Greater Cambridge Local Plan Preferred Options

The consultation document proposes that this Policy will group together “similar settlements into categories that reflect their scale, characteristics and sustainability”. For each category, it is proposed that the Policy will also set out the scale of development that would be considered acceptable through windfall applications on unallocated sites.

Categories
The approach proposed is very similar to that set out in the adopted South Cambridgeshire Local Plan 2018, including the following categories:
• City
• Town
• Rural Centre
• Minor Rural Centre
• Group Village
• Infill Village

Supporting text (page 47-48) states that “an updated assessment of settlements has been carried out, informed by the level of services and facilities, education, public transport and employment available at each settlement”. It proposes to change the position of only three settlements: Cambourne, Cottenham and Babraham. We have no objection to these three changes. However, given that the categorisations are stated to be based on an assessment of existing services, we believe that it is premature to include both Waterbeach New Town as one of three ‘Towns’ (alongside Cambourne and Northstowe) and to include Bourn Airfield New Village as one of four ‘Rural Centres’ (alongside Histon & Impington, Great Shelford & Stapleford and Sawston). Given the stage of development at both locations, these categorisations are not consistent with the approach taken to assessing existing settlements. They are based entirely on the future development of these strategic sites.

We consider that the policy approach is confusing and should be clarified. If the revised Settlement Hierarchy is to consider not only the existing levels of services and facilities within a settlement, but also the settlement’s potential as a location for sustainable future growth during the plan period, then this approach should be taken to all of the villages. In the absence of this evidence and approach, the strategy is inherently flawed. Where a village lacks existing services for its size, the development plan offers the potential to address that lack of provision in a planned manner.

We are strongly of the view that, based on a current assessment, Hardwick Village should be re-classified as a ‘Minor Rural Centre’ within the Settlement Hierarchy. However, if the future development potential of the village is to be taken into consideration (as per Waterbeach New Town and Bourn Airfield New Village), then Hardwick Village should be identified as a ‘Rural Centre’ and a key location for sustainable development.

The Site Assessment findings are set out in Topic Paper 1 (page 246 onwards). The text on Hardwick is as follows:
“Hardwick has a population of 2,550. It has a high proportion aged between 16 and 69 (70%) and a low proportion of the population is over 70 (10%). Hardwick does not have a secondary school. It has good public transport links as it is on the Citi 4 bus route, although the bus stop is approx. 10-minute walk from the village centre. It is also on the planned Greater Cambridge Partnership route between Cambourne and Cambridge and is awarded an additional point for transport to reflect this. Although well connected, Hardwick does not offer a range of shops and services to warrant moving up the hierarchy. It is in close proximity to the proposed new settlement at Bourn Airfield which will perform as a centre for the surrounding rural hinterland.”

Firstly, it is important to note that the planned centre for Bourn Airfield is 3.5km (as the crow flies) from Hardwick. Further, development is yet to progress at Bourn, has been subject to delay and uncertainty, and will take at least 10 years to deliver a centre that can serve the wider area. In this context; (a) why should residents of Hardwick have to travel 3.5km to additional services at Bourn, when it can be provided in the village; (b) why should residents of Hardwick be subject to the uncertainty over what comes forward there; and (c) why should they have to wait 10 years for these to be available? Travel to Bourn (for what is likely to be limited local services that could be provided in Hardwick) is not considered to be a sustainable strategy.

Whilst somewhat dispersed between the old village core, the 1970s village centre and St Neots Road, there are a range of facilities within Hardwick. These include: a school, pre-school, post office, pub, village store, veterinary surgery and a range of additional shops and services on Cambridge Road and St Neots Road (beauty, hairdressers, pet shop, cafe, tutoring services, etc). In addition, there is an active social club at the recreation ground and a number of community, sport and church groups.

Hardwick scores strongly in terms of accessibility (markedly better than Bourn) to Cambridge and occupies a sustainable location that will benefit from the Cambourne-to-Cambridge public transport scheme, once implemented. In the meantime, the Citi 4 bus route provides a fast and efficient route along St Neots Road with as many bus services as Cambourne and yet benefiting from being significantly closer to Cambridge. In addition, there are safe cycle routes and Hardwick is a commutable cycling distance from both Cambridge and Cambourne. It would seem entirely appropriate to plan for the local needs of Hardwick within the village (as opposed to reliance on Bourn Airfield), given that Hardwick is closer to Cambridge, which will serve its broader needs.

At the strategic scale, Hardwick lies within the Cambridge-Milton Keynes-Oxford (CAMKOX) arc, a key focus for future infrastructure improvement including East West Rail.

Recent developments in Hardwick include Grace Crescent and Land south of St Neots Road. Like the previous Meridian Close development, both of these recent developments were unallocated, windfall sites. However, each site was granted planning permission for major residential development – of a scale much greater than the thresholds suggested for Group Villages within the second part of S/SH (see below). The Green Belt designation has led to the development of Hardwick extending westward from the centre of the village. Our proposed development site at ‘Land east of Cambridge Road’ (Site No. 40414) provides a strategic opportunity for the future sustainable development of the settlement.

Limits of Windfall Developments
It is proposed in the consultation document that S/SH should place a restriction on individual housing scheme size, based on the categorisation of the village in question within the Settlement Hierarchy. This proposes that Cambridge, the Towns and Rural Centres have no limit on windfall scheme size. However, the following are suggested for the remainder of the Hierarchy:
• Minor Rural Centre: indicative maximum scheme size of 30 dwellings.
• Group Village: indicative maximum scheme size of 8 dwellings, and exceptionally consist of up to about 15 dwellings where this would make the best use of a single brownfield site.
• Infill Village: indicative maximum scheme size of 2 dwellings, and exceptionally consist of up to about 8 dwellings where this would lead to the sustainable reuse of a brownfield site bringing positive overall benefit to the village.

We object to this policy approach, and do not consider that these limits should be included as they are overly restrictive and inflexible. We would highlight the policy approach set out in NPPF (paragraph 78) for rural housing:
“In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs.”

Particularly given the lack of village allocations that are proposed in the consultation document, it is important that the policy allows adequate flexibility to respond to needs – which should be the subject of a more rigorous and informative assessment of settlements. As mentioned previously, one of the benefits of allowing medium- and large-scale housing development within villages is that it facilitates the delivery of affordable housing. By comparison, schemes of 2-8 dwellings will rarely include affordable accommodation and therefore does little to address existing or emerging local need.

As mentioned above, Hardwick is currently categorised as a Group Village and yet the scale of windfall developments permitted in recent years has been significantly larger than the thresholds suggested in S/SH. This is considered to provide further evidence that the village should be re-categorised to a higher tier of settlement in the hierarchy. Taking into account recent and ongoing development within Hardwick, and the settlement’s potential within the Plan Period – including the development of the promoted site at land east of Cambridge Road (Site No. 40414) – it is realistic that Hardwick be re-categorised as a Rural Centre.

The development strategy set out in the consultation document is based around a need for 11,640 additional homes to be identified over the period 2021-41. In keeping with our response to S/JH, we consider that this is inadequate to support the realistic growth objectives of the Greater Cambridge area over the next two decades.

In order to ensure choice, affordability and diversity, the Local Plan must make provision for a sufficient quantity of housing. It must also include a range of housing types and sizes, across a variety of sites and locations. In accordance with the NPPF (paragraph 68), strategic policy-making authorities should identify a sufficient supply and mix of sites over the local plan period. This should include small and medium sites (NPPF, paragraph 69), in addition to large and strategic sites, to ensure the ongoing delivery of housing throughout the plan period.

In terms of the spatial strategy, we strongly object to the approach set out in the consultation document.

We believe that there is an over-reliance on North East Cambridge (the North East Cambridge Area Action Plan – NEECAP Area), the edge of Cambridge and a limited number of new settlements. Whilst some development is proposed in the rural area south of Cambridge (‘Rural Southern Cluster’) the consultation document sets out the following approach for the ‘rest of the rural area’ (page 31, emphasis added):
“In the rest of the rural area, we propose a very limited amount of development:
• Small new sites for housing and employment at villages that have very good public transport access, to help our rural communities thrive;
• New employment sites in the countryside meeting specific business needs; and
• Windfall development - an allowance for homes on unallocated land, which would need to be consistent with policy requirements in the Plan, including Policy SS/SH: Settlement Hierarchy, which sets out scales of development in different categories of village.”

We strongly object to the proposed development strategy, and in particular the lack of site allocations for the rural areas. The Site at ‘land east of Cambridge Road, Hardwick’ (Site No. 40414) would clearly has the potential to deliver housing and employment that is well-connected to public transport and local services, and that can help the village thrive – fulfilling the objectives for rural areas set out in the first two bullet points as quoted above. The lack of allocations and general approach is considered to lack any sense of forward planning for the 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), there are restricted opportunities for a genuinely plan-led approach to the development of these villages.

We believe that the proposed strategy is in 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 development strategy in relation to the rural area.

As shown by Figure 10 of the consultation document (page 40), the proposed spatial strategy represents a decrease in the proportion of growth within rural areas: from 30% in the Structure Plan; to 23% in the currently adopted Local Plans; down to a proposed 18% (for the emerging Greater Cambridge Local Plan). Supporting text states that “the less sustainable rural area would have a lower share of development in the new plan, whilst still providing some limited development to help support our rural communities” (page 40, emphasis added). This represents a gross generalisation: there are many settlements within the rural area that are very sustainable, and there are many that could be made more sustainable if evidence suggests (via a more informative audit of facilities/services) that growth could address a local shortfall of services. We consider that the spatial strategy should include an enhanced and more informative audit of services and local needs for each settlement and support more allocations within the rural area, particularly where it could address local needs that would make a settlement more sustainable, or where there are existing sustainable settlements on public transport corridors such as Hardwick Village.

We are strongly of the opinion that the development strategy should include a range of site allocations within the rural area villages. In addition to harnessing the existing potential of sustainable locations – where there is good access to public transport, etc – the careful planning of village site allocations can deliver benefits and enhancements for the existing population of the settlement (in addition to new residents). Where well-located and well-planned, a new development or settlement extension within a village context can be a catalyst to deliver wider and more holistic improvements, in the best interests of local communities – the Local Plan evidence base should re-assess this and identify where development in or adjacent to settlements could be made to address/support local needs.

Another risk to the proposed strategy is that unplanned, piecemeal development is likely to come forward in and around the villages in the event that housing completions stall on the strategic / new settlement sites. There is a genuine risk that major infrastructure requirements, S.106 triggers and other constraints could delay the delivery of housing completions on several of the major sites. The impact on housing land supply – as experienced within South Cambs District in recent times – is that the tilted balance of NPPF will become engaged and windfall sites will be granted planning permission through an appeals-led approach. This is less likely to deliver the well-planned and sustainable development that could be provided through an allocations-led approach.

The ongoing sustainable development and rejuvenation of existing village settlements should form part of the vision and development strategy of the Greater Cambridge Local Plan. The strategy set out in D/DS includes an over-emphasis on the City and new settlements; it is imbalanced and demonstrates a lack of consideration for the significant proportion of the area which is made up of village settlements. These communities require new housing to meet local needs, and opportunities for sustainable growth and development. We believe that the strategy should be revisited with this in mind.

On a related note, alongside the lack of medium and large-scale site allocations within the rural area villages, the Settlement Hierarchy (Policy S/SH) proposes significant restrictions on the typical scale of development within the villages (depending upon their ranking in the hierarchy). By limiting the size of housing development that can come forward via windfalls, there is a reduced prospect of significant community benefits and affordable housing being delivered through these sites.

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.