Greater Cambridge Local Plan Preferred Options

Duty to Cooperate
The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration.
The revised Framework introduced a number of significant changes to how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SoCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. Planning guidance sets out that local planning authorities should produce, maintain, and update one or more SoCGs, throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, such as unmet housing needs.
Gladman are supportive of the two Councils working jointly to prepare the new Local Plan for Greater Cambridge, as this both aligns with the policy commitment in the existing Local Plans and allows for strategic matters which cross between the two LPAs to be considered comprehensively in a joined-up manner. Notwithstanding this, it still remains of critical importance for Cambridge City and South Cambridgeshire to work alongside the other Cambridgeshire authorities to ensure that any wider cross boundary issues are addressed. It may be the case that these need to be addressed through SOCGs with the other LPAs.
As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans examinations, if a Council fails to satisfactorily discharge its DtC a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications.

In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA), and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
The SA/SEA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the emerging Local Plan proposals on sustainable development when judged against all reasonable alternatives. The Councils should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed, and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Councils’ decisionmaking and scoring should be robust, justified, and transparent.

This policy identifies an objectively assessed need of 44,400 new homes and 58,500 new jobs to be provided in the Greater Cambridge area up to 2041.
Continued economic growth across the Greater Cambridge area is of fundamental importance and needs to be properly considered and planned for through the Local Plan. Greater Cambridge forms part of the nationally significant Oxford to Cambridge Growth Arc, thus the role the GCLP plays is of pivotal importance in delivering transformational scales of growth.
It is essential that economic growth opportunities are recognised and maximised and the Councils work alongside other LPAs in the Arc to ensure that the potential is realised through robust housing and job requirements.
The Local Plan First Proposals document acknowledges the Councils’ commitment to the Cambridgeshire and Peterborough Devolution Deal. If the scale of job growth required by this is achieved, around 2,900 homes a year would be needed across Greater Cambridge, resulting in a housing requirement of 66,700 homes between 2017-2040- a significantly higher figure than the initial policy direction suggests.
Gladman strongly believe that the new Local Plan should be planning for a significantly higher number of homes than the minimum identified by the standard method if the plan is to align with the scale of economic growth planned for the Arc. While the housing requirement in this plan are above the standard method figure, Gladman believe that this figure will need to be higher yet, in order to achieve the economic growth aspirations of the area.
In this regard, Gladman refer to the Cambridgeshire and Peterborough Independent Economic Review (CPIER), published in 2018 which sets out a compelling case for higher levels of housing across the Greater Cambridge area. Of particular note is Key Recommendation 5, which points to the need to review the housing requirement based on the need for high economic growth. Importantly, the report warns of significant negative impacts to both the national and local economy should housing needs continue to be constrained.
The Arc aims to create 1,000,000 jobs before 2050. For this target to be realised, LPAs across the Arc must work together to ensure that appropriate job requirement figures are allocated to authorities that are capable of providing employment. At present the first proposals consultation suggests looking to providing 58,500 jobs between up to 2041. Gladman consider that Greater Cambridgeshire should be seeking to deliver significantly greater economic and employment growth to ensure the Arc economic aspirations are realised.
Further to this, the Local Plan needs to recognise the importance of the Councils’ position within the Oxford to Cambridge Growth Arc and the implications of this in terms of growth in the area. The Arc is a key economic priority and one of the publicly stated key objectives of the Arc is to deliver up to 1 million high quality homes across the area, up to 2050. Gladman believe it is of imperative importance that the new Local Plan seeks to deliver a higher number of homes than required by the standard method to ensure that it is in line with nationally significant economic growth. As outlined in the PPG, the standard method for assessing local housing need is the minimum starting point in determining the number of homes needed in an area. It doesn’t account for future government policy, changes in economic circumstances or other demographic changes that might affect the level of housing required in an area. For this reason, it is necessary to consider that housing need in an area may be higher than the standard method calculation and the plan should be positively prepared for this.
Gladman reserve the right to comment on housing and job growth proposals when these are developed further and the Draft Plan is issued for public consultation.

The proposed direction of this policy focuses development in and around the City of Cambridge and through new settlements. Some development is proposed in the Rural Southern Cluster area of South Cambridge, including Green Belt land, and minimal development is proposed in the rest of the rural area.
The Councils should seek to allocate a range of sites, by size, type and market locations to ensure that the Local Plan delivers identified housing need for the region. Growth should be dispersed across the settlement hierarchy and the region to ensure future sustainability and vitality. Growth should also be focused along sustainable transport corridors, such as the Melbourn to Cambridge corridor in the southwest of the area. This corridor is a sustainable location for growth, offering sustainable transport options in to Cambridge whilst allowing housing needs to be met without releasing Green Belt land in the rural southern cluster.
While Gladman recognise that some Green Belt land may need to be released to meet the needs of Cambridge City, the release of Green Belt land in excess to meeting the City’s needs is unnecessary. As outlined at paragraph 140 of the NPPF (2021);
‘Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.’
The Councils must ensure that the methodology used to assess Green Belt land is suitably robust and can clearly demonstrate that exceptional circumstances exist to justify the release of Green Belt land.
Furthermore, the release of Green Belt should not be the primary source of developable land when other suitable and sustainable sites are available outside of the Green Belt. This is clearly outlined at paragraph 141 of the NPPF (2021) which states;
‘Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.’
It is recognised that there may be no alternative to Green Belt release to meet some of the needs of Cambridge on the edge of Cambridge, however that is unlikely to justify Green Belt release on in the villages and towns. It is imperative that the Councils have considered, assessed, and rejected all other reasonable options to get to that point.
The site submissions at Section 10 and the accompanying appendices demonstrate several available sites that would not require the loss of Green Belt and supports the NPPF’s (2021) assertion later within paragraph 141 that sites in ‘other locations well served by public transport’ should be optimised. Currently, the proposed spatial strategy disproportionately directs growth towards Cambridge City and fails to account for and direct growth towards the sustainable villages on key transport corridors in South Cambridge.
Many settlements, including rural service centres, are sustainable and capable of accommodating growth which ensures their continued vitality. The accompanying Linton StoryMap and Meldreth StoryMap explore this in greater detail. While Gladman support growth in Cambridge, there should be sufficient growth directed towards the rural areas, particularly in South Cambridge in line with the housing needs of the area. The Council must recognise that residential development performs a key role in maintaining and enhancing the sustainability and vitality of settlements. Growth should be directed to those settlements which have not experienced development in the current plan period to ensure the future prosperity of the area and ensure the vitality and continued use of services and facilities within the villages remain over the plan period.
In addition, while strategic sites in close proximity to economic hubs and Cambridge City will form an important aspect of the Plan’s strategy, it is vital that the Councils are not overly optimistic in the projected delivery rates of such sites. Additionally, the Councils should not be overly reliant on strategic developments to deliver identified need as such sites are often subject to significant infrastructure costs and provision. The Councils should also be mindful that new settlements may not be delivered within the plan period up to 2041 and are often subject to lengthy delays. To ensure that this does not impact overall housing delivery, the Councils should seek to allocate small to medium sized sites in sustainable locations that can be delivered by smaller housebuilders and are less likely to incur significant delays.
Fundamentally, the distribution of development should not be a politically driven decision, but one based on robust evidence and consideration of a number of factors such as local housing needs and settlement sustainability. Green Belt land should not be released unless exceptional circumstance can be demonstrated and all other reasonable, suitable alternative sites have been considered.
Overall, the Local Plan will need a balanced strategy, including a variety of different elements to ensure delivery over the course of the plan period and to meet the needs across the plan area. It is important that the Councils do not place an over reliance on just one type of approach, in this case, large scale urban extensions and new settlements, as this could hinder delivery of much needed housing.

This policy aims to group similar settlements into categories that reflect their scale, characteristics, and sustainability. Gladman support the use of a settlement hierarchy, but in line with previous comments regarding the development strategy, do not agree that schemes in Minor Rural Centres should be limited to 30 dwellings and this would not be in keeping with the national policy imperative that seeks to boost significantly the supply of housing. Additional development should be directed across the hierarchy and to villages to support their vitality and future viability, and larger schemes are capable of delivering more affordable housing and significant benefits to local residents.
The NPPF (2021) is clear that development in rural areas should be supported ‘where it will enhance or maintain the vitality of rural communities.’ The policy direction does not currently identify opportunities for villages to grow and thrive, nor does the settlement hierarchy explicitly consider how development in one village may support services in other nearby villages such as is the case with villages such as Meldreth and Melbourn.

This policy will define the boundaries of settlements and proposes that outside of settlement boundaries, no development would be permitted unless they meet a specific set of requirements. Gladman recommend that the new Local Plan should take a flexible approach to development and growth within and on the edge of villages. A rigid approach to development beyond settlement boundaries, except for specific circumstances, may act to unnecessarily stifle sustainable growth opportunities. This is at odds with national policy which seeks to significantly boost the supply of housing and applies a presumption in favour of sustainable development.
Gladman recommend that the settlement boundaries policy incorporates a criterion based balancing exercise so that the Plan can protect against unsustainable development whilst being open and flexible to additional development opportunities to come forward to meet identified needs.

This policy will set the levels of energy use that will be allowed for new development and the specific requirement regarding the energy needs of new buildings. Residential developments of 150 homes or more and non-residential development of 1,000 m2 or more should calculate whole life carbon emissions through a nationally recognised Whole Life Carbon Assessment and demonstrate actions to reduce life-cycle carbon emissions. This should include reducing emissions associated with construction plant. Gladman are supportive of attempts to reduce carbon, however new buildings and residential developments will be built in accordance with the Building Regulations at the time of their construction.

Gladman are supportive of the overarching aim of the policy to increase biodiversity in the Greater Cambridge area but consider the minimum requirement of 20% biodiversity net gain to be excessive and above national policy requirements. The Environment Act 2021, when the legislation is enacted, will introduce a requirement for new development to deliver a 10% net gain in biodiversity.
An additional 10% BNG on top of the forthcoming national requirement could stop smaller sites that would be capable of delivering much needed homes from coming forward and may also lead to schemes which do not take account of local site densities and characteristics of the surrounding area. Any policy requirement should be fully tested and justified through a viability assessment.
It is also important that the long-term impacts are considered when reviewing proposals for BNG, accounting for the fact that many of the measures provided will need to mature beyond the build period.
Gladman support the recognition that more significant and long-lasting biodiversity benefits are often delivered off-site and the policy should be flexible enough to allow for this.
These considerations should be considered when drafting a policy with regards to achieving biodiversity net gain.

Gladman generally support the protection of special and valued landscapes but have concerns that the proposed policy direction does not provide a suitably balanced approach and could stop sustainable development in the countryside coming forward when needed. The justification for and inclusion of Important Countryside Frontages needs to be robustly evidenced and the policy needs to provide the necessary flexibility at the edge of villages.

Gladman support the inclusion of a Green Belt policy but the policy must not simply duplicate national policy set out in the NPPF (2021). Other issues relating to the protection of the Green Belt with regard to the spatial strategy have been outlined in Section 4.2.