Greater Cambridge Local Plan Preferred Options

Overall, we do not believe that the Councils are planning for enough growth. We also have concerns at the lack of new planned commercial space, as highlighted in the appended evidence report by Savills.
Policy S/JH is the first strategic policy within the Local Plan and sets out the total number of jobs and homes proposed over the plan period.
We agree with the supporting text for this policy, that it is very important that housing delivery keeps up for demand for increased jobs within the area.
As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan. As set out in paragraphs 5.2-5.4 below, over reliance on large scale, strategic, and importantly complex sites, is contrary to policy in the NPPF 2021, and an approach which spreads growth more evenly, with less associated risk, is urged.
The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.
Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. The Local plan sets out a projection for 1.1% growth, whereas CPIER recommends 2.4% growth and ONS recommends 4.2% growth. Accordingly, it is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.
The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox- Cam Arc as a centre for housing and employment growth.
Further information on this, is set out within a further report that has been completed by Barton Willmore on behalf of Endurance Estates, in relation to a number of sites that are being promoted by Endurance as part of the emerging Local Plan.

The Council’s over-reliance on a few major sites (and critically the complex nature of some), we believe, is flawed and likely to result in delivery challenges.
As such, we think it would be prudent for the Councils to allocate more sites in a variety of locations for a wider range of housing. Additional allocations in the villages will help in this regard, as would less complex/constrained sites closer to Cambridge.
Policy S/DS states that the proposed development strategy for Greater Cambridge is to direct development to where it will have the least climate impact and where active and public transport is the natural choice.
In general, we support the principle of focusing development on sites 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. In relation to minimising car travel, this needs to be considered holistically along with a number of other competing objectives, and provision for car travel is not the only criteria to consider when selecting the most appropriate sites to allocate. It is also very important that due regard is given to the national policy and the three objectives of sustainable development set out in the NPPF 2021 (economic, social and environmental). This means allocating land for development to ensure choice and competition for market land, along with ensuring growth to ensure vitality of villages. Growth within villages can also assist with meeting localised housing need (particularly for affordable housing), which will not be met by a small number of strategic allocations around the largest settlements. In accordance with national policy it is also important that where possible growth is directed to sites that are situated outside of the Cambridge Green Belt.
In this regard, it is also important that a suitable level for growth is directed to the villages within South Cambridgeshire. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. This, however, has not been reflected within the First Proposals within the Local Plan, with minimal allocations within the villages of South Cambridgeshire.
It is suggested that the provision for increasing the range of sites to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and secure affordable housing more immediately and more reliably. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report.
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).
Accounting for the clear recommendations from the Planning Inspector on the 2018 Local Plan, it is not clear why this strategy has not been followed as part of the First Proposals.
Orwell, benefits from being a sustainable settlement in its own right. Orwell is a Group Village (as defined within the adopted Local Plan) that is not situated within the Green Belt. It benefits from primary education facilities, and a range of services, including shops, a pub, and community facilities.
Orwell has a very tightly drawn Development Framework which has remained unaltered since 2003. This does not allow for any windfall development. Orwell did not receive any allocations within the 2018 Local Plan and therefore provision for additional growth as part of the Local Plan 2041 would be appropriate and assist with maintaining viability and vibrancy of the village and meeting identified affordable housing need within Orwell.
For the above reasons, it is considered that the distribution of growth needs to be revisited and that the First Proposals are unsound in their current form. Whilst, clearly allocations that seek to minimise car travel has significant benefits, this should not be the only factor that dictates the most appropriate locations for new housing and employment development. In this regard, policy S/DS is not in accordance with national policy and it is not considered to be justified or effective in its current form.

Policy S/SB relates to Settlement Boundaries. Details of settlement boundaries have not been provided at this stage but are to be drawn on the Policies Map that will accompany the draft Local Plan for consultation. The Greater Cambridge Local Plan Topic Paper 1: Strategy explains: “Defining settlement boundaries (previously known as development frameworks) is necessary to ensure that the countryside is protected from gradual encroachment, but in particular they help guard against incremental growth in unsustainable locations”.
This approach is considered to be overly restrictive and does not accord with paragraph’s 69 and 79 of the NPPF, which states that housing should be located where it will enhance or maintain the vitality of rural communities and that small and medium sized sites can make an important contribution towards housing. . This policy direction should not preclude growth in sustainable locations, which may include sites well related to settlements but previously outside of settlement boundaries. It is noted that in the past settlement boundaries have been drawn to tightly, and do not provide for many (if any) windfall opportunities.
The settlement boundary for Orwell were last reviewed some time before the Adopted Proposals Map Published January 2010. The tight settlement boundary has artificially constrained development in a village which has a good range of services and facilities. Not allowing sufficient land within settlement boundaries for windfall sites is contrary to Paragraph 69 c) of the NPPF. The south-east side of site 40496 abuts Orwell’s settlement boundary. It is considered that the site would form a logical extension to Orwell, resulting in a site that is well related to the existing village, and that would not create amenity issues for existing residential properties.

We agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new local plan. To support this objective, it is imperative therefore that new housing growth is located within areas that are accessible to the Biomedical Campus. In this regard Orwell is within ease of commuting distance to the Biomedical Campus, with ease of access from the south- west side of Cambridge. Orwell also benefits from good transport connectivity to the proposed Cambridge South Station on the Biomedical Campus, via Shepreth, which is a short cycle from Orwell.

It is also very important that the emerging Local Plan 2041 aligns housing and employment growth, with major transport schemes that are being promoted in and around Cambridge. The First Proposals provide a number of references to East- West Rail and the provision for Cambridge South Station, both of which are important new transport infrastructure projects. It is considered important that substantial housing growth is provided within the villages to the south east of Cambridge which will benefit from these new transport links and will ensure ease of access to the Biomedical Campus by sustainable transport means.

The supporting text for policies S/RRA and S/RRP states that the GCSPS wants rural villages to thrive and sustain their local services. However, this unfortunately has not been reflected within policy S/RRA or Policy S/RRP, which proposes a very limited number of allocations. In addition, the vast majority villages have had no growth allocated to them at all, which will not assist in thriving or sustaining rural services, nor meet local housing need.
For reasons outlined above within section 3 we consider that the strategy needs to be revised, to include appropriate distribution of growth in the villages. In particular, this additional growth should be focused on sustainable villages, such as Orwell, which benefit from a range of services and are located outside of the Cambridge Green Belt.
The proposed strategy for growth is considered to be over reliant on a few large sites, with which there are associated risks in relation to delivery. The larger sites are particularly complicated in of the infrastructure requirements, associated with the early stages of delivery. As required by the NPPF 2021, a more balanced approach is urged, which spreads growth more evenly, reducing risk, providing choice and competition for market land, and providing more homes where they are needed.
It is worth noting that recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in the local plan being withdrawn.
Accounting for the recent decisions on the St Albans and Uttlesford Local Plans, it is unclear why the GCSPS appear to be adopting a similar approach. The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.
It is important that a range of housing, jobs and facilities are provided within villages as part of new allocations to allow them to thrive and remain vibrant. Endurance Estates are responsible for the promotion of Land Rear of Fisher’s Lane, Orwell and have a track record of promoting high quality housing developments and setting clear parameters for future housebuilders. Endurance Estates are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Orwell Parish Council regarding the mix and type of housing to be delivered on Land Rear of Fisher’s Lane, Orwell. The proposals also include the provision for the delivery of an area of public open space.

The supporting text for policies S/RRA and S/RRP states that the GCSPS wants rural villages to thrive and sustain their local services. However, this unfortunately has not been reflected within policy S/RRA or Policy S/RRP, which proposes a very limited number of allocations. In addition, the vast majority villages have had no growth allocated to them at all, which will not assist in thriving or sustaining rural services, nor meet local housing need.
For reasons outlined above within section 3 we consider that the strategy needs to be revised, to include appropriate distribution of growth in the villages. In particular, this additional growth should be focused on sustainable villages, such as Orwell, which benefit from a range of services and are located outside of the Cambridge Green Belt.
The proposed strategy for growth is considered to be over reliant on a few large sites, with which there are associated risks in relation to delivery. The larger sites are particularly complicated in of the infrastructure requirements, associated with the early stages of delivery. As required by the NPPF 2021, a more balanced approach is urged, which spreads growth more evenly, reducing risk, providing choice and competition for market land, and providing more homes where they are needed.
It is worth noting that recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in the local plan being withdrawn.
Accounting for the recent decisions on the St Albans and Uttlesford Local Plans, it is unclear why the GCSPS appear to be adopting a similar approach. The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.
It is important that a range of housing, jobs and facilities are provided within villages as part of new allocations to allow them to thrive and remain vibrant. Endurance Estates are responsible for the promotion of Land Rear of Fisher’s Lane, Orwell and have a track record of promoting high quality housing developments and setting clear parameters for future housebuilders. Endurance Estates are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Orwell Parish Council regarding the mix and type of housing to be delivered on Land Rear of Fisher’s Lane, Orwell. The proposals also include the provision for the delivery of an area of public open space.