Greater Cambridge Local Plan Preferred Options

We support the intention to carry forward the existing allocations for the new settlements allocated in the South Cambridgeshire Local Plan (2018) which will continue to form an important source of supply in the Greater Cambridge Local Plan. We note that a map of the boundaries of the allocations is provided at the end of the consultation document. For clarity we consider the proposed policy maps should include both the Strategic Site Boundary and the Major Development Site Boundary.
Of the three new settlement sites, Bourn Airfield is the only one not proposed to have amended annual delivery rates. Countryside consider that the annual rates for Bourn Airfield have the potential to be higher than previously stated due to the mix of tenures which has been agreed within the outline. Providing a broad mix of tenures across the sites will allow the delivery of a wide range of housing products which can be delivered without competing with each other.
It is considered that the Bourn Airfield new village has the potential to deliver the following housing trajectory: 2021/2022 – 0, 2022/2023 – 0, 2023/2024 – 35, 2024/2025 – 160, 2025/2026 – 190, with 190 housing completions per annum thereafter.

Whilst the spirit of the policy is supported, concern is raised regarding certain elements of the current proposed policy direction.
The current policy direction seems somewhat contradictory stating in one bullet that seemingly all trees should be protected (no matter what their value), whilst another suggests only trees of value (as measured by a recognised tool such as iTree) should be protected. In any event it is considered additional flexibility should be introduced to allow for instances where trees are required to be removed due to disease, age or safety concerns which renders their retention inappropriate. Flexibility should also be allowed for where in some instances the removal of trees, in whole or part, is required in order for the development to be brought forward and this loss should be weighed against the benefits of the proposals.
Furthermore the necessity of stipulating a recognised tool such as iTree is questioned. Assessment should be undertaken in accordance with relevant professional guidance and supported by tools as appropriate. Further detail is not considered necessary or justified.

Countryside are supportive of the aspiration to achieve high quality design through development which accords with its own ethos and approach to development. The following minor points requiring clarification are however raised:
• the need to successfully integrate waste, recycling and parking is referenced twice in the policy under ‘climate-positive’ and ‘local character’ which does not need to be repeated under the same policy.
• Clarification should be provided within the policy as to what is regarded as ‘significantly taller’ to understand when additional assessment will be required.

The approach to high quality landscape and public realm is supported. A minor comment is made on the last bullet point of the policy, which sets out the need to ‘provide appropriate types of open space whether in urban or more rural places that link into other sequences of existing or new landscape spaces and wider settings’. It is queried how the measure of ‘appropriate’ will be tested and applied given the significant prospects of variety in how this term is applied.

Countryside support the approach under this policy to take account of the current and likely future trend for working at home, largely as a result of the COVID-19 pandemic. The Bourn Airfield proposals will make appropriate provision to achieving the objectives of this policy through the provision of co-working space and provision of fibre broadband to all homes.

Countryside are supportive of the approach to this policy in that housing mix ‘recommendations’ are provided, along with these being set out as a ‘range’. This is a positive format for the housing mix policy by providing flexibility which will allow the development at Bourn Airfield to respond to changing market conditions and requirements.

Build to Rent (BTR) Homes are an important housing model for diversifying the housing market as has been recognised by the Government through the NPPF and PPG and there is a requirement to plan positively for rented homes in Local Plans. The inclusion of a policy specifically addressing this form of development is therefore supported. BTR expands residents’ access to, and choice of, good quality housing, helping affordability in the widest sense.
BTR is different from the existing private rented sector offer through the professional management and longer tenancies for those who want them of high-quality, purpose-built homes. It is important to recognise that whilst the BTR sector may have initially been focused on town/city centre developments of apartments the model has diversified to include all types of homes including family homes. BTR can also increase the overall supply and accelerate the construction of new homes due to the different market it serves.
Countryside recognise the important role that the BTR sector can play as part of the overall mix of housing to be provided at Bourn Airfield which will include a policy compliant 40% affordable housing. It is considered that the provision of BTR will further broaden the appeal of living as part of a new community by widening the choices available and will assist in bringing forward the proposed development more swiftly than originally envisaged by the Council.
The PPG provides the following guidance to LPAs in preparing Local Plans which consider BTR: “As part of their plan making process, local planning authorities should use a local housing need assessment to take into account the need for a range of housing types and tenures in their area including provisions for those who wish to rent. Specific demographic data is available on open data communities which can be used to inform this process. The assessment will enable an evidence-based planning judgement to be made about the need for build to rent homes in the area, and how it can meet the housing needs of different demographic and social groups. If a need is identified, authorities should include a plan policy setting out their approach to promoting and accommodating build to rent. This should recognise the circumstances and locations where build to rent developments will be encouraged – for example as part of large sites and/or a town-centre regeneration area.” Paragraph: 001 Reference ID: 60-001-20180913
The PPG is therefore clear that the onus is on LPAs to consider how BTR can meet housing needs and create mixed and balanced communities. Concern is therefore raised that the proposed policy direction seemingly seeks to direct this requirement on to the applicant rather than being considered in a Plan led manner. It is considered there is a clear and evidenced need for BTR provision in the Greater Cambridge area and therefore the Local Plan should be positively planning to support this as part of a diversified housing market.
The proposed policy direction also seeks to seemingly restrict how much BTR could be brought forwards, although a decision on the exact quantum is deferred for later stages of plan-making. Concern is raised regarding this proposed approach. Whilst we understand from the supporting text that the Council are concerned that the provision of a significant quantum of BTR would result in a reduction in the level of the overall affordable housing delivery (as BTR would likely be subject to a 20% affordable housing requirement rather than the 40% of general market housing locally) it is necessary to consider the needs for all forms of housing. Although no quantum is proposed at this stage, it is noted that the draft North East Cambridge Area Action Plan (AAP) proposes a restriction of no more than 10% of the total housing across the AAP being BTR. Importantly the AAP is only in draft and we are unaware of any similar restrictions being successfully introduced elsewhere in the country. Clearly no such restriction could be applied to other forms of private rented accommodation by private landlords. It is therefore considered such an approach is unjustified.
A variety of business models will exist for the provision of BTR and therefore flexibility should be allowed within the final policy wording to reflect this. It should be noted that Countryside will deliver BTR on Bourn Airfield whilst also delivering a 40% policy compliant level of affordable housing.

Countryside support the principle of the proposed policy and the aspirations it seeks to achieve. It will be important that the policy wording allows sufficient flexibility to respond to changing travel habits and technologies over the course of the Plan period. It is also important that the policy allows for changes in requirements depending on the location of developments and the availability of alternative modes of travel, existing cycle provision etc. These are all key considerations in relation to the delivery of the Bourn Airfield proposals and will be used to inform the development of the reserved matters applications following the grant of outline planning permission.

Whilst we support the aspirations of the policy and Countryside recognise the importance of the necessary digital infrastructure to support new developments, it is important that the eventual policy wording recognises to what degree these elements are under the control of the developer themselves as opposed to statutory undertakers etc.

Countryside fully supports the strategic commitment by the GCLP to positively address the issue of climate change mitigation and adaptation within the plan period and welcome the opportunity to comment on the draft policies to ensure they evolve to meet the tests of soundness and are both deliverable and viable whilst supporting the delivery of much needed high quality, private and affordable homes within Greater Cambridge.
Bourn Airfield already benefits from a recommendation for outline planning permission and is supported by a strong sustainability strategy that deploys extensive renewable energy technologies across the development.
Countryside supports the emphasis placed on responding positively and proactively to climate change in the Greater Cambridge Local Plan (GCLP). This aligns closely with Countryside’s own ambitions for their business operations and future development sites.
Countryside recognises the recently published findings by the International Panel on Climate Change (IPCC), which makes clear that the chances of crossing the global warming level of 1.5°C in the next few decades is likely unless immediate, rapid and large-scale action is taken.
To ensure Countryside plays its part, the company has recently published its Corporate Strategy ‘Path Finder – Marking Out the Route to Net Zero’ which sets out the company’s strategy to achieving net zero. As part of this strategy Countryside have set science-based carbon targets which have been verified by the Science Based Carbon Institute, and are to:
• Reduce our absolute Scope 1 and 2 emissions by 42% by 2030
• Reduce our Scope 3 emissions by 52% per sqm built by 2030
The GCLP Plan, and its emphasis on climate, will also play a very important role in meeting the challenges put forward by the IPCC. It is important to note that in meeting its net zero ambitions, one of the most important steps that the GCLP can take is to ensure that its spatial distribution strategy directs growth to locations that are sustainable and help to facilitate reductions in GHG emissions by reducing the need to travel by private car for work and leisure.
As a general theme, Countryside support the strategic objectives of the policy but note that the targets presented within the GCLP will introduce some of the highest sustainability standards in the UK at a time when the housebuilding industry is already responding at pace to the introduction of the Governments Future Homes Standard.
Given the volume of new homes required within Greater Cambridge there is a risk that the introduction of these standards will restrict the delivery of new homes particularly given that the supply chain is currently not able to deliver these standards at volume. These challenges will also be particularly acute for smaller housebuilders which may further restrict delivery and diversity within the market.
Whilst Countryside note the ambition of the GCLP, it is important that the sustainability policies do not restrict the delivery of much needed new private and affordable housing across the county. To meet the requirements of the National Planning Policy Framework, these policies must be supported by a robust evidence base and viability assessment that demonstrates these policies and targets are deliverable.
Countryside have reviewed each of the draft policies within the climate change section of the GCLP and have provided representations for each policy which we hope is of assistance to the Greater Cambridge Shared Planning authorities. Our focus is to ensure that each policy is both viable and deliverable whilst facilitating a shared objective of delivering more high quality affordable and private homes in an area with current and growing demand.
Where necessary these representations make reference to the GCLP Climate Change Topic Paper which summarises the evidence to support each of the policies and is hereafter referred to as the Topic Paper.
For draft Policy CC/ NZ, we have also reviewed the evidence base supporting these specific policies which is the Greater Cambridge Net Zero Carbon Evidence Base Non-Technical Summary and which is hereafter referred to as the Evidence Base document. Unfortunately a more detailed review of the full evidence is not possible as only the non-technical summary has been published and therefore Countryside reserve the right to amend our representations once this material has been reviewed.
Countryside welcome the opportunity to comment on these draft policies and would be happy to discuss our comments in greater detail with the authorities. We also recognise that these are currently policy options which will be informed by consultation feedback. Countryside look forward to reviewing the next iteration of the draft GCLP.