Greater Cambridge Local Plan Preferred Options
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Greater Cambridge Local Plan Preferred Options
STRATEGY
Representation ID: 59019
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
We support the seven main aims for the Local Plan that focus on: climate change, biodiversity and green space, wellbeing and social inclusion, great places, jobs, homes and infrastructure.
We support the seven main aims for the Local Plan that focus on: climate change, biodiversity and green space, wellbeing and social inclusion, great places, jobs, homes and infrastructure.
Comment
Greater Cambridge Local Plan Preferred Options
How much development and where?
Representation ID: 59032
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
We have strong concerns that the level of employment growth forecasted and the supply of homes proposed is not high enough and not best located.
The Councils’ development strategy relies heavily on development at Cambourne and in Cambridge’s urban area, as well as existing new settlements. This creates an inflexible development strategy that is unable to respond to faster/higher growth rates. It provides little contingency if any of the sites are stalled or slow to build out and does little to distribute growth to meet the needs of the area – particularly towards the eastern side of the plan area.
We have strong concerns that the level of employment growth forecasted and the supply of homes proposed is not high enough and not best located.
The Councils’ development strategy relies heavily on development at Cambourne and in Cambridge’s urban area, as well as existing new settlements. This creates an inflexible development strategy that is unable to respond to faster/higher growth rates. It provides little contingency if any of the sites are stalled or slow to build out and does little to distribute growth to meet the needs of the area – particularly towards the eastern side of the plan area.
Comment
Greater Cambridge Local Plan Preferred Options
S/JH: New jobs and homes
Representation ID: 59075
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
Summary: Land to the north, east and south of Six Mile Bottom (HELAA site 40078)
Greater Cambridge experienced a growth rate over 1% higher between 2010 and 2016 than the employment growth which is relied on in the First Proposals document. Our review of the evidence shows that the higher growth scenario is achievable and the chosen medium+ growth scenario falls significantly short of the growth potential of the area and fails to align with the aim of doubling GVA by 2042 through the city deal. As a result, further allocations will be needed and our promoted site at Westley Green (no. 40078) offers a significant opportunity to plug the gap in the development strategy.
Greater Cambridge experienced a growth rate over 1% higher between 2010 and 2016 than the employment growth which is relied on in the First Proposals document. Our review of the evidence shows that the higher growth scenario is achievable and the chosen medium+ growth scenario falls significantly short of the growth potential of the area and fails to align with the aim of doubling GVA by 2042 through the city deal. As a result, further allocations will be needed and our promoted site at Westley Green (no. 40078) offers a significant opportunity to plug the gap in the development strategy.
Comment
Greater Cambridge Local Plan Preferred Options
S/DS: Development strategy
Representation ID: 59082
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
Land to north/ south/ east of Six Mile Bottom, aka Westley Green (HELAA site 40078)
The development strategy does not provide a wide range of homes and jobs and is heavily reliant on commuting to Cambridge and high density living environments and risks not meeting the needs for all, for example for family housing.
In the case of NEC and Additional Cambourne, there is reliance on other consenting processes which in itself adds greater risk and uncertainty to deliverability. The strategy therefore needs to focus on strategic sites like Westley Green that are more deliverable and can facilitate more sustainable movements near to major employment locations to the east and southeast of Cambridge.
The development strategy does not provide a wide range of homes and jobs and is heavily reliant on commuting to Cambridge and high density living environments and risks not meeting the needs for all, for example for family housing.
In the case of NEC and Additional Cambourne, there is reliance on other consenting processes which in itself adds greater risk and uncertainty to deliverability. The strategy therefore needs to focus on strategic sites like Westley Green that are more deliverable and can facilitate more sustainable movements near to major employment locations to the east and southeast of Cambridge.
Comment
Greater Cambridge Local Plan Preferred Options
S/NEC: North east Cambridge
Representation ID: 59091
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
We are of the view that the quantum of development is far too high for the size of the area allocated for housing and the various site constraints.
This gives rise to significant challenges in terms of townscape impacts, biodiversity net gain, sustainable drainage, open space provision and transport mitigation.
Furthermore, the remediation of the site and DCO process is likely to negatively impact on delivery timescales and affordable housing provision.
We are of the view that the quantum of development is far too high for the size of the area allocated for housing and the various site constraints.
This gives rise to significant challenges in terms of townscape impacts, biodiversity net gain, sustainable drainage, open space provision and transport mitigation.
Furthermore, the remediation of the site and DCO process is likely to negatively impact on delivery timescales and affordable housing provision.
Comment
Greater Cambridge Local Plan Preferred Options
S/CB: Cambourne
Representation ID: 59097
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
There is currently no clarity from government on whether the full East West rail route will be funded following the Budget. Furthermore, there is no mention in the S/CB Policy commentary of consultation with the East West Rail Company or comfort around their timetable for delivery. In the absence of this and potential delay to approval of the both the routing of the railway and the new station, the Local Plan should look elsewhere in the plan area for a strategic growth location that can deliver more readily without dependency on upfront major infrastructure delivery.
There is currently no clarity from government on whether the full East West rail route will be funded following the Budget. Furthermore, there is no mention in the S/CB Policy commentary of consultation with the East West Rail Company or comfort around their timetable for delivery. In the absence of this and potential delay to approval of the both the routing of the railway and the new station, the Local Plan should look elsewhere in the plan area for a strategic growth location that can deliver more readily without dependency on upfront major infrastructure delivery.
Comment
Greater Cambridge Local Plan Preferred Options
S/NS: Existing new settlements
Representation ID: 59104
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
The draft policy assumes that annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on; however, we question whether the required infrastructure is able to keep pace with these increased delivery rates especially as there is a trip budget at Waterbeach.
Once these thresholds are met, it is highly likely that the dualling of the A10 will be required to unlock further development. At present there is no certainty over build programme. Similar concerns exist in terms of wastewater infrastructure delivery and the relocation of Milton Sewage Works.
The draft policy assumes that annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on; however, we question whether the required infrastructure is able to keep pace with these increased delivery rates especially as there is a trip budget at Waterbeach.
Once these thresholds are met, it is highly likely that the dualling of the A10 will be required to unlock further development. At present there is no certainty over build programme. Similar concerns exist in terms of wastewater infrastructure delivery and the relocation of Milton Sewage Works.
Comment
Greater Cambridge Local Plan Preferred Options
The rural southern cluster
Representation ID: 59118
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
Six Mile Bottom (HELAA site 40078)
We have responded to the issues raised in the HELAA rejected Site No. 40078 (Six Mile Bottom) and set out how this site will meet the objectives of the Local Plan through the following accompanying documents:
• Westley Green Strategic Case For Development
• Housing and Employment Forecasts for Greater Cambridge
• Sustainable Transport and Connectivity Strategy
• Health and Wellbeing Strategy
• Climate Change Strategy
We have responded to the issues raised in the HELAA rejected Site No. 40078 (Six Mile Bottom) and set out how this site will meet the objectives of the Local Plan through the following accompanying documents:
• Westley Green Strategic Case For Development
• Housing and Employment Forecasts for Greater Cambridge
• Sustainable Transport and Connectivity Strategy
• Health and Wellbeing Strategy
• Climate Change Strategy
Comment
Greater Cambridge Local Plan Preferred Options
BG/BG: Biodiversity and geodiversity
Representation ID: 59124
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
The need for biodiversity net gain (BNG) is supported but we have concerns that the proposed 20% net gain requirement has not been fully tested in the Council’s development viability appraisal. The First Proposals Viability Report assumes separate costs for greenfield and brownfield developments that will deliver 20% BNG on site. However, there will be several sites that cannot achieve this level of net gain on site and will require higher cost assumptions for off-site delivery. It is also not clear how the report has costed off-site delivery S106 contributions.
The need for biodiversity net gain (BNG) is supported but we have concerns that the proposed 20% net gain requirement has not been fully tested in the Council’s development viability appraisal. The First Proposals Viability Report assumes separate costs for greenfield and brownfield developments that will deliver 20% BNG on site. However, there will be several sites that cannot achieve this level of net gain on site and will require higher cost assumptions for off-site delivery. It is also not clear how the report has costed off-site delivery S106 contributions.
Comment
Greater Cambridge Local Plan Preferred Options
Sustainability Appraisal
Representation ID: 59135
Received: 13/12/2021
Respondent: L&Q Estates Limited and Hill Residential Limited
Agent: Barton Willmore
The SA would benefit from additional consideration and clarity as the Plan progresses. Areas for improvement include:
i. Confirmation of why updates to policy and Government strategy do not require alterations to the Sustainability Framework;
ii. Baseline data should reflect the latest available datasets.;
iii. Further clarification on how mitigation measures have been factored in to scoring the reasonable alternatives;
iv. For climate change mitigation, consideration of whole life carbon in developments, ecosystem services and reduction in travel should all be considered alongside the “hard” measures focused on energy efficiency in buildings and low carbon energy sources
The SA would benefit from additional consideration and clarity as the Plan progresses. Areas for improvement include:
i. Confirmation of why updates to policy and Government strategy do not require alterations to the Sustainability Framework;
ii. Baseline data should reflect the latest available datasets.;
iii. Further clarification on how mitigation measures have been factored in to scoring the reasonable alternatives;
iv. For climate change mitigation, consideration of whole life carbon in developments, ecosystem services and reduction in travel should all be considered alongside the “hard” measures focused on energy efficiency in buildings and low carbon energy sources
