Greater Cambridge Local Plan Preferred Options

Trumpington Meadows Land Company (‘TMLC’) a joint venture between Grosvenor Britain & Ireland (GBI) and Universities Superannuation Scheme (USS) owns the site at Trumpington South in Cambridge. TMLC therefore has an active interest in planning policy in Greater Cambridge and has provided comments on the relevant sections and policies in the Local Plan consultation. TMLC requests to be kept informed on the progress of the Local Plan.

TMLC supports the overarching vision for Greater Cambridge to be a place where a big decrease in climate impacts comes with a big increase in the quality of everyday life for all communities.

TMLC strongly supports the Great Places aim, in particular the reference to creating a place where people want to live, work and play.

TMLC strongly supports the Jobs aim, in particular the encouragement of a flourishing and mixed economy in Greater Cambridge which includes a wide range of jobs.

TMLC also strongly supports the aim of ensuring enough housing is planned for to meet the area’s needs.

TMLC supports the need for more housing in Greater Cambridge and that due to the climate emergency housing development should be located on sites that will have the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live.

The Local Plan will facilitate development to meet the objectively assessed needs (“OAN”) for 58,500 jobs and 44,400 homes, reflecting an annual OAN of 2,111 homes per year. TMLC supports the position that Cambridge have sought to plan for growth that extends beyond the figure calculated using the standard method in national planning guidance. As identified within the Government’s ‘Indicative Local Housing Needs (December 2020 Revised Methodology)’ table, using the standard method would result in 1,085 homes per year for South Cambridge and 685 homes for Cambridge City, equating to 1,743 homes per year across both authorities.

Paragraph 61 of the NPPF identifies that “exceptional circumstances” should justify an alternative approach to using the standard method. The evidence for the use of the alternative approach is included at page 22 of the Councils’ ‘Development Strategy Topic Paper’ which states that the ‘Employment Land and Economic Development Evidence Study’ and ‘Greater Cambridge Housing and Employment Relationships Report’, found that the standard method housing figure set by Government “would not support the number of jobs expected to arise between 2020 and 2041” and “it would also be a substantially lower annual levels of jobs provision that has been created over recent years”. Planning for this figure would “risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion” and as such, as is also concluded at page 23 of the Development Strategy Topic Paper, it cannot be considered that the standard method housing represents the OAN for homes and jobs within Greater Cambridge.

TMLC supports the proposed policy direction to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.

TMLC also supports the delivery of sites on the edge of Cambridge given they are sustainable locations to existing jobs, services, infrastructure, and transportation.

TMLC disagrees that Greater Cambridge housing need alone doesn’t provide the ‘exceptional circumstances’ required in national policy to justify removing land from the Green Belt on the edge of
Cambridge in this Local Plan (mentioned on page 39 and 45). Our position on why the release of Trumpington South from the Green Belt for housing is acceptable is discussed below and within the following sections: ‘Edge of Cambridge – General Comments’, S/CBC, S/EOC, BG/EO.

TMLC supports the need for the delivery of new strategic water supply infrastructure and will follow the development of the Water Resources East (Water Management Plan) for the region.

TMLC supports the delivery of Cambridge South Train Station and East West Rail. TMLC also supports Greater Cambridge strategy to plan new growth around the location of existing and committed transport schemes which will help provide sustainable transport options for residents and help the climate change aims of this emerging Local Plan (this is backed up by the majority of responses to the First Conversation consultation to releasing land from the Green Belt if it provides a more sustainable development option by reducing travel distances, helping us reduce our climate impacts)

TMLC supports new development on the edge of Cambridge as a sustainable location for new housing sites. TMLC supports land within the Green Belt on the edge of Cambridge being released for development.

Trumpington South is one such site, which can be delivered within the first five years of the new plan period. It is well connected to existing/proposed public transport nodes (such as Cambridge South Train Station & Trumpington Park & Ride) and it is well connected to jobs (such as the Cambridge Bio-medical campus).

TMLC supports the need to provide affordable housing for the key workers close to key employment sites.

TMLC have promoted Trumpington South within the Call for Sites, Issues & Options stages of this emerging Local Plan. The vision document for the Call for Sites sets out the following proposals for the site:
• Up to 750 zero carbon homes in operation, with a commitment to reducing and reporting on the associated embodied carbon emissions in construction as defined by the UK Green Building Council
• 40% affordable homes
• Primary school
• Mobility hub and community concierge services
• Active travel networks and segregated paths
• Car free zones and centralised parking locations
• New community and co-working facilities
• In excess of double the public open space requirements (up to 23 Ha)
• 25% net gain in biodiversity
• Up to 10% of open space planted with native trees

The emerging Local Plan has declared a climate emergency and as TMLC own the site they more flexible over the proposed development. TMLC aspirations are in the accordance with the goals of this proposed Local Plan such as promoting sustainable travel, access to public open space, higher net gain in biodiversity than Policy BG/BG, net zero homes and generally a scheme which has sustainability and climate change at its core. The site is in agricultural use with tenant farmer Trumpington Farm Company operating under a rolling Farm Business Tenancy and can be developed within the first five years of the new plan period.

The site is in the Green Belt. We consider its location on the edge of Cambridge (e.g., by Trumpington Park & Ride, close to the new Cambridge South Train Station and close to Cambridge Biomedical Campus) would be an appropriate site to be released from the Green Belt. The Greater Cambridge Green Belt Assessment (August 2021) classed the site as being ‘Relatively Significant’ according to Purpose 1, and, ‘Moderate’ according to Purpose 2 and 3. The harm rating of losing this Green Belt is ‘high’, which is a degree of harm lower than the proposed allocation at Cambridge Biomedical Campus where the harm rating is ‘very high’. In addition to the Biomedical campus expansion the site allocation also includes possible affordable housing and enhanced landscaping. Trumpington South has a lower impact than this Site and will provide a mix of development.

The Councils’ Strategic Topic Paper (page 208, Appendix 1D) states that 23 sites were submitted within the Green Belt on the edge of Cambridge. The paper states that 14 sites did not seek to justify exceptional circumstances and 4 sites did but these 18 sites were discounted. 5 sites provided bespoke arguments for exceptional circumstances and of these two were allocated within the plan (Land at Cambridge Airport and Cambridge Biomedical campus). TMLC Issues and Options and Call for Sites Vision document stated that this site could demonstrate exceptional circumstances, but the Topic Paper does not state where the site sits within the 23. TMLC would like to understand where Trumpington South sits within the review of the 23 Green Belt sites, as the site is suitable for development.

The site assessment (Ref. 40048) has a summary of red for Suitable and green for available and achievable. The Suitable criteria of red is based on 13 issues (1 as red, 8 amber and 4 green). It is not clear if the ‘further constraints’ are part of the scoring for the suitable criteria either. Based on these individual scoring TMLC doesn’t understand how the Council have concluded that this site scores as red (especially if further constraints are not included). If further constraints are included then the site scores red on landscape, impact onto the strategic road network and the Green Belt (assuming that the proforma accidentally missed including this as red). We consider the following in respect of the two first points:

• Within the Councils’ Landscape Character Assessment (2021) the site is located within Character Area 3D - Cam & Granta Tributaries Lowland Farmlands. The site serves as part of an existing Southern Fringe Area Action Plan and is land retained as undeveloped, to create an enhanced gateway into the City between Hauxton Road and the River Cam inclusive of hedgerow planting, foot and cycle paths, wildlife habitat enhancements and noise attenuation. It is considered that development at Trumpington South would have a significant impact on the local and wider landscape character. The Landscape Character Assessment identifies Trumpington Meadows as a nature reserve and within the Local Plan call for sites feedback it suggests that the Trumpington Meadows development has been designed to include a distinctive urban edge with a green foreground providing a gateway to the city. Given the character setting of the area, the LPA’s are against development which will use the M11 as an enclosing boundary. TMLC disagrees with this assessment given that the site will be designed taking into consideration and enhancing its surroundings. In addition, the vision document makes it clear that TMLC will provide double the amount of open space required, plant native trees and will have a 25% net biodiversity gain which is 5% larger than the proposed policy. TMLC aspirations is for sensitive development which enhances its surroundings.

• Highways England have considered the site to be unsuitable for development due to falling within Zone 8 (M11 North) which states that the site would need to ensure no net increase in vehicle trips onto the strategy road network. The Councils’ Housing and Economic Land Availability Assessment (HELAA) 2021 states (page 54) that this ‘does not rule out sites at this stage. However, to be acceptable in planning terms development proposals within these zones will need to demonstrate (through a Transport Assessment and Travel Plan) no net increase in vehicles trips on the strategic road network’. TMLC consider that an amber score would be more considerable given this position from Highways England. This is also based on the pending planning application for the relocation of the ‘Trumpington Park and Ride’ to the south of the M11, that Highways England consider the principle of development to be acceptable, under the assumption there will be a ‘trip budget’ approach to minimise vehicle traffic, resulting an acceptable minimal impact on the Strategic Road Network. Furthermore, the TMLC vision document sets out how the site will aim to reduce vehicle trips due to the location to key public transport nodes which TMLC consider will help mitigate vehicle trips onto the M11.

In terms of the Green Belt assessment undertaken by LUC, there are a number of important points that appear to be overlooked (in addition to the points above) and in conjunction with the landscape character of the site, which are as follows:

• Trumpington South is located within parcel TR6. This parcel includes part of Trumpington Meadows Country Park as well as the agricultural land within which the development is proposed. Previously we have argued that this area should be subdivided into two parcels reflecting the distinctive and well-defined landscapes of the country park and agricultural land. We maintain this view, especially given this distinction is incrementally becoming more pronounced as the park establishes. Notwithstanding this important point, what is undisputable is that by including the county park the scoring of how this land contributes to Green Belt purposes increases, given it form part of the River Cam corridor, a defining feature of the Cambridgeshire Green Belt. In the scoring for Cambridge Purpose 2 (setting), the LUC assessment specifically references the Country Park as part of the reasoning why this parcel is important to this Green Belt purpose.

• Further, much of the agricultural land within parcel TR6 is not proposed to be developed and will be retained as designated Green Belt. This is fundamental point as it will establish a wide and permanent green zone between the M11 and the development edge. Given a new Park and Ride is proposed south of the M11, in combination this would establish a permanent land use arrangement between Trumpington and Hauxton. This would not only meet the obligation that once a new Green Belt boundary is established it shouldn’t be altered at the end of the plan period, but also ensure sprawl (National Purpose 1) and encroachment (National Purpose 3) could not occur. Indeed the masterplan for Trumpington South has be configured to specifically to achieve this objective.

• It is relevant to note that the overall assessment for this parcel has determined that the level of harm is less than the surrounding land. This reflects parcel TR6 immediate relationship to the existing urban edge and the strong existing boundaries that are readily recognisable and permanent, fully in accordance with policy 143 of the NPPF. When considering the additional point highlighted above it is considered that the overall harm assessment of High for parcel TR6 should be reduced.

TMLC consider that the site has been incorrectly scored as per the points set out above and consider that it is suitable for development.

TMLC supports the aim for the proposed climate change policies to help Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks.
TMLC supports that planning is not just concerned with buildings themselves but place making, and as such has the potential to be a powerful tool in the response to the climate emergency. Achieving net zero carbon status cuts across all elements of place making; not just how homes and buildings are designed and constructed, but also by ensuring new development is located where it is or can be served by low carbon transport links, like public transport, cycling and walking.

TMLC notes the importance of ensuring new buildings are as low carbon as possible. TMLC supports the overall aims of this proposed policy.

TMLC notes the water management concerns in the region and supports the delivery of new infrastructure and the efficiently of existing water infrastructure.