Greater Cambridge Local Plan Preferred Options

Policy S/CB: Cambourne

3.1. Cambourne is a location where housing and employment already exist and where there is supporting community infrastructure in terms of shops, schools and other services. There is, however, significant potential to add to the range of uses located at Cambourne in a highly sustainable way, including new leisure, employment and homes enabling more residents to both live and work there and thereby increasing self-containment and correspondingly reducing the need to travel. Our evidence shows that, by increasing self-containment and extending existing and proposed public transport, there is the opportunity to add significant levels of employment and housing to the north of Cambourne without impacting on overall levels of car-based journeys .
3.2. We note that whilst there was no specific consultation on the issue of development at Cambourne in the First Conversation consultation, the Councils did ask for views about focusing development on transport corridors. In the consultation response to the First Conversation there was broad support for this approach, and for focusing development at public transport nodes.
3.3. Further to this, development around Cambourne formed a core part of ‘Strategic Spatial Option 8: Growth around Transport Nodes: Western Cluster’. Stakeholder workshops identified the benefits of matching jobs and homes with planned infrastructure around the EWR station and Greater Cambridge Partnership Cambourne to Cambridge Public Transport Project.
3.4. The First Proposals consultation document acknowledges that EWR means that Cambourne will be one of the best-connected places in the region, although the location of the new station is ‘yet to be resolved’. Nevertheless, we know from the EWR 2021 consultation that the preferred option for the route and a station to serve Cambourne is on MGH land, to the north of the A428. EWR has said, in support of this emerging preference (Route Alignment 9), “we believe that there is more potential for new homes and communities in the area (particularly for North Cambourne compared to Cambourne South)” and identify that the route can support more jobs and prosperity, as well as being cost-effective.
3.5. Savills and MGH have actively engaged in the EWR Consultation that took place earlier in 2021. We have shared with the EWR team our masterplans and details of the optioned land, which was previously submitted in the Call for Sites. We have also confirmed that we understand there is a need to re-appraise the masterplans in light of the preferred option to position a station at North Cambourne.
3.6. We have confirmed to the EWR team that MGH is fully supportive of the proposed alignment, due to the benefits for Cambourne, as acknowledged in the First Proposals consultation. In addition, MGH is keen to continue to engage actively with EWR as well as participate in wider stakeholder discussions. We understand that the preferred option may require a four-track width, as a passing loop, to accommodate freight if needed, rather than just two tracks, in part of the section north of the A428. Again, this has been considered in our emerging illustrative masterplan, with a sufficient width of rail corridor to accommodate this ambition.
The expected delivery of East West Rail and its relationship with Cambourne

3.7. The EWR project, and its preferred alignment, is a significant bonus to this already highly sustainable location. We suggest that the earlier delivery of this new mixed-use community should not be delayed pending the construction of the railway line and station, but rather that it’s delivery should be facilitated sooner, recognising the major benefits the railway and station will bring, in due course, to a settlement that is already well connected, whilst also being capable of high levels of self-containment.
3.8. The AECOM supplement paper that forms part of the evidence base states that the Councils’ assumptions in the Preferred Options trajectory result in delivery at Cambourne starting in 2032/33. This reflects the anticipated date for the new station at Cambourne to be opened as part of EWR and that the Councils will either not require a further supplementary guidance document after an allocation is made in the new Local Plan or that this will be prepared alongside the final stages of the Local Plan and adopted around the same time. This will be important in helping to speed up delivery, and allows proper consideration to be given to the component parts as the Plan evolves through to the submission stage.
3.9. EWR should be operational from 2030 onwards which will increase demand for housing in this location with good accessibility to employment and services in Cambridge, Milton Keynes and Bedford; and by this point Cambourne will be well-established as a new town and will begin to be a market in its own right (rather than ‘overspill’ for Cambridge). Combining the trajectories from Bourn Airfield, Cambourne West (due to be completed in 2037/38) the peak delivery is set to be 550 dwellings in 2036/37 from three strategic sites along the A428 / EWR corridor.

The MGH Vision for Cambourne

3.10. It is very clear that the Greater Cambridge combined authorities acknowledge that Cambourne can develop into a more substantial and self-contained town with a more vibrant centre (p.23 of the ‘First Proposals’ consultation document). MGH supports the overall aims for an expanded Cambourne to provide sufficient critical mass to allow it to perform the following role as a:
• Well-connected place through high quality public transport, cycling and walking facilities;
• South Cambridgeshire town for the 21st century which achieves carbon net zero targets;
• growing employment centre to provide local opportunities for its residents and nearby communities; and
• place that meets the day to day needs of its residents.
3.11. MGH considers that there is a fundamental opportunity to the north of Cambourne to create a scale of growth that allows for, what the First Proposals consultation refers to specifically as a ‘more substantial town with a more fully developed and lively centre’, with a sufficient socio-economic and physical mass to allow it to self-support required job and housing provision, as well as reduce the effects of travel by private car. It will also reduce development pressure on the Cambridge Green Belt and the associated need to demonstrate exceptional circumstances for development there.
3.12. The Transport Appraisal, prepared by i-Transport, that is appended to this representation makes clear that development of land north of Cambourne is not reliant on any new rail corridor or bus corridor coming forward. However, the site provides demonstrable opportunity for creation of a new multi-modal transport hub in the event that EWR and/or Cambridge to Cambourne come forward.
3.13. The site is well located to promote a new transport hub and can offer direct connections from the A428 and can facilitate a future, new, North Cambourne railway station, as part of East-West Rail should this come forward. Similarly the site can support C2C, should it come forward, as well as Park & Ride.
3.14. A summary of the potential transport interventions that may benefit the site are outlined in the i-Transport report that accompanies this representation.
3.15. MGH sees the 1,950 homes identified in Policy S/CB as the initial stage of a more significant opportunity, given that there is every opportunity for raising the numbers at Cambourne, building on the points we make in this representation.
3.16. The timescale for the Plan is currently proposed to 2041 but, as we emphasised at paragraph 2.10, strategic policies are encouraged by the NPPF to look at longer timescales for delivery. This extension of time is necessary both to meet the requirements of the NPPF and to properly consider how strategic growth can take place in a coordinated way alongside the substantial investment in infrastructure that is planned for the area. The recent ‘Building Better Building Beautiful Commission’ report endorses the joint authorities approach informed by the 2050 Peterborough and Cambridgeshire plan. The Commission also envisage a strategic plan of some 30 years as the necessary requirement to deliver place stewardship and ensure integrated control.
3.17. MGH support the preferred strategy, which proposes densification of Cambridge, including the non-GB edge, and expanding a growth area around transport nodes (in particular around Cambourne) with limited development in the villages, whilst recognising that some villages are located sustainably and able to accommodate some growth.
3.18. Given the preferred strategy set out in the consultation, and that Cambourne is recognised as a suitable location with existing great links, and proposed improvements in infrastructure, the emerging Plan should evaluate how the settlement should grow to become a truly vibrant and highly sustainable community.
3.19. MGH’s answer is to propose a wide mix of land use, including leisure and cultural facilities, together with a mix of new housing typologies (to balance the current homogenous suburban offering at Cambourne) and a choice of schools. These built components would be set within extensive Green Infrastructure, woodland and green spaces, with development guided by a code for great placemaking.
3.20. The aspirations of existing Cambourne residents are also really important, in terms of access to jobs / leisure / community and nature, and there seems to be a high level of optimism about how EWR can allow these to begin, and for the best opportunities to be brought forward.
3.21. Work MGH has undertaken with the Town Council shows that many people support an extension of Cambourne to the north, particularly if it delivers on better shopping, a swimming pool (and potentially cinema, and other leisure uses). That scale of ambition all helps the sustainability picture too, and gets Cambourne towards being the ‘proper town’ that the consultation document alludes to
3.22. MGH is therefore seeking allocation of its land interest at North Cambourne as part of this emerging Local Plan, in recognition of the long-term opportunity here to deliver sustainable development.
Greater Cambridge HELAA Report – Site Reference 40114.
3.23. The scoring and weighting in the HELAA Report, and in relation to land North of Cambourne (Site Ref 40114) is necessarily high level. However, it also indicates some results that seem, on the face of it, to be unsubstantiated, especially in the context of the large area of land controlled by MGH and the significant opportunities this provides for landscape measures, biodiversity net gain and wider benefits that can be delivered within this wider space.
3.24. The North Cambourne site is identified in the HELAA Report both as ‘available’ and ‘achievable’, with which we concur. However, the ‘suitability’ overall score is ‘red’, and also contains some red scores on technical matters; namely Landscape & Townscape, Biodiversity & Geodiversity; Historic Environment and Archaeology.
3.25. Based on the Methodology and Assessment Criteria, the overall concluding red score on suitability indicates that ‘The site does not offer a suitable location for development for the proposed use and/or there are known significant constraints or impacts which cannot be mitigated’.
3.26. Fundamentally MGH does not consider the HELAA Report to represent an accurate analysis of the land at North Cambourne. By their nature, developments on greenfield sites will involve the loss of existing open land (often of high agricultural land value in the Cambridgeshire context) and associated impacts on landscape that are negative and unavoidable. However, the assessment also needs to take account of the wider prospects for mitigation, including extensive buffer planting and off-sets, and for biodiversity net gain, as well as the wider balance of benefits and improvements in the context of the Local Plan strategies for sustainable growth. We have developed these points further in our consideration of the Sustainability Appraisal in Section 5, and our vision document demonstrates the overall benefits.
3.27. Looking in more detail, the Methodology for the Assessment Criteria of Suitability indicates that for Landscape and Townscape the red score is associated with development that would have a ‘significant negative impact which cannot be mitigated’ and for Biodiversity where the development would have ‘a detrimental impact on designated sites, or those with a regional or local protection which cannot be reasonably mitigated or compensated as appropriate’. For Historic Environment the red score is considered to apply where development of the site would ‘cause substantial harm, or severe of significant “Less than substantial harm” to a designated heritage asset or the setting of a designated heritage asset which cannot be reasonably mitigated.’ For Archaeology the red score indicates ‘Known archaeology of significance which could not be mitigated through design or conditions.’
3.28. In the following sections we tackle these main ‘red’ flags, which were weighed against the suitability of the site;
3.29. Landscape & Townscape – the HELAA identifies that the site lies within the National Character area of the Bedfordshire & Cambridgeshire Claylands, and the Local Character area of the Western Claylands. The assessment comments that there are wide, local views and amenity views due to the open nature of the fields and low-lying boundary hedgerows. The effect of large-scale development is seen as having a significant adverse effect on the landscape as a resource in its own right and effects on views and visual amenity.
3.30. The Chris Blandford Associates supplementary report within the Council’s evidence base suggests that the provision of appropriate strategic landscape mitigation and enhancement measures for integrating the extension of Cambourne into the surrounding countryside would be a key policy consideration for the new Local Plan. Such an approach, it suggests, is likely to be based on the following principles;
• Maintain strategic countryside gaps to protect the distinct character and separate identity of the rural villages;
• Create a strong landscape structure to screen/soften the edges of built development as experienced in views across adjacent landscape types;
• Strengthen the character of linear landscape features to create biodiverse and accessible green corridors connecting new settlements to the surrounding countryside (informed by the findings of the Green Infrastructure Study); and
• Ensuring high quality and distinctive design that is responsive to local character and creates a strong sense of place through sustainable building/urban design and appropriate landscaping and green infrastructure provision.
3.31. Our representation is supported by a Landscape & Visual Assessment (LVA), prepared by Cooper Landscape Planning. This assesses our emerging illustrative masterplan in the context of the landscape character areas, key views and associated receptors. The LVA concludes that it is obvious that development will change the local landscape character of any site, and North Cambourne is no different. Nevertheless, the design approach adopted of retaining an open landscape, with development enclosed behind strong woodlands is an approach that will work well in this landscape.
3.32. Accordingly, the proposal at North Cambourne has been based on a positive landscape vision:
• retaining an open agricultural landscape, as well as accommodating a new settlement;
• providing a series of significantly strong woodland to create the framework for development; and
• forward planning the eastern area to allow for the growth of planting fer development commencing in the west.
3.33. The extended North Cambourne proposal has been modelled to provide an accurate representation of how the housing blocks would look from key viewpoints. This includes the location of the new woodland in the east, planted in advance and reaching up to 10-15m by the time in the western and central parcels have been built out.
3.34. The photomontages provided demonstrate that the area extended to the east will not produce unacceptable visual effects when seen from the local villages of Elsworth and Knapwell.
3.35. Overall the view is that the proposals will become assimilated into this landscape, and the design adopted will follow the landscape character principles set out in guidance.
3.36. Biodiversity & Geodiversity – the HELAA confirms the location of an SSSI, Wildlife Site and Ancient Woodland within the area of MGH land interest. The summary states that the development would have adverse impact on designated sites, or those with a regional or local protection ‘which cannot be reasonably be mitigated or compensated as appropriate’.
3.37. However, the Biodiversity & Green Spaces Topic Paper states that the Western Gateway Multi-Functional GI corridors provide opportunities to improve biodiversity by expanding and joining up the existing woodland, hedgerow and grassland habitat network.
3.38. The objectives identified in the Topic Paper will be delivered through an extensive Green and Blue Infrastructure Strategy that will include new woodland planting, natural regeneration, hedgerow extension and management, and habitat restoration. The strategy also requires that opportunities for biodiversity offsets from EWR are sought. Other suggested measures include;
• ensuring negative impacts from access and recreational pressure on sensitive ecological sites (Eversden and Wimpole SAC, and woodland SSSIs) are minimised, by providing additional GI sites for recreation, promoting alternative or new access routes, and educating visitors on the value of conserving habitats.
• improving access throughout the area for people (where it will not cause detrimental impact on ecological sites - as above) through opportunities associated with East West Rail as well as along river corridors.
3.39. In the vision document and illustrative masterplan we identify how we can capitalise on these opportunities, and identify ways to make suitable and substantial net gains. The Green Infrastructure being proposed is in excess of 60% of the land interest (around 400 acres). This point is also expanded upon in following sections.
3.40. Heritage – the presence of a listed asset, under ‘Historic Environment’, and crop marks under ‘Archaeology’, have resulted in views in the HELAA that development would cause substantial harm, or the more severe end of ‘less than substantial harm’. Again this seems to take no account of the ability to reflect on setting, historic landscape, buffers and mitigation, plus the need to consider significant public benefits that would accrue.
3.41. The Chris Blandford Associates paper assessing the blended approach comments that “The concentration of development at Cambourne, the NEC and Airport, should enable the management of risk through appropriate design responses e.g. height, massing, landscape etc. The Cambourne area poses lower inherent risks with regard to Cambridge and designated heritage assets than many other sites.”
3.42. The Savills Heritage Team has reviewed the more detailed aspects of this topic. The known heritage assets sensitive to any development within the site includes the two Grade II listed structures at New Inn Farm, and potentially non-designated heritage assets at other historic farmsteads within, and immediately adjacent to, the site.
3.43. Beyond this initial desk-top analysis, there has been no fieldwork or on-site investigation of the indicated cropmark and earthwork features within the site.
3.44. As part of the ongoing planning process, a staged programme of archaeological fieldwork and supporting studies will be undertaken to increase the understanding of heritage assets on the site. This would include further Desk-Based Assessment and geophysical surveying, and focused evaluation trenching by way of an agreed Written Scheme of Investigation, as necessary. These methods will provide a greater understanding of the extent and type of features that exist. The results of this additional assessment would further inform the level of significance of these remains and any further mitigation that may be necessary.
3.45. A sensitively designed layout of any proposed development, which includes off-setting development and/or the appropriate use of intervening landscaping would be implemented to mitigate potentially adverse harm to the setting of the designated and non-designated heritage assets within or adjacent to the site. Notably, avoiding built development adjacent to the listed New Inn Farmhouse and barns would preserve their setting and minimise harm. Development would therefore not give rise to any direct harm to the fabric of listed buildings. In addition, a scheme which provides a degree of separation of any new development and incorporates layered tree planting/vegetation buffers and open-ness around New Inn Farmhouse and barns would provide reasonable mitigation. With this combination of measures any substantial or significant ‘less than substantial’ harm to the setting/significance of the designated heritage assets would be avoided.
3.46. In considering any non-designated built heritage assets, their identification and assessment would be undertaken, and the significance they possess and/or the contribution of their setting to their significance would be understood. A design scheme which recognises their setting and responds to it by safeguarding where necessary and appropriate off-sets would mitigate any harm resulting from development.
3.47. We also notice that some other sites that are indicated as being ‘located in a landscape of cropmarks of late prehistoric and Roman settlement and associated activity’ are scored as amber. This scoring appears to acknowledge the potential for mitigation to be implementation in a way that is consistent with the approach described above. The Heritage and Archaeology HELAA analysis for North Cambourne should therefore be revised accordingly.
3.48. Other elements of the HELAA which scored as amber for North Cambourne included; Adopted Development Plan Policies, Flood Risk, Site Access, Transport & Roads, Noise, Vibration, Air Quality and Ground Conditions (including the loss of Grade 2 Agricultural Land). However, the HELAA recognises the potential to overcome and mitigate for concerns in these areas, subject to detailed design, conditions and controls. The illustrative masterplan contained in the vision document provides an initial assessment of the range of measures that would be incorporated in the scheme at North Cambourne to ensure a comprehensive mitigation strategy is implemented. The site is of sufficient scale to accommodate these mitigation strategies as well as secure a scale of development consistent with the sustainable new community that MGH proposes.

1.0 Introduction

1.1. Savills is instructed to act on behalf of Martin Grant Homes Ltd (MGH). MGH controls a substantial area of land to the north of (and adjoining) Cambourne (referred to as North Cambourne).
1.2. Our representations are structured to respond to relevant sections of the Greater Cambridge Local Plan (GCLP) ‘First Proposals’ consultation. This follows on from our representations to the ‘First Conversation’ in the previous stage of the Local Plan during 2020, and our earlier response to the Call for Sites in 2019.
1.3. This representation is accompanied by a vision document and illustrative masterplan (under separate cover), setting out the key strategies and proposals for North Cambourne, and by other technical reports on transport and landscape. The vision document and illustrative masterplan explain how new employment could be delivered together with new infrastructure, facilities and housing, creating a new sustainable community, that is well connected to Cambourne and to Cambridge as well as providing improved access to services and facilities for existing Cambourne residents.
1.4. Development at North Cambourne is a highly sustainable option for accommodating both new housing and new jobs in the Greater Cambridge area. There is significant opportunity for development here of a scale that can promote self-containment and consolidate the functions of the existing settlement. This will support internalised movements using active travel and sustainable modes, minimising carbon impacts as compared to other development options and thereby addressing the Climate Emergency that the Greater Cambridge local authorities have declared.
1.5. The Government has identified the Oxford-Cambridge Arc as a key corridor for growth in the country. This reflects the fact that the fundamentals of the economy in Cambridge are very strong, with certain key sectors clustered in the area including Life Sciences and Bio-Medical. The Arc therefore represents one of, if not the best, opportunity for delivering growth where the economy can sustain it, where productivity is high, and where there are huge opportunities to improve equality and sustainability .
1.6. The narrative as a whole indicates MGH’s general views, as well as indicating areas of support or objection in relation to the First Proposals emerging policies and general direction of travel for the Local Plan. The headings and sub-headings in the following sections relate to the main sections and policies in the First Proposals consultation.
1.7. MGH has already consulted widely among local communities on its proposals for North Cambourne and will continue to participate in the discussion about where growth should take place in Greater Cambridge in order to appreciate, advance and fully embed all of the benefits that development can deliver here, as well as understand and respond to local concerns.
 
2. Vision and Development Strategy

Vision and aims
2.1. Helping Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water efficiency, and is resilient to current and future climate risks, requires bold action - and promptly. MGH shares the Councils’ commitment to delivering homes, jobs and infrastructure in the most sustainable places that will secure this transition in a timely way.
2.2. We support the emerging Local Plan aims to;
• increase and improve networks of habitats for wildlife and green spaces for people;
• create new distinctive and inclusive places that will help people to lead healthier and happier lives, where there is less reliance on travel by unsustainable modes;
• encourage a flourishing mixed economy, providing a range of jobs whilst protecting the global reputation of Greater Cambridge for innovation;
• plan enough homes to meet the needs of the area, including affordable housing and a wide range of housing to suit the needs of the community;
• plan for transport, water, energy and digital networks; and health, education and cultural facilities; in the right places and built at the right times to serve the growing communities;
• help to tackle the climate emergency through proactive interventions to mitigate carbon emissions through sustainable design measures, eliminating the need to use fossil fuels within buildings and achieving net zero emissions through on-site measures.
2.3. In the current consultation the Greater Cambridge authorities have indicated that location is the single biggest factor in impacting on carbon, albeit recognising that it is not suitable to focus on any one broad location. In order to balance this, we understand that the combined authority is proposing;
1) a blended strategy – taking the most sustainable elements of the Western Cluster / Public Transport corridors (incorporating Cambourne) and including them, to meet a variety of needs; and
2) a focus on development at a range of the best performing locations in terms of minimising trips by car.
2.4. In addition, the Greater Cambridge authorities have indicated that mitigating carbon emissions from new buildings will be a key issue in delivering the authorities’ longer-term net zero carbon objectives. With South Cambridgeshire having declared a climate emergency in 2019, it now aiming to halve emissions by 2030 and reduce them to zero by 2050. In terms of the effect of these goals on emissions from new development, we understand that the combined authority is proposing;
1) a net zero carbon policy for new development; and
2) a focus on calculating whole life carbon emission from new development.
2.5. In the public feedback sessions held so far as part of this First Proposals consultation, a focus on public transport corridors and the densification of the Cambridge urban area were the top options preferred by respondents.
2.6. Importance was also given in the feedback sessions to the opportunity to deliver sufficient jobs as well as homes, and the particular recognition of the benefits that East West Rail (EWR) brings to Cambourne. The preference being to expand here, rather than create further new settlements.
How much development and where? - general comments
2.7. The NPPF, at paragraph 61, sets a requirement to determine minimum housing numbers using the standard method. At paragraph 81 the NPPF also states that significant weight should be placed on the need to support economic growth and productivity, and that policies should address the specific locational requirements of different sectors. The NPPF states that this is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential. This includes making provision for clusters or networks of knowledge and data-driven, creative or high-tech industries, but also recognising all of the supporting roles that employment and services need to provide to support communities. Paragraph 105 of the NPPF also sets out the requirement that the planning system should actively manage patterns of growth in support of sustainable transport objectives. Significant development, it states, should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes, which can help to reduce congestion and emissions, and improve air quality and public health.
2.8. The location of Greater Cambridge within the national economic priority area of the Oxford to Cambridge Arc lends even further weight to the need to support this growth. The Arc already supports two million jobs and brings £110 billion to the UK economy per annum, which is over 7% of England’s economic output (Gross Value Added) . The emerging Spatial Strategy and Vision for the Arc suggests that by 2050 the economic output could increase by between £80 billion and £160 billion per annum, and up to a further one million jobs generated.
2.9. MGH supports the strategic ambitions to deliver substantial growth in the GCLP plan period to 2041, and in the wider Arc Strategy to 2050, and we have set out our position in more detail in the following sections.
2.10. The timeframes associated with plan making also need to be realistic. Paragraph 22 of the NPPF states that “strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”
2.11. The updated Planning Practice Guidance (PPG) states that where the new policy applies, “the authority will need to ensure that their vision reflects the long-term nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan.”
2.12. A recent Ministerial Letter to the Chief Executive of the Planning Inspectorate confirms that the changes to the NPPF are intended to ensure that local authority plan preparation can continue “at pace while also ensuring that the government’s objectives are delivered”
2.13. For the strategic sites contained in the Plan, MGH suggests that it sets out and indicative plan for ‘future Growth Areas’ for the period to 2050, which aligns with the timescale for the Oxford to Cambridge Arc Strategy.

New jobs

2.14. The Cambridge economy is internationally significant and sits at the heart of three economic corridors. Its’ influence therefore extends far beyond Greater Cambridge. There are really important key sectors located here; research & development, professional services, health and care. Nevertheless, the joint authorities recognise the need for a mixed economy providing a wide range of jobs, whilst maintaining the global reputation of Greater Cambridge for innovation.
2.15. The evidence base documents within the First Proposals consultation make clear that the effect of this highly successful local economy is that it comes at a cost; high house prices and low levels of affordability, leading to increased commuting distances and associated carbon emissions impacts. There is also a potential threat of de-population from Greater Cambridge with economic migration to more affordable areas, especially if working patterns in the knowledge economy are increasingly flexible and supported by technological advances.
2.16. We understand that the approach taken to forecasting jobs has involved looking back, to review both recent and longer-term employment trends, but also a look forward using the standard regional economic forecast as a baseline. The conclusions set out in the evidence base have been towards promoting a ‘central scenario’ seen as ‘most likely’ accounting for longer terms patterns of employment growth, but with acknowledgement of recent fast growth in key sectors.
2.17. However, there has also been a ‘higher scenario’ considered, which is seen as ‘plausible’, and which places greater weight on the recent fast jobs growth in the key sectors. It is also noted that there has also been accelerated growth in jobs generally in recent years.
2.18. There is a difficulty (that is recognised in the GL Hearn ‘Housing and Employment Relationships Report’) in delivering the homes to match job provision, and a recognition that existing (2011 Census) commuting patterns would expect Greater Cambridge to continue to be a net importer of labour. The minimum growth model takes the number of houses that would derive from the Government standard method to calculate the number of jobs that this would support; whereas the higher growth model takes more specific account of evidence of job forecasting in Greater Cambridge, and uses that to calculate the homes required to support it.
2.19. MGH asserts that, if the objective of the plan is a successful economy that can continue to thrive and meet the local authority carbon emissions targets, it will need the homes to match jobs, or commuting will increase. Alternatively, the policy would need to be to deliberately constrain job growth, which, in our view, does not comply with government policies or the Arc strategy. Given the very particular, arguably exceptional, ambitions for growth in Greater Cambridge the latter approach would be unlikely to be found sound.
2.20. Savills undertook an Employment Market Assessment in July 2020, on behalf of MGH, which indicates that the Cambourne office market, while smaller compared to other urban areas in the region, has a diverse business sector base comprised of companies in the knowledge economy. This mix is comparable to that found in Cambridge and signifies that Cambourne is already seen as an attractive office location. Cambourne’s office rents are competitive compared to other regional markets in the wider area and there is a good level of high-quality office premises.
2.21. The industrial market in Cambourne was assessed in the same study as being limited at present, compared to main industrial locations at Bedford and Cambridge and, to a lesser degree, Biggleswade and Huntingdon. Bedford and Cambridge dominate the ‘large sheds’ market (over 10,000 sqm) while the other locations cater more for ‘mid box’ industrial sheds (2,000 - 5,000 sqm). However, much of this stock is assessed to be in need of renewal, which could provide an opportunity for Cambourne in the near to medium-term.
2.22. The Employment Market Assessment also indicated that the new EWR station and other mass transit proposals would enable a significantly larger labour catchment to access North Cambourne via public transport modes. We estimate that this could achieve a theoretic modal shift from car to rail within the 30 and 45-minute drive time catchments of more than 50%. This point is explored in further detail in Section 4 of our vision document. This shift would help underpin future investment, given the importance placed by businesses in having access to suitably qualified staff.
2.23. Much of the existing and future (once EWR is operational) local labour catchments have skill levels higher than the national average, which would benefit office-based occupiers in particular. The Savills employment study also identified the positive impact that new rail stations across the UK have had on their local commercial markets within a 2-mile radius. These positive impacts included reduced vacancies, higher rents, and increased leasing activity and new deliveries compared to their relevant regional markets. Based on these factors we estimate that Cambourne could capture up to 15% of future office growth within its office market area and up to 5% of its industrial market area.
2.24. From the Savills Employment Market Assessment this translates to:
• 37ha of office land (or 185,000 sqm of office floorspace) over 20 years or 55ha (278,000 sqm) over a 30-year period, based on a 50% plot ratio;
• 11ha of industrial land (or 43,000 sqm of industrial floorspace) over 20 years or 16ha (65,000 sqm) over a 30-year period, based on a 40% plot ratio.
2.25. Our ambition for North Cambourne, contained within the vision document and illustrative masterplan, therefore indicates much more than the 40,000 sqm of employment space shown in the previous SHLAA submission.
2.26. The masterplan in the vision document shows a large area of employment space together with the homes that can be accommodated at North Cambourne, that equates to just over 1 job per home. We would also wish to generate more jobs within the existing areas of Cambourne, in order to rectify the current imbalance of 0.35 jobs per home that presently exists within the settlement and which gives rise to high levels of out-commuting.
2.27. Overall, the importance of a job led approach, incorporating a realistic assessment of local economic factors and the ability to deliver housing that supports the labour market in a sustainable way, is critical to the strategic policy for Greater Cambridge and meeting the wider economic objectives for the Arc. These objectives will be supported by the growth proposed at North Cambourne.
New homes
2.28. The recognised need is to provide homes consistent with the forecast jobs (as detailed in the ‘Housing and Employment Relationships’ report).
2.29. The Greater Cambridge LPAs have explained that the proposed housing quantum is derived from understanding workplace populations, commuting patterns and resident populations, and has also involved testing likely commuting patterns. The housing forecast is associated with the most likely central employment scenario, and assumes that all the additional homes generated by forecast jobs above those supported by the standard method will be provided in full within Greater Cambridge.
2.30. The table below identifies the scenarios in the First Proposals consultation that have been assessed in seeking to identify the overall position on Objectively Assessed Need. Importantly, we understand that the jobs are proposed across all employment sectors, including business, retail, leisure, education and healthcare.
Homes 2020 - 2041 Jobs 2020 - 2041
Minimum Growth – Gov Standard Method 36,700 45,800
Per annum 1,743 homes 2,181 jobs
Central Scenario – ‘Most likely’ 44,400 58,500
Per annum 2,111 homes 2,786 jobs
Higher Scenario – ‘Plausible’ 56,500 78,700
Per annum 2,690 homes 3,748 jobs
Table 2.1 – Homes and Jobs Scenarios in the First Proposals Local Plan 2041

2.31. The table above suggests a changing factor of 1.24 to 1.31 to 1.39 jobs per home, as the numbers increase. We suggest that this, in turn, could potentially increase the amount of displacement and commuting. This is particularly relevant in Cambourne, where the job to home ratio is currently low. Furthermore, it is accepted by the joint authorities that planning for the standard method of calculating homes would increase the risk of higher levels of commuting.
2.32. It is also notable that an independent economic review has suggested an even higher number of jobs could be created, based on the recent accelerated growth in some sectors. The consultation document highlights that the Cambridgeshire and Peterborough Independent Economic Review (CPIER) says: “A distinguishing feature of [Cambridgeshire and Peterborough] is how strongly it has grown recently… This has been driven primarily, but not entirely, by rapid business creation and growth in the south – Cambridge and South Cambridgeshire.”.
2.33. In conclusion, MGH would strongly support the higher scenario for jobs and housing that has been assessed, given that it is seen as ‘plausible’, and also that the recent trend demonstrates accelerated growth in jobs in Greater Cambridge. It is this level of growth in jobs that should guide the housing targets in order to avoid local labour shortages causing damage to the economic potential of the area and / or giving rise to longer distance commuting, which will render the 2030 and 2050 net zero carbon targets unachievable.

Policy S/DS – Development strategy

2.34. As set out above, it is essential, not just for the prosperity of those living in the area, but also for the wider region within the Oxford-Cambridge Arc and the UK in general, that Greater Cambridge plays its part in delivering economic growth.
2.35. The obligation is on the LPAs to properly plan for and match the provision, and manage the impacts, of housing, including affordable housing, and jobs. The failure to co-ordinate and plan sufficient land for development would result in the Local Plan being found unsound and in turn potential unplanned development arising, in the absence of a 5-year housing land supply. In turn this would have external implications for infrastructure delivery, worsening housing and employment land affordability, increased commuting and carbon impacts. Clearly this is not sustainable in terms of social, economic and environmental impacts. In other words, not delivering sufficient land for jobs and housing would be contrary to climate mitigation strategies.
2.36. The evidence base is, we accept, currently blurred by the effects of COVID-19, but Greater Cambridge is in a strong position given its sectoral mix and there is still high demand for workspace.
2.37. The consultation document makes clear the existing commitments and allocations within the emerging Plan. Northstowe and Waterbeach are progressing, of course, and the hope from the joint authorities is for accelerated pace there. However, there are no changes proposed to overall numbers in those locations, and it is difficult to know how the LPAs expect to force that pace anyway.
2.38. MGH argue that a better pace overall is likely to be delivered by opening up new locations around Cambridge, including those supported by new infrastructure such as a rail station, and other public transport provision. Policy S/DS recognises the opportunity for “Evolving and expanding Cambourne into a vibrant town alongside the development of the new East West Rail station, which will make it one of the best connected and most accessible places in the area”, and identifying the delivery of 1,950 homes in the plan period.
2.39. We understand that Cambourne is identified as a broad location for growth, but with no specific sites identified at this point. The LPA has left the zone for Policy S/CB as, what has been referred to in one of the consultation sessions as a “mysterious circle” because the sites are not yet defined, and suggesting that the delivery of the development here would be later in the plan period. However, MGH can start delivering development at North Cambourne before the rail connections are all in place, because new sustainable transport infrastructure (C2C and Park & Ride) will be delivered in advance of the rail and provide a sustainable mode of transport as an alternative to the car. The C2C scheme will connect Cambridge to Bourn Airfield New Village and Cambourne, and therefore residents of North Cambourne would also be able to utilise this new infrastructure for travel.
2.40. Moreover, whilst Paragraph 23 of the NPPF states that “Broad locations for development should be indicated on a key diagram…” MGH considers that the opportunity exists for greater precision and therefore greater certainty (both spatially and in terms of the tests of soundness) compared to the loosely positioned circle over the existing settlement. At present the uncertainty risks raising concern with local residents unnecessarily as well as making planning for new infrastructure, such as the MRT more difficult.
2.41. The consultation rightly recognises the prospects for Cambourne as one of the best-connected places in the area, due to the planned preferred EWR route and station at North Cambourne. Our vision document and illustrative masterplan shows how these new place-making components can be delivered. The vision document, along with the transport paper that supports this representation, also explore how the new community at North Cambourne can be well connected to the existing settlement by the creation of ‘green bridges’ supporting active travel and high levels of permeability. The proposed location of the North Cambourne railway station will also add significantly to the impetus for these improved connections.
2.42. We also note that, in the transport modelling of the new settlement location options tested, the Cambourne area performed best in terms of active mode share for trips generated and equal best for car trips per dwelling. Again, our transport paper identifies more detailed information to further support these measures and thus further reduce carbon emissions.
2.43. The Development Strategy Topic Paper highlights that future development at Cambourne will address a series of key issues:
• How to integrate with and maximise the opportunity provided by East West Rail;
• The role of the new development in Cambourne as a place, and how it can contribute towards the achievement of net zero carbon;
• The relationship with Cambourne and Bourn Airfield, and how to make the area more sustainable, through the mix of services, employment and transport opportunities offered by the area as whole;
• The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy;
• How the place will develop over time, and the infrastructure needed to support different stages during its development;
• Making effective connections within the new development and with Cambourne for public transport and active travel, as well as connections to surrounding villages so they can also benefit;
• Be structured around, and have local and district centres that can meet, people’s day to day needs within walking distance, including responding to changing retail and working patterns;
• How it can help deliver the Western Gateway Green Infrastructure project, and in doing so positivity engage with its landscape setting, as well as recreation and biodiversity enhancement opportunities such as woodland planting; and
• Take opportunities to reduce flood risk to surrounding areas, that take innovative solutions to the management and reuse of water.
2.44. In addition, the Council’s evidence indicates that large scale development at Cambourne could have landscape impacts and that these would be hard to address. We consider this point further in our response to the HELAA assessment, in the vision document and in a supporting landscape paper prepared by Cooper Landscape Planning.
2.45. Landscape factors will be explored further as part of preparing the draft Local Plan, but the Councils are clear that the design of North Cambourne will need to be ‘landscape led’ in order to minimise impacts in the wider landscape and to have a focus both on place making for the expanded town, and the delivery of the wider vision for green infrastructure set out in the plan. This includes supporting the objectives for ‘Strategic Green Infrastructure Initiative 8: Western gateway multifunctional GI corridors’
2.46. Notwithstanding the issue of landscape, the consultation paper also highlights that, in the context of the significant economic and carbon benefits of locating development at the proposed new rail station at Cambourne, it is considered that the benefits are likely to outweigh the level of landscape harm..
2.47. The supporting text to draft policy S/CB says that, nevertheless, it is ‘too early to identify a specific development area and amount of development’ (hence the ‘mysterious circle’). The document does though go on to provide suggested provisional amounts and timescales associated with Cambourne as follows;
• “..anticipated to start delivering in 2032/2033 after opening of the new railway station, with build out rates based on Housing Delivery Study assumptions for new settlements of gradual increase in annual completions to maximum of 300 dwellings a year;
• 1,950 dwellings anticipated in 2020-2041
• Noting as above that it is too early to identify a specific development area and amount of development for Cambourne broad location, for the purpose of transport and other evidence testing we needed to include a specific number of total dwellings assumed to be present once development is fully built out. We therefore included an assumption of 10,000 dwellings.
Use of this figure is a proxy for a strategic scale development for the purposes of testing at this point, and does not mean that the Councils have made any decisions about the level of housing that should be located in this area.”
2.48. Building on the points set out in earlier sections, MGH advocates that the joint authorities plan for a level of growth that is informed by the economic strategy, and which is noted as plausible, should be pursued. This involves matching the provision of jobs with homes in locations that are capable of higher levels of self-containment and where the options to reduce reliance on private cars are highest.
2.49. The GL Hearn Employment Land Review that forms part of the evidence base stated that the higher employment scenario places greater weight on the fast jobs growth seen in the recent past, particularly in key sectors. By implication, this higher-level outcome is considered possible in the report but not the most likely. As such, the maximum level of homes, associated with the higher employment scenario, is not considered by the report to represent the objectively assessed need for homes in Greater Cambridge.
2.50. Importantly though the Employment Land Review makes recommendations to plan positively for growth and provide for more than the medium level of jobs, in order to provide flexibility (Section 5.3 of the Development Strategy Topic Paper refers).
2.51. In planning positively for growth, MGH agrees that it is appropriate that the new Local Plan provides new land for the identified undersupply in particular types of employment and where those are most suitable to meet sustainable development targets. This is particularly the case where there is a more blended market demand between Research and Development and office uses (former Class B1 b and a).
2.52. The GL Hearn supplementary paper identifies that spreading employment outside of Cambridge would be contrary to prime office market preferences for the city centre and city fringe locations. However, the paper also acknowledges that secondary offices and lab development is likely to be successful around Cambourne with improved accessibility.
2.53. It is also highlighted that industrial and warehousing tend to have a greater reliance on strategic road access rather than public transport and would benefit from the A428 connection. If higher growth is achieved over the next two decades, then it is suggested by the GL Hearn review that the current pipeline of supply is likely to be insufficient without further supply being made in the new plan.
2.54. It is noted that there is a likely undersupply in general industrial premises (Class B2). These premises are required and any losses, particularly in the city, would require re-provision that would need to be either on alternative sites within Cambridge or more likely elsewhere in South Cambridgeshire. Further provision should therefore be made in the new plan to address this anticipated undersupply.
2.55. The GL Hearn paper also anticipates undersupply in warehousing and distribution (Class B8) space, and it is suggested that suitable locations should be identified for small and mid-sized light industrial and distribution units with the drive-in e-commerce further increasing the need for smaller scale warehousing opportunities (final mile centres). This positive approach will ensure a flexible supply, supporting a healthy local economy over the plan period and beyond. Again, the GL Hearn paper recognises the opportunity that Cambourne provides for this sector.
2.56. The GL Hearn analysis therefore allows the expansion of Cambourne to be planned in a way that anticipates the sort of employment spaces that would be likely to be successful in the area, and is well aligned to the mixed employment strategy that the plan is seeking.
2.57. The consultation document states that having identified the objectively assessed need for housing to support the medium level jobs, the next consideration is whether it is appropriate and possible to meet those needs in full within the plan area. The total homes arising from the forecast jobs is identified in section 4 of the strategy topic paper as the objectively assessed need. In translating jobs to homes, this is represented by the scenario whereby the additional homes above the standard method are calculated with a 1:1 commuting ratio (‘consume our own smoke’). The evidence also considered the implications of following existing commuting patterns, which would have the effect of some of the additional homes having to be provided outside of Greater Cambridge.
2.58. Given the Councils’ aims of limiting global carbon emissions, and the key acknowledged role that the location of development plays in carbon emissions, the principle of limiting longer distance commuting is particularly important. In this context, as a matter of principle, the Councils’ intention is to meet the objectively assessed needs for housing identified within Greater Cambridge over the plan period, unless evidence identifies an insurmountable problem with achieving that in a sustainable way.
2.59. In the spatial options for the Western Cluster, including Cambourne, the consultation paper says;
“Headline sustainability benefits noted include:
• Further develops and enhances a new settlement where the groundwork has already been laid, providing access to services and facilities within Cambourne and likely provision of new services and facilities, resulting in positive effects for accessibility, equalities, health, climate change mitigation and air quality.
• Good access to public transport and services, facilities and employment centres elsewhere, once strategic transport infrastructure is complete.

Headline sustainability challenges noted include:

• Access to jobs and services outside Cambourne are beyond reasonable walking and cycling distance, which could encourage car use, despite public transport provision and investment.
• Could result in damage to or degradation of biodiversity assets and green infrastructure.”

MGH fully endorses the first two points, and does not consider that the latter two represent substantial risks in the overall balance. The vision document, and our responses to the HELAA and the Sustainability Appraisal in the following sections of this representation explain why.

Climate Change

4.1. The big themes of the emerging Local Plan are an excellent way to progress the underpinning principles for growth in Greater Cambridge. Care needs to be used in prioritising each of these themes. A balanced approach should be used. Each policy of the new Local Plan, and each potential site for employment or housing (or both), will have different impacts that are nuanced depending on proposals and site locations. The Sustainability Appraisal is the key to understanding relative impacts on the four big themes, and we have commented separately on that in Section 5 of our representation. However, it is clear that the location and design of development will play a key part in achieving key principles of sustainability, including minimising operational carbon emissions and the effects of movements, which relate to climate change, wellbeing, social inclusion and place making.
4.2. A number of the issues raised in relation to reducing impacts on the climate are applicable to all policies and developments. The preparation of the Local Plan should therefore focus on those issues that have the most impact on the decision-making for the Local Plan, including:
 setting policies to reduce operational carbon emissions from new development;
 assessing whole life carbon emissions to account for a balanced approach to embodied and operational emissions for new buildings;
 promoting patterns of development that reduce the need to travel; and
 locating development where a choice of travel options exist other than the private car.
4.3. We would also add: -
 encouraging transport choices that have less impact on the climate, such as walking, cycling and public transport;
 promoting self-containment and sustainable settlements, where public transport can easily be supported and a wide range of facilities and services are within walking and cycling distance;
 allocating development where public transport infrastructure already exists, is planned, or can be provided, to encourage sustainable travel.
4.4. A key requirement for reaching net zero carbon targets is the minimisation of vehicular movements (with transport making the largest contribution, and responsible for 34% of emissions in South Cambridgeshire). The plan should therefore favour options that are capable of providing alternatives to private car use. Public transport is not only more efficient, it reduces traffic queues (and therefore impacts positively on productivity), it is better for health and wellbeing , and is socially inclusive as it allows equal mobility for those without access to a car (and for those who do not wish to own a car).
4.5. There are two key factors that can assist in reducing car travel and increasing public transport:
 placing jobs, leisure facilities and shopping in close proximity to housing, thereby reducing the need to travel and increasing ‘self-containment’;
 and providing new development in locations that provide alternatives to the private car – in particular good public transport services.
4.6. A further requirement to reduce the risk of climate change impacts is to minimise the energy used to construct and operate new development, with over 40% of UK emissions arising from built property. Whilst the costs of achieving more sustainable buildings will be similar regardless of the location of development, there will be greater opportunity for carbon reduction to be achieved where development is at sufficient scale to provide an integrated and holistic approach to climate change mitigation and adaptation.
4.7. The Climate Change Topic Paper sets out a number of emerging policies aimed at reducing carbon emissions from new buildings, and ensure that suitable adaptation measures are incorporated into proposals to futureproof development against a changing climate.

CC/NZ: Net zero carbon new buildings

4.8. This policy sets out an ambitious approach to address carbon emissions through the sustainable design of new buildings, reducing energy demand in the first instance through a ‘fabric first’ approach, before selecting low carbon, fossil fuel free building systems and then employing renewable technologies to offset residual emissions to zero. The policy also incorporates an approach to tackle embodied emissions in construction materials and processes by consideration of whole life carbon analysis to ensure that low impact construction methods are deployed.
4.9. In order to meet these policy objectives, for the site at North Cambourne MGH will utilise the energy hierarchy approach to first reduce the demand for heating through efficient design of the building fabric. In addition MGH will adopt measures consistent with those set out in the UK Government’s Future Homes Standard consultation , intended to provide new homes ready for the 2050 net zero carbon economy. This ‘fabric first’ approach has the added benefit of ensuring energy bills will be kept to a minimum for new occupants.
4.10. The site will not be connected to the gas grid and will instead employ all-electric building systems, providing heating, cooling (where needed) and hot water through the use of heat pump systems. These will avoid the need to retrofit or upgrade building systems in future.
4.11. Where suitably co-located, waste heat from non-domestic uses can be used to heat homes. Opportunities for heat sharing between domestic and non-domestic uses will be explored in more detail as the scheme design is progressed.
4.12. A systematic approach to renewable technology selection will be undertaken to understand the feasibility of various technologies in delivering the maximum level of renewable energy generation through onsite means, aiming to achieve net zero carbon emissions without offsetting where possible. Site-wide emissions will be established for all building uses, aiming to provide net zero across the site as a whole, with buildings with surplus savings offsetting those where net zero is harder to achieve.
4.13. Offsite measures, such as carbon offsetting, will only be used as a last resort in situations where it is impractical to generate sufficient renewable energy from onsite systems.
4.14. Whole life carbon assessment will also be undertaken to establish the lifecycle performance of proposed embodied and operational energy efficiency measures, in line with current RICS best practice guidance. The whole life carbon analysis will account for the ongoing decarbonisation of the UK electricity network, with the UK Government recently announcing that it is aiming for net zero carbon electricity from 2035.

CC/WE: Water efficiency in new developments

4.15. This policy recognises the increasingly importance of potable water scarcity in the region and sets out measures to reduce potable water consumption in new development as follows:
 Residential developments should be designed to achieve a standard of 80 litres/person/ day unless demonstrated impracticable.
 Non-residential development will be required to achieve full credits for category Wat 01 of BREEAM unless demonstrated impracticable.
4.16. North Cambourne will therefore aim to reduce potable water consumption to the levels set out above by utilising low flow fixtures and fittings throughout the development.
4.17. It is unlikely that the 80 litres per person per day target will be achievable through low flow fittings alone. The potential to include rainwater harvesting will therefore be investigated in more detail, rainwater harvesting systems could be employed at a building level or used in conjunction with the site-wide Sustainable Urban Drainage Systems (SuDS) features to provide a centralised rainwater collection system to be used in washing machines and toilet flushing.

CC/DC: Designing for a changing climate

4.18. New buildings will need to include adaptations to the changing climate. In particular, increased temperatures and changing rainfall patterns have been highlighted as key considerations for climate change adaptation strategy, prioritising passive solutions where possible to reduce the need for artificial cooling.
4.19. Our scheme will utilise a sitewide approach to reduce climate risks, including the integration of sustainable drainage systems as part of the landscape design, the use of urban greening to reduce heat build-up in developed areas through increased tree canopy cover and integrated green space.
4.20. Buildings will be designed to reduce the risk of overheating through two primary courses of action. Firstly, heat gain into buildings will be minimised through fenestration design and external shading where needed. Secondly, natural ventilation strategies will be employed to ensure buildings are able to purge excess heat effectively.
4.21. All overheating measures will be thoroughly tested in accordance with the Good Homes Alliance Overheating Tool to ensure the risk of overheating is minimised. Additional analysis will be conducted where required, accounting for future weather scenarios with increased air temperatures. This will be developed in more detail once dwelling designs are more advanced.

CC/FM: Flooding and integrated water management

4.22. The emerging policy sets a requirement for new development to provide integrated water management, including SuDS, where surface water is managed close to its source and on the surface where possible. In addition, potential flood risk from developments will need to be fully addressed and account for potential climate change impacts.
4.23. North Cambourne is located in Flood Zone 1, so is at low risk of flooding from rivers and the sea. However, there are some isolated areas of the site at risk of surface water flooding, adjacent to existing watercourses. Through an integrated sitewide SuDS strategy, this risk will be mitigated within public open spaces and potentially mitigated through a centralised rainwater harvesting system to reduce potable water consumption.
4.24. The SuDS strategy will aim to ensure that the peak runoff rate post development is no greater than that which currently exists on the site.

CC/CE: Reducing waste and supporting the circular economy

4.25. The objective of this policy is to reduce the amount of waste being sent to landfill, both during the construction and operational phases of development. Circular economy principles are seen as the best means of ensuring materials stay in their highest use state for the longest period of time, with disposal and end of life considerations forming part of the development design principles.
4.26. Operational waste should be managed in accordance with relevant Waste Management Design Guidance, aiming to provide adequate, flexible and easily accessible waste storage for site occupants.
4.27. Circular economy principles will therefore be combined with the whole life carbon assessment to minimise the carbon embodied in construction materials, and ensure materials and buildings are capable of being reused and adapted over their lifespan.
4.28. The design of buildings will be carefully considered to allow for disassembly and material repurposing at the end of useful life. The scheme will adopt a ‘materials bank’ approach to construction. Dynamically and flexibly designed buildings will be incorporated into the circular economy, where materials in buildings sustain their value. This will lead to waste reduction and the use of fewer virgin resources.
4.29. During design development, the design team will examine the potential to include innovative approaches to operational waste management, including underground refuse systems in higher density areas of development.