Greater Cambridge Local Plan Preferred Options

No evidence has been put forward to detail how delivery will be sped up on existing new settlements. What specific, reliable and deliverable mechanisms will be used to ensure that this strategy will come to fruition?
Furthermore, we question if the necessary infrastructure for these sites will be delivered at the same pace?

The development strategy does not provide enough land within village locations to make a meaningful contribution to the housing trajectory or affordable housing provision. Given our concerns over the growth forecasts, the development strategy will need seek village growth locations of sufficient size to ensure the growth strategy is balanced and resilient. This should include housing and employment sites to reduce commuting pressures in and around Cambridge and bring further vitality to villages.

The suggested policy approach represents a lack of forward planning for existing village settlements, some of which are highly sustainable and represent excellent locations for growth.

Further evidence is required as to how the Councils’ have assessed the costs and impacts of their proposed approach particularly as the requirement for 20% BNG will reduce gross development value and in some cases impact on site viability and deliverability.

Paragraph 5.4 of the Sustainability Appraisal highlights that the “…the draft Local Plan will consider potential in-combination effects of the Local Plan with other relevant plans and programmes, including those being brought forward by other organisations and under separate planning processes, for example the relocation of the Cambridge waste water treatment plant”. It is not clear whether any “in-combination” effects of the First Proposals and the CWWTP have been adequately assessed. We expect the Sustainability Appraisal to be updated to reflect a proper assessment of impacts of the CWWTP relocation together with the impacts of the First Proposals.

It appears from the HRA Report that the relocation of the CWWTP is part of the mitigation measures which will be necessary to provide certainty that water quality impacts arising from the First Proposals will not adversely affect the integrity of several designated nature sites, in combination with other plans and projects. We expect the policies of the First Proposals to be revised (including to provide for the relocation of the CWWTP) in order to ensure that the emerging plan secures appropriate mitigation in connection with the development strategy - in particular North East Cambridge.

The widespread promotion of Neighbourhood Plans (page 24) is likely to act as a constraint on development in the rural area. Research on the progress and effectiveness of neighbourhood plans found that 55% of the draft plans published for consultation have ‘protectionist’ agendas and many are openly anti-development. Therefore, there is a likelihood that this agenda will create inevitable conflicts between the national aim to significantly boost housebuilding and local community NIMBYism. The idea of ‘top down’ housing targets being set by the local authority may also dissuade some areas from engaging with the neighbourhood planning process altogether.

A more pragmatic and flexible approach would be for the Greater Cambridge authorities to carry out up-to-date local housing need surveys for the whole area (e.g. at ward or parish level) to determine quantitative and qualitative need. Used as robust evidence for the determination of planning applications, this would be a fairer system which would guide development to the right locations and, given the reliance on the private housing building sector to deliver affordable housing, also ensure that housing needs are met across the whole District, more effectively tackling the chronic affordability issues present. The process could be managed and controlled by the relevant Council, with local input from the relevant Parish Council. A bottom-up approach where small to medium scale developments are planned for local people in housing need (those named on the housing register), would also be less controversial.

Additional commentary on the proposed housing and employment targets and overarching development strategy as outlined in Policy S/DS is provided in a separate report by Barton Willmore.

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the ‘organic’ growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.

Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the ‘open countryside’. But it is not logical to treat all sites equally in policy terms. Whilst sites within sensitive valued landscapes and the green belt should receive a high level of protection, the sensitive development of some sites on the edge of a village would cause no significant harm. Such a pragmatic approach is often taken at appeal. For example, rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping where it would soften an existing harsh area of built form can be acceptable in certain locations.

Furthermore, for minor rural centres such as Linton, the current strategy to restrict schemes to an indicative maximum of 30 dwellings within settlement boundaries will not deliver the quantum of development required to meet the pressing local need for affordable homes. As a result, the affordability crisis will deepen in the rural area. For example, to deliver 25 affordable homes within Linton, a minimum of 63 dwellings will need to be permitted as part of major developments. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable villages such as Linton.

In summary, a carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built-up areas should not perpetuate unfettered incremental growth.

Draft policy CC/NZ sets a high threshold of 150 homes for calculating whole life carbon emissions. Support should also be expressed for developments of <150 dwellings where this information is provided voluntarily.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.

Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).