Greater Cambridge Local Plan Preferred Options

Policy BG/BG: Biodiversity and Geodiversity

7.0 POLICY BG/BG: BIODIVERSITY AND GEODIVERSITY

7.1 The text supporting emerging policy BG/BG states the proposed policy will ‘require development to achieve a minimum 20% biodiversity net gain’. This figure is considerably above the minimum 10% biodiversity net gain noted within the Environment Bill 2021.

7.2 Martin Grant Homes support the principle of biodiversity net gain and have successfully implemented them within modern development. However, the minimum proposed figure of 20% is not considered appropriate. To make 20% net gain achievable, there will be considerable pressure on sites financially and spatially to ensure this ambitious target is met.

7.3 The result of this will be sites will become unviable and as such, would likely sacrifice other aspects of development such as affordable housing. Spatially, an increased net gain requirement will likely drive-up densities given the likely land take need for biodiversity purposes. Topic Paper 3 suggests an alternative to the policy. It references a mandatory 10% net gain, but does not consider this appropriate. However, the Topic Paper does not include any assessment of financial or spatial impacts.

7.4 It is therefore considered appropriate to amend the proposed policy direction to a minimum of 10% biodiversity net gain. A higher figure could be encouraged but not form part of the policy requirement.

BG/TC: IMPROVING TREE CANOPY COVER AND THE TREE POPULATION

8.1 Martin Grant Homes supports the provision of trees within developments and successfully ensure appropriate planting sits within their development to the benefit of future residents. The concept of policy BG/TC is therefore supported.

8.2 However, the policy and supporting text within the First Proposals document does not provide any guidance as to when the policy would be needed or any quantum of planting that a development would need to provide. As such, it is unclear whether this would be relevant to residential development, and if so, what would the potential land-take be as a result. The latter point raises concerns regarding densities and associated impacts upon viability that could result.

8.3 It is not therefore considered the policy at present gives clear guidance as to what is expected from developers, which raises concern. Greater clarity is needed before appropriate and informed comments can be made.

Policy BG/GI: Green Infrastructure

9.0 POLICY BG/B1 GREEN INFRASTRUCTURE
9.1 Policy BG/GI highlights areas within Greater Cambridge that are considered appropriate for green infrastructure initiatives. With regards to the promotion of land in Coton, area 7 (West Cambridge green infrastructure buffer – Coton Corridor) is relevant to land at Silverdale Close given it washes over the site.

9.2 The policy as proposed seeks to ensure development can benefit ‘people, wildlife and the planet’ and provides a list of criteria as to how that can be achieved, including the need to ensure ’proposed green infrastructure is appropriate to its local context’.

9.3 At Silverdale Close, open space is indicatively location to the south of the site, where it can benefit from views of the countryside and Bin Brook along the southern boundary. The development allows the opportunity to enhance Bin Brook by providing long term maintenance along the waters edge and providing suitable habitat features to encourage use of the brook by identified species. On site planting can also respect and supplement the tree planting beyond the western boundary.

9.4 The finalised wording of the policy should be drafted so as not to inhibit development within these areas. As noted, the Site brings forward significant benefits and is a logical extension to the village. The green infrastructure policy must be clear that appropriate development is suitable in this location and the policy should not be an opportunity to deny appropriate development in principle. The policy should then set out the potential requirements to be included within such development.

9.5 At this stage, it is unclear as to how the policy will be worded and therefore further representations will be made in further consultations as necessary.

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.