Greater Cambridge Local Plan Preferred Options

OBJECT

Ely Diocesan Board of Finance (EDBF) has promoted a number of sites through the emerging GCLP process.

EDBF’s representations to the GCLP Preferred Options consultation refer to two of those sites, as follows:

• Land at Hinton Way in Stapleford (HELAA Site Ref. 40369) for residential development, and adjacent to the preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford); and
• Land off Butt Lane in Milton (Site Ref. 40365) for employment development on remainder of land adjacent to approved Cambridgeshire Constabulary Police Station.

The sites are currently located in the Green Belt. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster (for the Stapleford site) and the rest of the rural area (for the Milton site), and specifically the decision to allocate a very limited amount of development to the more sustainable villages close to Cambridge such as Great Shelford, and the decision to not consider the relocation needs of existing businesses within the North East Cambridge area. It is requested that both sites are released from the Green Belt.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predicts high average annual housing delivery rates for Northstowe and Waterbeach.

The redevelopments at North East Cambridge and Cambridge East are complex and involve the relocation of the existing uses and are likely to take much longer to deliver than currently predicted; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East.

Most of the new settlements deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases.

For these reasons, it is requested that additional small and medium allocations including land off Hinton Way in Stapleford should be identified in emerging GCLP, which can be delivered easily and provide policy compliant levels of affordable housing.

The Proposed Submission version of the North East Cambridge AAP is currently being reported through various committees of Cambridge City Council and South Cambridgeshire District Council, in advance of public consultation in early 2022.

It is noted that a number of amendments have been made to the AAP, including a 25% reduction in the amount of new commercial (office) floorspace to be provided across the North East Cambridge area and an associated reduction in the number of jobs to be provided from 20,000 to 15,000 jobs. It is intended that there would be no net loss in the quantum of existing industrial (Class B2 and B8) floorspace as a result of the regeneration of the North East Cambridge area. Although it is acknowledged in the AAP that some existing businesses within North East Cambridge would need to relocate as part of the redevelopment.

The Councils intend to support those existing businesses that will be displaced from North East Cambridge, including help to find alternative sites. However, finding alternative sites is likely to be difficult, partly because of the number of businesses that are likely to be displaced either permanently or for a temporary period, and partly because some business will want to remain close to the edge of Cambridge to be close to customers and employees. It is suggested that the remaining land off Butt Lane in Milton, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, could be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area, as well as for general employment purposes.

The promoted land by EDBF is currently located within the Green Belt, and in these representations it is requested that the Stapleford site is released to accommodate housing and affordable housing, and that the Milton site is released to accommodate employment uses including those business displaced from the North East Cambridge area.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt at Stapleford and Milton, which are related to the significant identified need for housing and affordable housing in Greater Cambridge and the need to support economic growth (for Stapleford), and the specific need to provide land for existing businesses that will displaced by the redevelopment at North East Cambridge (for Milton).

Paragraph 141 of the NPPF requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identify previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

Paragraph 142 of the NPPF requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in the emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The EDBF land off Hinton Way in Stapleford is well served by public transport (bus and rail) and is well connected with existing cycle routes, and there are future public transport improvements proposed in the surrounding area. The EDBF land off Butt Lane in Milton is adjacent to Milton Park & Ride and is well connected to existing cycle routes, and there are proposed public transport and walking/cycling improvements proposed in the area including connections to Waterbeach, Milton and North East Cambridge. Therefore, the release of the land off Hinton Way and off Butt Lane from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

There are a further three paragraphs within the NPPF that suggest additional allocations should be made in Stapleford and the Rural Southern Cluster:
• Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas.
• Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.
• Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Great Shelford and Stapleford contain a good range of services and facilities, reflecting their status as a Rural Centre in the settlement hierarchy. For example, they contain a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants.

The promoted development by EDBF at land off Hinton Way in Stapleford would support the existing services and facilities. Shelford Station is located close to the site. There are bus routes on Hinton Way, Mingle Lane, Station Road and Cambridge Road, all of which are close to the site. There are cycle routes through Stapleford and Great Shelford into Cambridge. The route for the proposed Cambridge South East Transport project by the Greater Cambridge Partnership is located to the north west of the site, and there are proposed stops at Hinton Way and Haverhill Road that would be within close proximity of the site. Therefore, the promoted development by EDBF at land off Hinton Way in Stapleford is accessible by a range of sustainable modes of transport, and it would be consistent with national policy to direct additional development to this site.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a current need for 28 affordable dwellings in Stapleford for those with a local connection to the village, and an identified need in Great Shelford for 47 affordable dwellings – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. It should be noted that additional affordable housing needs will arise in Stapleford and Great Shelford in the future and during the plan period to 2041. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Great Shelford and Stapleford should only seek to meet locally derived affordable housing needs but also those district-wide needs of Greater Cambridge. The preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford) for 100 dwellings would meet the current identified needs for affordable housing of Stapleford, but not district-wide or future needs. The Stapleford and Great Shelford Neighbourhood Plan is at an early stage and a draft plan has not yet been published, so it is not clear whether this document will seek to address future and district-wide affordable housing needs through additional allocations; although it is noted that the emerging GCLP does not anticipate any future amendments to the Green Belt boundary to accommodate those affordable housing needs.

It is for these reasons that EDBF is requesting an additional allocation at land off Hinton Way in Stapleford.

It is requested that additional housing allocations should be made in the more sustainable villages in the Rural Southern Cluster and on the edge of Cambridge including at Stapleford, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is a need for affordable housing in the villages which would only be partially met.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements and the new communities on the edge of Cambridge are reviewed so that they are more realistic.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that additional housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including at land off Hinton Way in Stapleford, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is a current need for affordable housing both in the village and district-wide and there will be a need in the future too.

It is requested that the emerging GCLP should identify additional employment land allocations to meet the needs of businesses that will be displaced as a result of the redevelopment at North east Cambridge. The remaining land off Butt Lane in Milton, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, could be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area, as well as for general employment needs.

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Stapleford and Great Shelford fall within this category.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The land promoted by EDBF at Hinton Way in Stapleford would support the existing services and facilities in the village, including the convenience stores, post office, library, banks, public houses and restaurants, bus, and rail services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire.

It is requested that medium sized sites such as land off Hinton Lane in Stapleford are allocated to meet the requirement for a mix of sites including those that are easily deliverable.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Shelford Station is located close to the site. There are bus routes on Hinton Way, Mingle Lane, Station Road and Cambridge Road, all of which are close to the site. There are cycle routes through Stapleford and Great Shelford into Cambridge. The route for the proposed Cambridge South East Transport project by the Greater Cambridge Partnership is located to the north west of the site, and there are proposed stops at Hinton Way and Haverhill Road that would be within close proximity of the site. Stapleford and the land off Hinton Way are sustainable locations in transport terms, and additional development in this location would be consistent with Paragraph 104.

Paragraph 62 of the NPPF expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 28 affordable dwellings in Stapleford for those with a local connection to the village, and 47 affordable dwellings in Great Shelford. This identified need would not be met without allocations in the village. The preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford) for 100 dwellings would meet the current identified needs for affordable housing of Stapleford, but not any district-wide or future affordable housing needs. The land promoted by EDBF at Hinton Way in Stapleford would include provision of housing and affordable housing to meet future local needs of the village and address a proportion of the district-wide needs, and there would be a policy requirement to include a proportion of self/custom build housing plots within the development.

EDBF’s representations to the assessment of the land off Hinton Way in Stapleford site in the HELAA (Site Ref. 40369) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed.

In summary, the landscape and townscape mitigation measures identified for the preferred allocation at Site Ref. S/RSC/HW (Land between Hinton Way and Mingle Lane, Great Shelford) could also be delivered at the land promoted by EDBF at Hinton Way i.e. strategic landscaping at the north western boundary. The site assessment does not consider the route for the proposed Cambridge South East Transport project located to the north west of the site, in terms of the change to landscape character and to the openness of the Green Belt in this location. If additional land is required to meet a higher housing requirement and housing and affordable housing needs of the villages, then land off Hinton Way in Stapleford would be a suitable location for an additional allocation.

Requested Change

It is requested that the development strategy for the Rural Southern Cluster includes an additional residential allocation at land off Hinton Way in Stapleford, as promoted by EDBF, with the following policy requirements:

• Site Area of 16.87 Ha
• Capacity for approx. 500 dwellings, including affordable housing and self/custom build plots
• Provide strategic landscape buffer at north western and south eastern boundaries
• Design of development to preserve key views from Stapleford Conservation Area and setting of Church of St Andrew (Grade II*) and The White House (Grade II)
• Provide open space and green infrastructure
• Upgrade existing vehicular access from Hinton Way and Mingle Lane
• Design and layout to be compatible with adjacent allocation (Site Ref. S/RSC/HW)

As suggested in the HELAA site assessment (Site Ref. 40369) the site capacity could be reduced to be consistent with the north eastern boundary of the adjacent allocation. A capacity assessment will need to be undertaken, informed by landscape and heritage impact assessment, to determine the most appropriate locations for built development, strategic landscaping, and open space within the promoted development.

It is requested that the development strategy for the rest of the rural area includes an additional employment at land off Butt Lane in Milton, as promoted by EDBF, with the following policy requirements:

• Site Area of 13.80 Ha (Approx. 3.3 Ha for new Police Station and approx. 10.5 Ha for promoted Class E, Class B2 and Class B8 uses).
• Proposed Employment Uses: including Commercial/Office Use (Class E), Class B2 (General Industrial) or Class B8 (Storage or Distribution), and ancillary uses.
• Retain and enhance existing trees and hedgerows at site boundaries
• Vehicular access from Butt Lane
• Pedestrian and cycle connection to Milton Park & Ride
• Pedestrian and cycle connections to future public transport projects e.g. Waterbeach to Cambridge Project or walking and cycling routes to/from North East Cambridge

It is anticipated that the allocation would be suitable for employment uses displaced from North East Cambridge, and that is expressed in the specified mix of uses.

OBJECT

The Proposed Submission version of the North East Cambridge AAP is currently being reported through various committees of Cambridge City Council and South Cambridgeshire District Council, in advance of public consultation in early 2022.

It is noted that a number of amendments have been made to the AAP, including a 25% reduction in the amount of new commercial (office) floorspace to be provided across the North East Cambridge area and an associated reduction in the number of jobs to be provided from 20,000 to 15,000 jobs. It is intended that there would be no net loss in the quantum of existing industrial (Class B2 and B8) floorspace as a result of the regeneration of the North East Cambridge area. Although it is acknowledged in the AAP that some existing businesses within North East Cambridge would need to relocate as part of the redevelopment.

The Councils intend to support those existing businesses that will be displaced from North East Cambridge, including help to find alternative sites. However, finding alternative sites is likely to be difficult, partly because of the number of businesses that are likely to be displaced either permanently or for a temporary period, and partly because some business will want to remain close to the edge of Cambridge to be close to customers and employees.

The successful delivery of the redevelopment of North East Cambridge is a key part of the development strategy for the emerging GCLP, including in terms of meeting housing needs. However, the redevelopment of North East Cambridge is reliant in part on the timely relocation of existing business from land to be redeveloped by other uses. It is considered that the relocation process would be made easier if additional land was specifically identified in the emerging GCLP for relocated businesses from North East Cambridge, whether temporary or permanent.

It is requested that the remaining land off Butt Lane in Milton owned by EDBF, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area as well as for general employment purposes. This outcome would represent the exceptional circumstances to justify the release of land from the Green Belt.

It is considered that, taking into account the neighbouring uses and the current Green Belt status of the site, the land off Butt Lane could be suitable for commercial offices, high quality industrial, or other compatible uses. There may also be an opportunity to deliver an EV charging station in conjunction with the existing and proposed uses e.g. Park & Ride, Police Station, office, and industrial uses.

EDBF’s representations to the assessment of the land off Butt Lane in Milton in the HELAA (Site Ref. 40365) request that the assessment takes into account the approved new Police Station on part of the site (App Ref. S/20/04010/FUL). EDBF’s representations also comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed.

Requested Change

It is requested that the development strategy for the rest of the rural area includes an additional employment at land off Butt Lane in Milton, as promoted by EDBF, with the following policy requirements:

• Site Area of 13.80 Ha (Approx. 3.3 Ha for new Police Station and approx. 10.5 Ha for promoted Class E, Class B2 and Class B8 uses).
• Proposed Employment Uses: including Commercial/Office Use (Class E), Class B2 (General Industrial) or Class B8 (Storage or Distribution), and ancillary uses.
• Retain and enhance existing trees and hedgerows at site boundaries
• Vehicular access from Butt Lane
• Pedestrian and cycle connection to Milton Park & Ride
• Pedestrian and cycle connections to future public transport projects e.g. Waterbeach to Cambridge Project or walking and cycling routes to/from North East Cambridge

It is anticipated that the allocation would be suitable for employment uses displaced from North East Cambridge, and that is expressed in the specified mix of uses.

Land South Bramley Ave, Melbourn (new site 59396)

New site submitted through call for sites proforma.

Land south of Haden Way, Willingham (new site 59431)

New site submitted through call for sites proforma.