Greater Cambridge Local Plan Preferred Options
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Greater Cambridge Local Plan Preferred Options
S/JH: New jobs and homes
Representation ID: 60623
Received: 13/12/2021
Respondent: NIAB Trust - Girton site
Agent: Strutt & Parker
Summary: Land east of Redgate Road, Girton (HELAA site 40241)
We agree that it is very important that housing delivery keeps up for demand for increased jobs within the area.
It is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. 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, in line with the ‘maximum’ growth forecast, 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.
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 focus for housing and employment growth with associated infrastructure.
QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?
We agree 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.
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. 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, in line with the ‘maximum’ growth forecast, 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 focus for housing and employment growth with associated infrastructure.
Concern is also expressed in relation to the types of sites which have been allocated. 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 their Local Plan being withdrawn.
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.
Comment
Greater Cambridge Local Plan Preferred Options
S/DS: Development strategy
Representation ID: 60624
Received: 13/12/2021
Respondent: NIAB Trust - Girton site
Agent: Strutt & Parker
Land east of Redgate Road, Girton (HELAA site 40241)
In principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. Also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.
Girton is a Minor Rural Centre (as defined within the adopted Local Plan) which benefits from both Girton Glebe Primary School and Girton Nursey and Pre-School, and a large range of facilities, including shops, pubs, restaurants and community facilities.
It is considered that this limited additional growth within Girton would be consistent with the objectives of the Local Plan, which seeks to minimise car travel.
QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?
Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear within paragraph 79 of the National Planning Policy Framework (NPPF) that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.
The CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. The proposed Cambridge South Station proposes significant sustainable transport improvements between Cambridge and Meldreth Station, which is within walking distance to Melbourn.
The site at Redgate Road is located in a sustainable area, with the development not overly reliant on car travel, with many public transport options easily accessible. Girton is a Minor Rural Centre (as defined within the adopted Local Plan) which benefits from both Girton Glebe Primary School and Girton Nursey and Pre-School, and a large range of facilities, including shops, pubs, restaurants and community facilities.
The release of the site from the Green Belt would facilitate the creation of a cycleway/footway that could link into the Darwin Green development to the south, on the opposite side of the A14. It is proposed that as part of any development of the site, of any size, a cycleway/footway route connecting Girton to Cambridge to the south would be incorporated and provide an improved linkage over the A14 and directly to the existing cycle and pedestrian links within Cambridge. This would further encourage a shift away from car use and towards more sustainable modes of transport.
It is considered that this limited additional growth within Girton would be consistent with the objectives of the Local Plan, which seeks to minimise car travel. The site would easily integrate into the existing built form of the settlement and relate to the housing development to the west.
Comment
Greater Cambridge Local Plan Preferred Options
S/DS: Development strategy
Representation ID: 60625
Received: 13/12/2021
Respondent: NIAB Trust - Girton site
Agent: Strutt & Parker
Land east of Redgate Road, Girton (HELAA site 40241)
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations. The findings of the Inspector in the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
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. 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.
QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?
We agree 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.
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. 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, in line with the ‘maximum’ growth forecast, 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 focus for housing and employment growth with associated infrastructure.
Concern is also expressed in relation to the types of sites which have been allocated. 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 their Local Plan being withdrawn.
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.
Comment
Greater Cambridge Local Plan Preferred Options
S/CBC: Cambridge Biomedical Campus (including Addenbrooke's Hospital)
Representation ID: 60626
Received: 13/12/2021
Respondent: NIAB Trust - Girton site
Agent: Strutt & Parker
We strongly 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 that new housing growth is located in areas with sustainable transport links to the Campus.
QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?
We strongly 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 that new housing growth is located in areas with sustainable transport links to the Campus.
The site is within half an hour cycling distance of the Campus and bus links are also available. It is considered important that substantial housing growth is provided in close proximity to the Biomedical Campus to support its growth and so it can be accessed by sustainable transport means. Therefore, growth in Girton would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure.
Comment
Greater Cambridge Local Plan Preferred Options
S/RRA: Allocations in the rest of the rural area
Representation ID: 60627
Received: 13/12/2021
Respondent: NIAB Trust - Girton site
Agent: Strutt & Parker
An extremely small number of small to medium sized allocations have been identified with very little new growth proposed in rural communities. This is likely to result in the proposed growth having little impact on housing affordability.
It is worth noting that the St Albans Local Plan was withdrawn following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations. The findings of the Inspector in the examination of the Uttlesford Local Plan were very similar and also resulted in the local plan being withdrawn.
The current approach to allocating only a very limited number of larger sites is not considered to be sound. In particular, it is considered that additional growth should be provided within the most sustainable villages, such as Girton.
The additional housing will allow people to live closer to work thus reducing car travel and increase employment opportunities. Additional housing would also contribute towards the local economy through spending on local provisions.
QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?
It is acknowledged that the proposed strategy focuses on locating new development in and around Cambridge City, growing existing new settlements and a small degree in the rural southern clusters. An extremely small number of small to medium sized allocations have been identified with very little new growth proposed in rural communities. This is likely to result in the proposed growth having little impact on housing affordability.
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.
As set out above, the current approach to allocating only a very limited number of larger sites is not considered to be sound in its current form. In particular, it is considered that additional growth should be provided within the most sustainable villages, such as Girton.
It is considered that the provision for increasing the range of sites modestly 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 securing affordable housing more immediately. 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).
It is not clear why the Shared Planning Service have deviated from a clear recommendation provided by the Planning Inspectorate.
However, it is also important to acknowledge the employment sites/areas in Girton which will benefit from increased housing provision. The additional housing will allow people to live closer to work thus reducing car travel and increase employment opportunities. Additional housing would also contribute towards the local economy through spending on local provisions.
Comment
Greater Cambridge Local Plan Preferred Options
S/RRA: Allocations in the rest of the rural area
Representation ID: 60628
Received: 13/12/2021
Respondent: NIAB Trust - Girton site
Agent: Strutt & Parker
Land East of Redgate Road, Girton (HELAA site 40241)
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.
Land East of Redgate Road, Girton should be allocated for development and would be a sound allocation as part of the emerging Local Plan. We have also demonstrated that the site could be delivered without any adverse impacts on landscape.
This representation has been prepared by Strutt & Parker on behalf of NIAB Trust to support the promotion of land to the East of Redgate Road, Girton as part of the Greater Cambridge First Proposals Consultation 2021.
In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA), which provided an initial assessment of the sites put forward for consideration for allocation as part of the Call for Sites consultations within Greater Cambridge.
This representation provides a response to the ‘First Proposals’ Preferred Options Consultation and has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Proforma for the site.
The HELAA excludes the land East of Redgate Road site from allocation primarily on the basis of landscape issues, notably that the proposed development would impact the rural character of the surrounding landscape.
The site covers an area of approximately 0.94ha and is able to accommodate 28 dwellings, associated access and landscaping. Additionally, there is an opportunity to provide a new pedestrian/cycleway link over the existing A14 crossover. This new link would provide a sustainable transport link which could even reduce overall pressure on the Strategic Road Network. It is noted that the NIAB Trust has also put forward two other sites at Park Farm (Villa Road and Land West of South Road).
It is considered that several of the assessment criteria, should be re-categorised. It has been demonstrated in the supporting information provided that the allocation of this site would not have a significant adverse impact and should be considered as a suitable, achievable and deliverable site for housing and should therefore be put forward for allocation in the emerging Local Plan.
In support of this report, the following document has been prepared;
• Prospective Site Feasibility Study, produced by pHp architects.
QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?
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. NIAB Trust are responsible for the promotion of the land East of Redgate Road, Girton, and have a track record of delivering high quality developments. NIAB Trust are fully committed, to engagement with the GCSPS and Girton Parish Council regarding the mix and type of housing to be delivered on land East of Redgate Road, Girton. The site also has the potential to provide open space to serve the new and wider local community and would trigger contributions towards improvements towards local facilities.
QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?
Yes, Land East of Redgate Road, Girton should be allocated for development and would be a sound allocation as part of the emerging Local Plan. The Land East of Redgate Road, Girton site was promoted originally at Call for Sites stage. We have also demonstrated that the site could be delivered without any adverse impacts on landscape.