Greater Cambridge Local Plan Preferred Options

The vision and aims are generally supported. However, we feel that the necessary integration between the location of new development (homes and jobs) and infrastructure needs to be expressed more clearly. There are clear advantages in locating major development and planned or committed transport infrastructure in close proximity.

Our clients support the identified requirement for 44,400 new homes in the period to 2041 as a minimum. This is above the minimum figure recommended by Government using the standard methodology which is appropriate for an economically thriving and ambitious region. Furthermore, it is pleasing to see the application of a pragmatic 10% flexibility allowance to allow for the non-take up of allocations or account for where delivery is stalled. The requirement for additional land for a minimum 11,640 homes to be identified in the Plan period to 2041 is appropriate.

Detailed comments provided under S/DS: Development Strategy.

With regard to the sources of supply, a blended strategy is proposed which draws on multiple approaches including; densification of Cambridge urban area, edge of Cambridge (outside the Green Belt), new settlement expansion, focus on public transport corridors and some dispersal to the villages. We feel the potential for further new settlements should form part of the strategy considerations.

The potential for further new settlements has been dismissed in the assessment of options and the Strategy places unsubstantiated reliance on intensification of existing allocations (North West Cambridge) and accelerated delivery at the new settlements of Northstowe and Waterbeach. In total, this accelerated delivery and intensification is expected to deliver 2,500 new homes over the Plan period. It is unclear how this approach can significantly boost the supply of homes (as sought in Government policy) in comparison with an approach which identifies additional strategic sites for new housing.

The Plan identifies that there is the opportunity for additional homes within the built area of the existing site in North West Cambridge at Eddington (1000 additional homes). Simply making an existing allocation larger does not necessarily mean it will deliver housing at an increased rate. We note that in the draft housing trajectory (Development Strategic Topic Paper) completions at Eddington are shown to increase from 109 to 291 dwellings per annum in the monitoring year 2024/2025. Beyond this, the delivery rate is set at around 250 homes per annum. This is an unrealistic expectation and whilst it would not be disputed that larger sites can contribute more units over the longer term (i.e. beyond the plan period), it is not necessarily the case that larger sites deliver more units per year. Output is dictated by market demand in a particular area, the number of sales outlets (per developer) on site and the capacity of homebuilding for each company on site. Given that a housebuilder would typically build 35-50 homes per sales outlet, the expectation for Eddington would require 5-7 housebuilders on this single site. This is extremely unlikely and does not reflect the historic disposal strategy of the landowner for this site. There appears to be no certainty contained in the evidence base that this additional housing at Eddington can come forward in the period to 2041.

The accelerated delivery at Waterbeach equates to an additional 50 units per annum over the period 2026/27 to 2041/41. A total of 750 additional homes are identified above the planned growth. No evidence is presented in the current consultation as to how this accelerated delivery is to be achieved. Housing delivery at Waterbeach has not yet started (anticipated to commence in 2022). In a similar approach to Northstowe, the draft housing trajectory assumes 250 units from each site per annum. At this stage there is no evidence to support the view that delivery rates can be sustained in these locations at this level.

As advised at para 73 (d) NPPF 2021, strategic policy-making authorities should make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites. Without further justification for the densification and acceleration of key schemes within the development strategy the housing delivery element of the Plan would be unsound.

The conclusion must be that further strategic sites need to be allocated for housing to ensure the required annualised supply of housing of 2,326 homes can be achieved. Vistry Group and RH Topham & Sons Ltd do not feel that sufficient evidence has been put forward to show that this can be achieved by a strategy that relies upon increasing the density of existing allocations and accelerating delivery. The identification of a further new settlement or strategic expansion of a sustainably located settlement would provide greater certainty around housing supply over the Plan period and beyond. We feel there is more potential for integrating new development (in the form of new allocations) with planned new infrastructure to the west of Cambridge such as the A428 Improvement Scheme.

The Landowner, RH Topham & Sons Ltd submitted a proposal for a new settlement option at Croxton during the 2019 Call for Sites stage (HELAA reference 40288). This site offers the opportunity to co-ordinate the delivery of new homes and jobs with key elements of committed transport infrastructure. NPPF 2021, para 73 directs strategic-policy makers to consider the opportunities presented by existing or planned investment in infrastructure when considering suitable locations for new development. This must therefore consider potential site opportunities which arise as a result of changes to key infrastructure. In terms of suitability, the Site falls outside of the Cambridge Green Belt, lies wholly in Flood Zone 1 (lowest probability of flooding), outside of any protected landscape/open space designation and is not part of a County Wildlife Site. In addition, there are no abnormal physical constraints to the development of the land.

The Concept Plan included with the earlier submission and provided with these representations shows how a Croxton Garden Village concept within the Greater Cambridge Local Plan administrative boundary could be achieved. The land contained between the new A428 carriageway and the existing road can accommodate circa 1,750 homes and associated supporting infrastructure within the South Cambridgeshire administrative boundary.

The land is in single ownership and can be phased over future Plan periods to continue delivering to 2050. A proposed Garden Village at Croxton would be a unique, practical and exciting opportunity to deliver housing and growth needs using Garden Settlement principles. The proposed location, being bounded by the existing and new A428 road could provide a solution towards meeting the identified social and economic needs and addressing the housing and development delivery during the Plan period and beyond.

The land is controlled by Vistry Group which was formed in January 2020 following the successful acquisition of Linden Homes and the Galliford Try Partnerships & Regeneration businesses by Bovis Homes Group PLC. With developments from Northumberland to Cornwall and Cheshire to Norfolk, Vistry is one of the top five housebuilders in the UK by volume. As one of the country’s leading housebuilders, Vistry has an established reputation for quality that runs through their homes’ design, build, specification and customer service.

Vistry Group has an established track record of taking large strategic sites through Local Plans to planning permission and importantly then delivering the new communities (infrastructure and homes) on the ground in a timely manner.

Introducing further land supply through alternative locations where they are not affected by large-scale upfront infrastructure requirements with long lead-in periods can enable new communities to be established quickly. For example, utilising planned infrastructure projects to direct growth to areas that have the necessary infrastructure capacity and options to influence delivery rates is key. Taking advantage of this immediate opportunity that new transport connections will offer during the Plan period will help create new markets to offer choice and avoid market saturation. The committed A428 dualling scheme should be a key focus for locating new housing in a location with improved connectivity and accessibility.

A Croxton growth option should be considered in the context of extending the C2C corridor scheme to link through to the St Neots rail infrastructure.

When the A428 Black Cat to Caxton Gibbet improvements scheme opens in 2025/2026, the new dual carriageway will become an extension of the existing A421. The certainty created through the committed funding stream and the current Development Consent Order application can be relied upon during the early part of the Plan period which allows major decisions to be made on locating development along this road corridor.

The First Proposals acknowledge that Cambourne could be a broad location for growth where the exact quantity, locations and design will be defined through future plan reviews. It correctly acknowledges that it is too early to identify a specific development area and amount of development.

There is potentially a case for a longer plan period to 2050 to be advanced to allow time to plan the necessary infrastructure but this would not change the need for sufficient land to be identified for the phase to 2041 on deliverable sites.

There is already significant committed growth around Cambourne and at Bourne Airfield which can continue through the Plan period regardless.

Whilst the future EWR route and new station locations are uncertain, all of the published work to date demonstrates that the land at Croxton will not be affected by any of the route options. The site is the only contained land parcel between the Black Cat Roundabout and west Cambridge that does not require any land to be safeguarded to deliver EWR. Should the current or preferred Route Options 1, 2 or 9 be realised, the recent Value Management Scenario testing has shown that all works would occur beyond the site boundaries. This is in stark contrast to any Cambourne-related works.

In summary, the draft development strategy does not currently reflect a robust spatial strategy that is capable of delivering the stated growth levels during the plan period. Some additional sites will be required.

Our Clients acknowledge this is a ‘First Proposals’ stage but it is imperative that progress on the plan preparation is not unnecessarily delayed pending decisions on the EWR route. There is the opportunity to include safeguarded land/corridors within the 2041 plan with a view to locating additional growth in a future plan review to 2050 once the route is fixed/delivered.

For the current Plan, additional land will be required to be identified now that will be compatible with, and complement future growth at Cambourne.

The settlement hierarchy methodology and tiers are generally supported. The recognition of Cambridge city at the top followed by the existing new settlements/towns including Cambourne is logical. However, decisions on the status of specific settlements within the remaining categories should be paused until the spatial strategy has been finalised. For example, the identification of any new or expanded settlements in the next stage of plan-making may alter the status of other villages.

For example, a new Garden Village or expanded settlement could take on a different role, potentially as a rural Centre or a Minor Rural Centre. Any new settlement should not solely be assumed to be within the same category or status as the three proposed ‘new towns’ of Northstowe, Waterbeach and Cambourne.

This policy will guide the continued development of the North West Cambridge (Eddington). We find there is little basis to conclude that the site can accommodate the amount of additional homes identified in the development strategy.

It is acknowledged in the Plan that the reconsidered capacity of the site will need to be informed by a detailed review of the site wide masterplan. The capacity is anticipated to be in the region of 1,000 to 1,500 homes. It is surprising at this stage of Plan making that the capacity of the site has not yet been tested before consultation with the public.

Our clients consider there is more potential for new settlements as part of the development strategy in the Plan. Historically, Development Plans in the area have identified new settlements which have allowed policy makers to look beyond the time horizon of a particular Plan period. New settlements have become a characteristic of plan making in the area. The identification of a further new/expanded settlement would provide greater certainty over housing supply in the plan period and beyond. We feel there is more potential for integrating new development (in the form of new allocations) with planned new infrastructure to the west of Cambridge such as the opportunity that arises through A428 dualling.

New settlements should not be viewed in isolation of existing infrastructure and communities. It is appropriate to consider whether there are any specific opportunities for creating new settlements based around existing infrastructure and services.

It is unclear what evidence is being relied upon to inform the view that annual delivery rates at Northstowe and Waterbeach can accelerate over the plan period (in comparison with historic rates and lead-in times)

The rural areas within Greater Cambridgeshire vary significantly in terms of their role and ability to successfully deliver sustainable growth. The evidence base should clearly acknowledge the different roles that parts of the district can play in the next plan.

There are settlements in the rural area that are underperforming relative to the village context and locational advantages.

Croxton is one of those settlements where the existing village is severed, split by the existing A428 which currently separates the employment area from homes and other commercial premises. It is a small village that sits within a key transport corridor. Its character will permanently change when the A428 is realigned, diverting the through traffic onto the new dual carriageway. There is a clear and unique opportunity to utilise the area that will be bound between the old and new A428 to create an expanded and better integrated settlement which could take on the form of a new garden village building on the established core.

The HELAA concluded that development in this location (site 40288) would have significant landscape and visual impacts on the historic landscape to the south and general impacts on views from the north and east. It is not clear whether the HELAA has considered the site in the context of the A428 Improvement Scheme that will fundamentally alter the rural landscape in this location and specifically, permanently change the views form the north and east. There is a clear opportunity to take advantage of this committed infrastructure change in a positive way. The Plan should recognise the possibilities for increasing the C2C corridor to St Neots and maximising the modal shift options that the section of the de-trunked A428 can offer post 2025/26 between Croxton and Cambourne.

The historic parkland landscape to the south would be largely unchanged in visual terms, but the consequential improvements through the change to the existing A428 as a local road would serve to better connect the village and potentially allow its historic characteristics to be better managed. Currently the two parts of the village are severed and inward looking away from the existing A428.

The functionality of the village could be improved through additional development and its sustainability credentials could be significantly enhanced through the inclusion of specific services and local amenities including school provision and expanding the existing employment opportunities currently on offer in the two existing commercial locations.

It is in the unique position of being able to support and complement the wider multi-modal strategies that are being considered for this corridor, capitalising on the opportunities to change the role of the current A428 carriageway once the new dual carriageway has been delivered.

The landscape impacts are not insurmountable; nor is the perceived negative impact on the landscape particularly different to the conclusions drawn in the HELAA for the majority of the 19 site options put forward in the First Proposals.

The HELAA should properly reflect planned infrastructure changes within its site assessments including at Site 40288.

Setting appropriate levels of energy use that will be allowed for in new development should be the remit of Building Regulations and not the Planning system.

Vistry Group’s purpose is to deliver sustainable homes and communities across all sectors of the UK housing market. Key to this purpose is a successful and ambitious sustainability strategy.

Their strategy launched in 2021 and is focussed on three priority areas of People, Operations and Homes & Communities. It includes a commitment to setting carbon reduction targets consistent with reduction required to keep warming at 1.5°C and the development of a roadmap to deliver net zero carbon homes.