Greater Cambridge Local Plan Preferred Options

The proposed development strategy for Greater Cambridge directs the vast majority of growth to the Cambridge Urban Area, the edge of Cambridge and new settlements. Only a very small level of growth is directed to the Rest of the Rural Area. Of the allocations proposed, the majority of these are existing commitments (adopted allocations, sites with planning permission etc.). The Council are only proposing a need for an additional 11,640 homes to be allocated through the emerging Local Plan.

As part of their strategy, the Council have stated that their top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes. Some villages within South Cambridgeshire are in very close proximity to Cambridge; benefit from close proximity to employment opportunities; and are well placed in terms of existing and proposed public transport routes. Hauxton is such a settlement.

The allocation of the FWWTW for a greater quantum of housing and/or employment would help meet the needs of smaller settlements over the Plan period, providing greater variety in the types and location of development delivered and co-locating homes and jobs in close proximity to one another, reducing the need to travel.

With respect to the delivery of housing, it is important to highlight that the NPPF is clear in paragraph 69 that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly’ and that local planning authorities should ‘promote the development of a good mix of sites’. It is considered that the Council strategy focuses on the delivery of very large sites with a much lesser number of small and medium allocations.

Furthermore, paragraph 79 of the NPPF is clear that in order 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.’ By delivering more housing and/or employment florrspace in settlements such as Hauxton, development will continue to support local services and facilities, supporting their retention and growth.

In respect of delivering employment provision, paragraph 85 of the NPPF is clear that ‘planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport’. Whilst the Site is presently beyond the settlement boundary, opportunities close to the Site will significantly improve the public transport and sustainable modes of transport options to access the Site, not just from the City but from the surrounding settlements too. These same opportunities will also significantly change the Site setting and will place it instead, within a dynamic transport and growth corridor, linking directly to the City Centre and the Cambridge Biomedical Campus.

Paragraph 85 of the NPPF goes on to say that ‘the use of previously developed land, and sites that are physically well-related to existing settlements should be encouraged where opportunities exist.’ Bridgemere Land Plc consider that their Site at Hauxton represents such an opportunity and that it will also provide the opportunity to remediate a highly contaminated Site, which will have wider environmental and/or employment and housing benefits.

Bridgemere Land Plc are therefore of the view that the Council should look to deliver a greater number of smaller and medium allocations to ensure that there is a supply of housing that can be built out sooner within the Plan period, but that the FWWTW site is also highly suited to deliver employment floorspace, or a mixture of the two. The Site in Hauxton comes with environmental constraints which will need to be addressed in full and would constitute an environment benefit to the wider area. It could be remediated and developed within the first half of the Plan period.

Under this policy the Council set out a settlement hierarchy as follows:

(i) Cambridge
(ii) Town
(iii) Rural Centre
(iv) Minor Rural Centre
(v) Group Village
(vi) Infill Village

This hierarchy is essentially the same as the adopted hierarchy in the South Cambridgeshire Local Plan (2018), with the addition of Cambridge and Town to recognise the bringing together of the two authorities for planning purposes.

Within the First Proposals, Hauxton is identified as a Group Village, which is again the same as adopted policy. Notwithstanding the existing and forthcoming transport links, this suggests that Hauxton is towards the bottom of the hierarchy.

Hauxton benefits from a number of services and facilities commensurate with a village of its size. These include a pre-school, primary school, places of worship, a community swimming pool, a village hall with an extensive range of classes and sports activities available and recreational facilities including sports pitches and playgrounds.

Within the Council’s Development Strategy Topic Paper (September 2021), an audit of each settlement has been undertaken to inform the location of each settlement within the hierarchy. Bridgemere Land Plc would suggest that this is reviewed, because it identifies that Hauxton does not have a nursery/day care. Hauxton does have a pre-school which provides an important facility for local residents. Furthermore, it is unclear how the provision of a primary school is taken into consideration within the methodology, given that it is not included in Appendix 5, but Appendix 3 of the paper. As such, no points appear to be given to this important facility in the scoring system.

A very important consideration is the proximity of Hauxton to Cambridge. Housing, employment or a mixture in Hauxton would help facilitate a shift away from car use, and certainly reduce any journey times by car. Hauxton is highly accessible and is linked to the edge of Cambridge by footways, which as already outlined are set to be significantly improved for pedestrians and cyclists. Bus services serve the village linking it to Cambridge, along with nearby settlements. The closest railway station is Shelford Station, which is 2.5 miles from Hauxton and offers services to London.

It is highlighted that despite Hauxton’s very close proximity to Cambridge, no sites are proposed for allocation within the village. The Former Waste Water Treatment Works at Hauxton would therefore offer the opportunity for a site that benefits from many sustainable travel opportunities owing to its proximity to Cambridge.

In line with their promotion of the Former Waste Water Treatment Works at Hauxton, and in light of significant forthcoming infrastructure projects, Bridgemere Land Plc advocate that the Site should be included within the settlement boundary of Hauxton for the provision of either a significantly increased quantity of housing, employment or a mixture of both.

This policy is considered to only illustrate further the lack of distribution in housing and employment sites across villages within South Cambridgeshire. The vast majority of proposed allocations are carried forward, with only 3 new residential allocations and a single new mixed use allocation. These sites are in Melbourn, Caldecote and Oakington. The latter two of these both being Group Villages like Hauxton. The residential allocations propose a total of 104 homes and the mixed use allocation 120 homes. These are considered to be small additional contributions to housing allocations in the entirety of the rural area.

Furthermore, whilst land has been allocated for employment uses, specifically research and development facilities, these are at established sites such as the Genome Campus, Babarham Institute and Cambridge Biomedical Campus to strengthen existing clusters. However, as identified in the Council’s own employment evidence base, Greater Cambridge has a diverse range of employment sectors and in order to ensure that existing settlements benefit from jobs in close proximity to their homes to reduce the need to commute into Cambridge and further afield, consideration of new employment allocations within and close to existing settlements should be examined further as part of the next stage of the Local Plan. The FWWTW site provides an opportunity for consolidating the employment opportunities that have been created by the adjacent Mill SciTech Park on the eastern side of the A10.

If the Councils are of the view that new housing and employment uses will come forward through windfall sites, then Bridgemere Land Plc consider that this is highly unlikely. The settlements in South Cambridgeshire have tight settlement boundaries and the availability of land within these boundaries for future housing and employment development is limited. This is evident given the exceptionally high demand for land for development in the district. Indeed the risk may be that small sites come forward for 2 or 3 houses at a time, given the size of plots, which will increase the overall population of existing settlements, but without the means to secure funding to improve local services and facilities. As such, the Council should be taking a more comprehensive approach, whereby housing and employment allocations are identified at this stage to deliver much needed homes and jobs in a planned manner, alongside funding for important local infrastructure.

The Greater Cambridge Local Plan Development Strategy Options – Summary Report (November 2020) sets out work undertaken to assess further whether the spatial choices set out in the Greater Cambridge Local Plan: First Conversation consultation were indeed reasonable.

Consequently, eight choices were taken forward for testing as strategic options, which included:

‘Spatial Option 5: Focus on Dispersal: Villages - this approach would spread new homes and jobs out to the villages.’

The document sets out that such distribution would ‘result in multiple smaller sites that are likely to be deliverable in the short to medium term; this would also meet the NPPF requirement to allocate a percentage of small sites.’

It was however considered to be the worst for carbon emissions with the worst transport links. However, this is a generalised statement and does not recognise the different attributes of individual settlements. Key to a sustainable scheme is accessibility. Hauxton is in close proximity to Cambridge, the largest settlement in the Greater Cambridge area and the location of the major employment, retail and leisure opportunities. Cambridge is readily accessible from Hauxton (and vice versa) by bicycle, bus or via Park and Ride, and by car would only be subject to very short journeys. It is also at the confluence of several forthcoming transport initiatives, which will place the Site within a dynamic and highly sustainable transport corridor.

It is therefore considered that the conclusion reached in the evidence base is not representative of Hauxton, and that the Council should give further consideration to the delivery of housing and employment in this location, which relates to further comments that Bridgemere Land Plc have to Policy S/RRA - Site H/2 - Bayer CropScience Site, Hauxton.

Policy S/RRA - Site H/2 - Bayer CropScience Site, Hauxton:

The First Proposals Consultation Document contains Draft Policy S/RRA which comprises a small number of site allocations within the rural area. As part of this policy, Site H/2 is identified as the Bayer CropScience Site to the East of the A10 in Hauxton. It is proposed that the proposed policy direction for this site will be amended from the adopted 2018 Local Plan, to encompass only the employment areas of the Bayer CropScience site, which are still to be developed, the rest of the scheme now having been completed and occupied.

At this stage, the proposed policy direction is limited within the consultation document and therefore it is not clear whether the emerging policy will contain similar provisions within the supporting text, concerning the FWWTW site. Paragraph 7.13 of Policy H/2 in the adopted 2018 Local Plan sets out the following:

Proposals for the redevelopment of the recreation buildings and waste water treatment facility on the western side of the A10 will be considered in the context of proposals that do not comprise inappropriate development within the Green Belt. As a planning objective it would be highly desirable to secure the removal of the incongruous industrial structures on the western part of the site. Particular consideration should be given to proposals that remove these structures and improve the visual appearance of the Green Belt through proposals that are consistent with Policy NH/9 and the NPPF (2012) paragraph 89.

Whilst not contained within the specific wording of the policy, the identification that the remediation of the Site is a planning objective and that particular consideration should be given to proposals that remove the existing structures and improve the visual appearance of the Green Belt are of use in determining planning applications for the Site, including the recent permission for 32 homes on the Site.

During the determination of the planning application for 32 homes, it was apparent to all parties, the highly complex nature of the Site, which aside from its planning designations, has a significant number of environmental requirements to satisfy in order to remove the contamination from the Site. This unique set of circumstances ultimately informs the type and scale of development needed on the Site in order to see it remediated, the existing structures removed and an appropriate scheme found for the Site, which improves the visual appearance of the Green Belt. Such a scheme is highly likely to be for a greater quantity of homes than currently approved or alternatively an employment use to complement the Mill SciTech Park.

This would be in accordance with the objective of paragraph 145 of the NPPF, which ‘sets out that once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, including looking for opportunities to improve damaged and derelict land’.

Furthermore, paragraph 119 of the NPPF sets out that ‘strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land’. This is a strategy which the Government have continued to advocate through recent briefings and the Autumn Budget 2021.

Taking this into account and given the unique circumstances of this Site, Bridgemere Land Plc are of the view that the Site requires more than a supporting paragraph within the emerging Local Plan, but a policy of its own, in order to fully realise the development potential of this Site. Therefore, the Site has been put forward as a Major Development Site within the Green Belt as part of the Call for Sites Consultation 2021.

The extant planning permission demonstrates that it is possible for a scheme to come forward on this land within the Green Belt, utilising the Previously Developed Land. However, given the complexities of the Site, specifically around the extent of remediation required, it is vital to include a site specific policy within the emerging Local Plan, which recognises the complete development potential of this Site for delivery of housing, employment or a mixture of both and to support its delivery, which Bridgemere Land Plc consider to be greater than currently approved.

The Green Belt Assessment (2021) undertaken by LUC on behalf of Greater Cambridge places the Site into Parcel HX12. Within its assessment, it identifies that the parcel makes limited or no contribution to the preservation of Cambridge as a compact, dynamic city and that it makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting and preventing communities from merging with one another, in this context, Hauxton and Haslingfield.

Notwithstanding this, the assessment identifies that the release of the land as an expansion to Hauxton would not be favourable, given the presence of the A10 as a strong separating feature between the settlement of Hauxton and parcels of Green Belt to the west, including Parcel HX12. As such, the suggestion is to not release the land from the Green Belt, but to identify it as a development site within the Green Belt, taking into account national and local Green Belt policy, but also recognising that the Site does have a very special set of specific circumstances, which need to be considered as a whole in order to bring forward this Site and see it improved for the benefit of all. Bridgemere Land Plc consider that these specific circumstances of the Site which include the ability of a scheme to remediate the contamination on Site and making the most efficient use of the previously development land resource available, requires a scheme of greater scale than currently approved and that working collaboratively with the local planning authority and key stakeholders this can be achieved on the Site.

To facilitate this, a site specific policy should be included in the emerging Local Plan and to assist the Council, such a draft policy for the Site could include:

A. Proposals for the re-development of the Former Waste Water Treatment Works, Hauxton as previously developed land within the Green Belt will be permitted where the re-development:

a. contributes towards local housing needs and/or provides new jobs;
b. removes the existing incongruous industrial structures on the western part of the Site;
c. would not have significantly greater impact on the openness of the Green Belt;
d. where the scheme delivers significant environmental benefits including remediation of the Site and that these benefits are recognised as very special circumstances that should be given great weight in the planning balance and consideration of harm;
e. improves the visual appearance of the Green Belt through a comprehensive landscaping strategy;
f. where possible, seeks to connect to existing and/or emerging sustainable transport schemes linking to existing villages and the City of Cambridge; and,
g. contributes to the authorities’ sustainable development principles as set out in other policies in the Plan.

B. The Council will assess the proposed re-development scheme based on the following:

a. the very special circumstances of the re-development scheme and ensuring that site specific benefits are given great weight against any assessment of harm to the Green Belt;
b. the visual impact of the development would not cause substantial harm to the Green Belt, when taking account of the existing built form, the context of the Site, the significant environmental and/or employment/housing benefits and the notable features, including new transport projects within the vicinity;
c. the activities / use of the new development compared to the existing/established use;
d. the contribution of the development to remediate the Site so that it diminishes the risk to human health and the environment and provides a safe and habitable/working environment for the end users; and
e. taking into account other policies within the Plan when taken as a whole.

Wider Green Belt Context
As part of the consideration for this Site, one needs to recognise that there are a number of emerging local transport schemes in close proximity to the Site, as outlined in paragraph 2.8 above, which will alter the visual context of the Site, but also bring with them considerable improvements to sustainable connections between the Site and the City. These schemes are being brought forward by the Greater Cambridgeshire Partnership in conjunction with Cambridgeshire County Council and the East West Railway Company and have funding and approval to move forward to construction, subject to obtaining the relevant consents. All are located in the Green Belt:

(a) A new travel hub on land to the west of junction 11 of the M11, to the north of the FWWTW and west of the A10. This travel hub will provide 2,150 car parking spaces, 326 cycle parking spaces and associated coach parking, a new travel hub building, bridge across the M11 and associated highway infrastructure works to the M11 junction and dedicated busway into Cambridge. Whilst the planning application for that scheme still remains under determination by the County Council, the location of that site within the Green Belt to the proximate north-west of parcel HX12 is notable and will alter the appearance of this part of the Green Belt.

(b) A number of Greenways have been approved linking villages on the periphery of Cambridge with the City and the Partnership are in the process of detailing these routes. Immediately to the west of the site, will be the junction for the Melbourn and Haslingfield Greenways, with their indicative route into the City Centre utilising land directly to the west of the Site. This Greenway will link into the new travel hub to the north, providing onward routes for pedestrian and cyclists over the M11 and into Cambridge. As a shared use path, it is expected that it will be approximately 3 m in width, potentially with some level of lighting, and will certainly form a new distinctive western edge to the FWWTW Site.

The above are important factors to consider and ones that could equally be harnessed for the benefit of a future scheme on the Site.

Whilst the Site is seen to be separated from the core settlement of Hauxton, the above context demonstrates that to the west of the A10 a sustainable transport corridor is highly likely to come forward, which places this previously developed site in an ideal location to provide a scheme which can contribute towards meeting local housing and/or employment needs in a highly sustainable location and a rapidly-changing context, which makes it very unique and readily deliverable.

Section: S/JH: New jobs and homes
Whilst Bridgemere Land Plc support the approach that the Council have taken in setting a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth over the Plan period and accordingly that this needs to be supported by a higher level of housing provision in the emering Local Plan.
Full Text:
The Council states that the emerging Local Plan will meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs; and,
• 44,400 homes.

The housing figure equates to an average of 2,114 homes per annum, with a suggestion that this will meet an objectively assessed housing need for 2,111 homes per annum that has been rounded upwards in deriving the total figure. It is noted that the Plan seeks to provide for approximately 10% more homes than are calculated as being needed, a total of around 48,840 homes.

In justifying a housing need figure above the standard method, the First Proposals cite evidence assembled in the following two studies, with the higher need predicated on supporting anticipated economic growth within Greater Cambridge:

• Greater Cambridge Local Plan: Housing and Employment Relationships (November 2020), GL Hearn; and,
• Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020), GL Hearn, SQW and Cambridge Econometrics.

The latter of these two studies presents two alternative forecasts of potential economic growth over the Plan period:

• A Central Scenario under which 58,400 new jobs would be created, claimed to represent the ‘most likely outcome taking into account long term historic patterns of employment’ with the Housing and Employment Relationships study also describing it as ‘a business as usual growth scenario’;
• A Higher Scenario under which 78,700 new jobs would be created, with this ‘higher outcome placing greater weight on fast growth in the recent past, particularly in key sectors’ and the Housing and Employment Relationships study describing it as ‘a plausible but more aspirational growth outcome’.

The Housing and Employment Relationships study concludes that housing provision in line with the standard method will not support either of these economic growth scenarios. It estimates the housing need associated with supporting both as follows:

• Central scenario – 41,900 to 44,310 homes (1,996-2,110dpa) with the range reflecting alternative commuting assumptions, the upper end assuming that there is a 1:1 or balanced commuting ratio for new jobs and the lower end assuming continued in-commuting
• Higher scenario – 53,500 to 56,490 homes (2,549-2,690dpa) with the range again reflecting alternative commuting assumptions

The emerging Local Plan is proposing to deliver 44,400 homes, which supports 58,500 new jobs, aligning with the Central Scenario for growth in the District over the Plan period.

As set out in the Council’s Topic Paper on the Development Strategy (September 2021) at Section 5.3, the evidence base has identified that Greater Cambridge is a centre of excellence and a world leading economy of international importance. Whilst the focus is within the knowledge-based economy, other types of industry provide a wide diversification of jobs and services in Greater Cambridge, including education, retail, leisure, tourism and agriculture, all of which are highly important. This together with the important strategic position of Greater Cambridge within the Oxford-Cambridge Arc means that there is significant opportunity to plan for the higher jobs scenario of 78,700 new jobs, which in turn needs to be supported by a higher housing requirement of between 53,500 – 56,490 new homes to ensure that an appropriate level of market and affordable homes can be delivered within the Plan period.

Whilst Bridgemere Land Plc support the approach that the Council have taken in setting a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth over the Plan period.
Attachments:
2021_12_13_Bridgemere Representations, Hauxton_As Issued.pdf