies where there are weaknesses, oversights and omissions.
• Stage 2 – a critique of the LUC Assessment in relation to the parcels in which the proposed development Site (No. 40414) is located.
• Stage 3 – re-visiting the Terence O’Rourke Green Belt Assessment (2019), and how the proposed concept masterplan for the Site (including mitigation strategies) respond to the Green Belt.

The reassessment includes looking carefully at the NPPF and Cambridge Green Belt purposes in the context of the Site area – rather than Parcel HA4 as a whole (as defined by LUC). The reassessment work confirms that, unlike other areas of the Green Belt, the Site does not contribute to Cambridge Green Belt purpose 1 and provides only a relatively limited contribution for Cambridge Green Belt purposes 2 and 3. It will have only a minor-moderate impact on adjacent Green Belt if released and would create only moderate overall harm if released. However, this moderate harm would be further reduced by the considerable mitigation measures being proposed within the concept masterplan for the Site, as set out in the Development Framework (Vision) Document (December 2021).

LUC assessed the overall harm of releasing parcel HA4 from Green Belt as creating ‘high harm’. However, in using the LUC criteria to reassess the harm that Site No. 40414 would create if released from Green Belt, Terence O’Rourke’s Review considers that this falls within the ‘moderate harm’ category, two levels of harm lower than LUC’s assessment for the whole of parcel HA4. The Review also concludes that creating a new woodland edge to the development could become a new strong defensible Green Belt boundary, and that this mitigation would assist in reducing the harm further, should the Site be released from Green Belt.