Greater Cambridge Local Plan Preferred Options

The proposed Vision for Greater Cambridge is set out at page 20 of the Draft Local Plan and states that:
“We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”
Whilst Miller supports the Council’s objectives with regards to climate changes and protecting the environment, it is disappointing that the Vision as currently drafted makes no reference to the Oxford-Cambridge Arc.
The Oxford-Cambridge Arc is an area covering Oxford, Milton Keynes and Cambridge, identified by the Government as a unique opportunity to become an economic asset of international standing. In July the Government held a 12 week consultation which closed on 12 October 2021 seeking views on the vision for the Arc. The consultation document ‘Creating a vision for the Oxford-Cambridge Arc’ (July 2021) confirmed that it is still the Government’s intention to prepare a ‘Spatial Framework’, which will provide a national planning policy framework for the Arc.
As set out at paragraph 1.1 of the Government’s consultation document the Oxford- Cambridge Arc ‘is a national economic priority area’. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. As advised by the National Infrastructure Commission, without urgent action, a chronic under-supply of homes could jeopardise growth, limit access to labour and put prosperity at risk.
If the Arc to reach its full potential local authorities will need to plan positively in their areas to deliver the transformational growth required. On this basis we would suggest that the Vision is revised as follows:
“Greater Cambridge is a leading UK and global hub of innovation, which plays a key role in the internally recognised Oxford-Cambridge Arc. We want Greater Cambridge to be a place of great prosperity and innovation where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

Policy S/JH of the Draft Local Plan proposes to meet the following objectively assessed needs for development in the period 2020-2041:
•58,500 jobs
•44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year
For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.
For Greater Cambridge the housing need using the Standard Method would equate to 1743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario the modelling predicted that 78,700 jobs would be required over the plan period.
Whilst Miller is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.
We would strongly advise the Council to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.
As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the 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.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land south of Cambridge Road, Melbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and a good range of services, the development strategy as currently drafted proposes relatively limited growth around Melbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the 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.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land south of Cambridge Road, Melbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and a good range of services, the development strategy as currently drafted proposes relatively limited growth around Melbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the 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.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land south of Cambridge Road, Melbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and a good range of services, the development strategy as currently drafted proposes relatively limited growth around Melbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

It is proposed in the Draft Local Plan that the village of Melbourn remains a Minor Rural Centre rather than being upgraded to a Rural Centre.
Rural Centres are described in the adopted South Cambridgeshire Local Plan as the most sustainable villages of the district and are described as having:
“….good access to a secondary school (either within the village or accessible by good public transport), employment opportunities, a variety of services and facilities and have good public transport services to Cambridge or a market town”
In terms of population, the 2011 Census confirmed the population of Melbourn to be 4,689.
Melbourn has a wide range of services and facilities, including schools at both primary and secondary level, a health centre, a community hub, two garden centres, cafes, restaurants, takeways, pubs and two convenience stores.
In terms of promoting sustainable modes of transport, Melbourn has excellent bus links, with the Intalink 915 providing a direct hourly service to Royston and Cambridge. The village is also within a 30 minute walk/7 minute cycle of Meldreth Train Station, which is on the mainline between Cambridge and London Kings Cross. There is dedicated public footpath linking Melbourn village with the train station. Journeys by train into Cambridge are half hourly and take 16‐18 minutes. Journeys to London’s Kings Cross take approximately 1h 10m.
In addition to being within a reasonable distance of a wide range of employment opportunities in Cambridge the village has historically had a positive work population: employment ratio. This includes the Melbourn Science Park, a growing science and tech cluster, specialising in combined life sciences and engineering.
In conclusion, Melbourn scores highly on the factors assessed and should not reasonably fall within the category of Minor Rural Centre. Such villages are described as having ‘a lower level of services, facilities and employment than Rural Centres’. The high service provision, high quality public transport and the employment opportunities clearly demonstrates that Melbourn should be re-classified as a Rural Centre.

The Draft Local Plan identifies Melbourn as falling within the policy area ‘Rest of the rural area’.
As previously mentioned the Councils’ state at page 122 of the Draft Local Plan that the strategy for this area is as follows:
“…..propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted. Any development in and around villages needs to be well-designed for the rural setting, with a strong relationship to landscape”
Policy S/RRA of the Draft Local Plan sets out the site allocations in the rest of the rural area. For the entire area, which covers 3 rural centres and 12 Minor Rural Centres, the Council have identified only four sites for housing as follows:
•The Moor, Moor Lane, Melbourn – 20 homes
•Land to the west of Cambridge Road, Melbourn – 120 homes
•Land at Mansel Farm, Station Road, Oakington – 20 homes
•Land at Highfields (phase 2), Caldecote – 64 homes
The Plan states that the 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. Given its superior range of facilities and excellent public transport services to Cambridge, Miller are strongly of the view that the development strategy should be seeking to identify further growth to the north east of Melbourn, where there are opportunities to locate development close to the A10, a well-established public
transport corridor.
As shown on Figure 11 of the Draft Local Plan, the section of the A10 between Cambridge, Melbourn and Royston is identified as forming part of the Greenways programme, to encourage commuting by sustainable transport modes into Cambridge city from South Cambridgeshire villages. In June 2020 the Greater Cambridge Partnership approved plans for improvements along the route of the A10 to provide a dedicated cycleway between Cambridge and Royston.
The Site is considered worthy of being an allocation. The development of the Site is acknowledged by the Council as in keeping with the pattern of growth to the north east of Melbourn, whilst also being in close proximity to a range of services and facilities in the village itself and existing and planned public transport links to Cambridge and other centres. In accordance with national planning guidance, the inclusion of the Site will help the village to ‘thrive and grow’, whilst also ensuring a more appropriate balance of sites, specifically smaller and medium sized sites which can make an important contribution to meeting the housing requirement of an area.