Greater Cambridge Local Plan Preferred Options

The following is a summary of the of the overarching representations submitted on behalf of Endurance Estates by Barton Willmore. The full report is appended to these site-specific representations for completeness.
The First Proposals draft Plan sets out that the Greater Cambridge Partnership will seek to deliver an objectively assessed need of 58,500 jobs and 44,400 (48,800 inc. 10% buffer) homes during 2020-2041. This represents the Councils' medium+ growth scenario, with the maximum growth scenario (78,700 jobs and 56,500 homes) being discounted on the basis that it does not reflect the most likely level of jobs growth when reflecting on long-term employment patterns.
Within paragraph 5.22 of the Councils' Employment Land and Economic Development Evidence Study, it is in fact recommended that a preferred range for jobs growth would be 'between a central and higher growth scenario'.
The 'central' growth scenario represents an annual average employment growth rate of 1.1%. This is significantly below other assessments of growth for the Districts. The CPIER report quotes ONS 2010-2016 average growth rates of 2.4% and 2.3% across the City and South Cambridgeshire respectively, whilst their own 'blended rate' shows rates of 2.4% (equal to ONS) and 4.2% (significantly more than ONS).
These figures suggest that the First Proposals are not planning for sufficient employment growth and therefore not enough housing to support it.
The employment and housing growth figures for the Local Plan through to 2041 should be revised upwards substantially, in order to accommodate the demonstrable growth potential of the Districts.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). While it is acknowledged that the principle of this growth is already established through adopted development plan documents, the additional dwellings at Cambourne is proposed through the emerging GCLP and associated East West Rail.
While it is acknowledged that the Council's preferred development strategy is to utilise those edge of Cambridge sites which were previously developed, the redevelopment of both North-east Cambridge and Cambridge East poses significant challenges. North-east Cambridge requires the relocation of a sewage treatment works and existing businesses; Cambridge East requires the relocation of airport related uses and businesses. The development of these site is therefore very complex and highly likely to cause delays to delivery within the plan period and also highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The Councils' preferred development strategy also refers to speeding up housing delivery rates at some new settlements. However, there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. The Councils have not evidenced if any site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings per year over the plan period.

In order to ensure that the overall plan is deliverable, there needs to be greater certainty that sites will come forward within the plan period to deliver the growth required and, in turn, to address the under-delivery of affordable housing within Greater Cambridge. This under­ delivery is evidenced through the affordable housing contributions that have come forward on major strategic sites as follows:

• Northstowe (Phase 1and 2) - 20%

• Waterbeach - 30%

• Cambridge East - (Wing) - 30%

• Cambourne West - 30%

The development strategy should allocate some sites that are capable of delivering policy­ compliant levels of affordable housing. Land at Gazelle Way does not have infrastructure constraints and, as such, can provide policy-compliant levels of 40% affordable housing to help address the significant under-delivery in Greater Cambridge. The potential for sites like this to deliver policy compliant levels of affordable housing has been evidenced at Land north of Cherry Hinton.

It is acknowledged that the development of Land at Gazelle Way requires some release of land from the Green Belt, and that the Council have dismissed this as a preferred option as per the following conclusion:

"Whilst edge of Cambridge Green Belt sites performed in a similar way in many respects to Cambridge East, they would have significant Green Belt impacts and given the relatively good performance of Cambourne, which is not in the Green Belt and would benefit from there was considered to be no exceptional circumstances for releasing land on the edge of Cambridge to meet development needs as a matter of principle and that spatial option was not preferred."

Greater Cambridge has significant affordability issues and addressing such affordable housing needs should be a priority for the Local Plan. Allocating the land east of Gazelle Way which will deliver the affordable housing required provides justification for the release of Green Belt land, especially since this land is located sustainably and is well served by public transport as required by paragraph 742 of the NPPF when reviewing Green Belt boundaries.

Land at Gazelle Way is located on the edge of Cambridge, only three miles from the City Centre. The site benefits from existing sustainable transport infrastructure, including access to existing cycle routes and bus service provision to access surrounding local amenities and facilities, as well as convenient access into the City Centre. The site will also benefit from being located along the proposed Fulbourn Greenway route and has potential to accommodate a new train station along the Cambridge-Ipswich line. The accessibility of the site is not reliant on expensive major new infrastructure.

The development strategy needs to fully embrace and reflect the strategy for the City of Cambridge to be net zero carbon by 2030. The allocation of highly sustainable sites where housing and jobs are located together, reducing the need to travel, will be instrumental in achieving this goal. The Land at Gazelle Way is within a highly accessible location which means that new residents would not be reliant on their cars to access jobs, shops or socialise either within the Site or within the City. The vision for this site is to provide a highly sustainable community which locates homes and jobs together.

In summary, Endurance Estates wish to object to the 'high risk' nature of the development strategy, which is dependent upon the delivery of some strategic, complex sites. The development of these is highly likely to cause delays to delivery within the plan period and highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The development strategy should allocate some additional sites such as Land east of Gazelle Way that are capable of delivering policy compliant levels of affordable housing. The allocation of the site would also contribute to the Council's aspirations to become a zero-carbon authority by 2030 by offering an opportunity to be a truly sustainable community which locates homes and jobs together.

The review of the Green Belt is welcomed as there is a compelling need for Greater Cambridge to release some land from the Green Belt to provide the opportunity for sustainable development. However, the results from the 'Greater Cambridge Green Belt Assessment 2021' provide a significantly different assessment of a number of parcels of land compared to that of the Council's previous evidence (2012 Inner Green Belt Boundary Study).

The parcels of land labelled within the assessment as CHll, CHl2, CHl3, CHl4, FUl, FU19, TE6, TE7, TE8 TE9 have been assessed as either 'Very High, High and Moderate High' in terms of the level of impact that the release of these parcels for development would have.

This assessment conflicts with the Councils' previous evidence (2012 Inner Green Belt Boundary Study) whereby 'Plan 4 - Areas of Significance of Development on Green Belt', assesses the same parcels of land as either 'medium' or 'low significance'. This resulted in part of the site being the lowest significance of all the Green Belt around Cambridge. The five principles of the Green Belt as defined within the NPPF remain unchanged in the past 10 years therefore in the context of this site, it is unclear why the classification has changed, and with a much clearer and more robust justification for the change in classification needing to be provided. It is also noted that the vast majority of Green Belt parcels within the 'inner green belt area' around Cambridge have been identified as resulting in 'High­ Harm'. Such a blanket conclusion does not appear to reflect the differences in context around the city. Further clarification is needed.