Greater Cambridge Local Plan Preferred Options

QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore carbon emissions, can be minimise?
Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. Consistent with this strategy, it is considered to be very important that some growth is delivered in villages that have existing employment areas and have good access to local services and public transport links. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services.
The growth strategy is to create nearly 60,000 (58,500) new jobs across within the plan period to support the economic growth of Greater Cambridge. This growth scenario is at the medium level which aligns with the medium scenario for the housing growth strategy. This strategy requires 2,786 new jobs to be created per year. Greater Cambridge is in a unique position outside London that it has a strong growing economy. The main factor holding back the unleashing the economic potential for Greater Cambridge is housing supply. Therefore, it is essential that the Greater Cambridge Local Plan puts forward an ambitious growth strategy so that it can attract and maintain the work force required to enable companies to grow.
The aim of the jobs policies in the First Proposals is to encourage a flourishing and mixed economy in Greater Cambridge with a wide range of jobs. Sensitive small-scale employment development can help sustain rural economies, and provide a wider range of employment opportunities for local residents. Providing jobs near to residents to reduce the need to travel is a key issue. Therefore, it is important that jobs are created in existing employment locations close to existing settlements in order to reduce car travel.
The CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. Histon & Impington is a highly sustainable location with excellent transport links including the Guided Busway and other bus services. It also has a strong employment area which is located alongside the Guided Busway. In the settlement hierarchy, Histon & Impington is identified as a ‘Rural Centre’ which has no limitation on the size of individual schemes.
It is therefore essential that the existing employment areas which are located adjacent to the existing settlement are enabled to grow, particularly in such a sustainable and attractive location as the Villa Road site. The allocation of the Villa Road site for employment use (B2 and E use classes) would attract companies to an establish employment area which has excellent links to a range of existing facilities which can be accessed without the need for car travel.
The Villa Road site is located within close proximity to the NIAB Agricultural Research facility which lies to the north along Villa Road which would complement the employment allocation of the site.
The Villa Road site is enclosed on three sides by an electricity terminal site to northwest, the Guided Busway to the north with large warehouses beyond, and housing to the south-east in Primrose Lane. No sites have been allocated for employment in Histon & Impington. The site represents an ideal and suitable site for employment due to having excellent transport links, being highly accessible by sustainable modes of transport and would not have a detrimental impact on the wider landscape context.

QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?
Growth should be focused in villages, such as Histon & Impington, which benefit from having an established employment areas and excellent links to public transport. Histon & Impington is one of 5 Rural Centres which should be the focus of housing and employment growth.
It is considered very important that the Local Plan makes provision for a proportion of growth to be delivered from villages such as Histon & Impington to avoid them becoming dormitory villages where residents have to travel into Cambridge or further afield for work and leisure. It is therefore considered that additional growth should be provided within the most sustainable villages, such as Histon & Impington.
The allocation of the Villa Road site would provide an economic boost to the local area which would enable existing services and facilities to remain. The site is also located within close proximity to existing housing which the employment opportunity would be attractive to.

QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?
It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. NIAB Trust is responsible for the promotion of the Villa Road, Impington site, and have a track record of delivering high quality developments in Cambridge. NIAB are fully committed, to engagement with the GCSPS and Parish Council regarding the potential allocation of employment uses to be delivered on the Villa Road site.
The Villa Road site is located adjacent to an established employment area and within close proximity to local facilities and services in the village. It therefore essential to the local economy that there is space to cater for and attract the small to medium size firms to the area by providing an attractive location, close to sustainable transport links. The Villa Road site achieves both these objectives. The feasibility study demonstrates how the site could be laid out to respond to its context without impacting the uses on each of the site’s boundaries.
It is important that the GCSPS growth strategy includes provision that caters for all needs and requirements. The Villa Road site is located adjacent to an established employment base which is vital to the local economy and so should be the focus of a new allocation to allow some expansion. The site could also provide much-needed lab space in the Cambridge area. Therefore, it is considered that the Villa Road site should be allocated for B2 and E use class employment uses in the emerging Greater Cambridge Local Plan as it meets the objectives of the economic growth strategy.

QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?
We agree that it is very important that housing delivery keeps up with demand for increased jobs within the Greater Cambridge area.
As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. However, a significant proportion of this growth is made up of existing allocations within the current Local Plans.
The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth; it generally exceeds it. This is in particular due to a world renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted. Therefore, a more ambitious growth strategy should be prepared.
Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.
The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox-Cam Arc as a centre for housing and employment growth.
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?
We agree that it is very important that housing delivery keeps up with demand for increased jobs within the Greater Cambridge area.
As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. However, a significant proportion of this growth is made up of existing allocations within the current Local Plans.
The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.
The Development Strategy Topic Paper that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth; it generally exceeds it. This is in particular due to a world renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted. Therefore, a more ambitious growth strategy should be prepared.
Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.
The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox-Cam Arc as a centre for housing and employment growth.
Concern is also expressed in relation to the types of sites which have been allocated. Recently the St Albans Local Plan was withdrawn in November 2020 following a number of serious concerns raised by the Inspectors which included an overreliance on a small number of large strategic allocations (500 dwellings or more, or over 14 ha) at the expense of smaller scale subareas. The Inspectors noted that such sites, provide choice and flexibility in the housing market and secure affordable housing more immediately as advocated in national planning policy. The findings of the Inspector in 2020, in respect of the examination of the Uttlesford Local Plan were very similar and also resulted in their Local Plan being withdrawn.
The current GCSPS housing growth strategy is reliant on a handful of very large allocations to deliver the proposed proportion of the growth in predominantly urban areas. It is considered that it would be more sustainable to distribute a wider range of housing growth/allocations across the Greater Cambridge area, as this will provide sustainable benefits for the existing settlements and communities in terms of existing businesses, facilities, and give people greater choice over where to live. National planning policies recognises that rural communities need to be able to grow and thrive to avoid decline. The inclusion of smaller sites will also aid delivery and more competition in the housing market.

QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?
Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. Consistent with this strategy, it is considered to be very important that some growth is delivered in villages. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services.
The CPIER report (2018), which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. Histon and Impington is on the Cambridge Busway and as such is located along a key public transport link into Cambridge, and also nearby towns of St Ives and Huntingdon within Huntingdonshire District. The Busway provides a service every 7 minutes, providing residents and employees with a reliable and sustainable option for travel. A potential new stop on the busway is currently being considered within Histon and Impington, within close proximity to land owned by our client, this is supported by the Histon and Impington Neighbourhood Plan and would further encourage a shift away from car use, towards more sustainable modes of transport for both existing and future employees and residents.
The release of Land West of South Road, Impington from the Green Belt would facilitate the creation of a cycleway/footway that could link into the Darwin Green development to the south, on the opposite side of the A14. It is proposed that as part of any development of the site, of any size, a cycleway/footway route connecting Histon and Impington to Cambridge to the south would be incorporated and provide an improved linkage over the A14 and directly to the existing cycle and pedestrian links within Cambridge. This would further encourage a shift away from car use and towards more sustainable modes of transport.
The encouragement of the use of public transport, cycling and walking in and around the South Cambridgeshire District and City of Cambridge would assist in addressing a key and fundamental issue, congestion. New development should aim to address this problem which would also be compliant with the key issue of Climate Change, a big theme underlying the new Local Plan. This new link has the potential to reduce pressure on the Strategic Road Network which currently does not have capacity to accommodate any new growth in the area.
In addition, Impington (and Histon), benefit from being sustainable settlements in their own right. Histon and Impington are identified in the current South Cambridgeshire Local Plan as a Rural Centre (Policy S/8) and are described as ‘the largest, most sustainable villages of the District.’ Due to this, there is no strategic constraint on the amount of development land for housing within their development frameworks. They benefit from both primary and secondary education facilities and a large range of services, including shops, pubs, restaurants and community facilities.
For the above reasons, it is considered that additional growth within Impington would be consistent with the objectives of the Local Plan, which seeks to minimise car travel.

QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?
We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new local plan. To support this objective, it is imperative that new housing growth is located in areas with sustainable transport links to the campus.
The site is within half an hour cycling distance of the campus and bus links are also available. It is considered important that substantial housing growth is provided in close proximity to the Biomedical Campus to support its growth and so it can be accessed by sustainable transport means. Therefore, growth in Impington would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure.

QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?
Growth should be focused in villages, such as Impington, which benefit from having a range of services and sustainable transport links to Cambridge City Centre. As stated above, Histon and Impington are identified in the current South Cambridgeshire Local Plan as a Rural Centre (Policy S/8) and are described as ‘the largest, most sustainable villages of the District.’
It is considered very important that the Local Plan makes provision for a proportion of growth to be delivered from villages. As set out above, the current approach to allocating only a very limited number of larger sites is not considered to be sound in its current form. In particular, it is considered that additional growth should be provided within the most sustainable villages, such as Impington.
It is considered that the provision for increasing the range of sites modestly to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and securing affordable housing more immediately. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).
It is not clear why the Shared Planning Service have deviated from a clear recommendation provided by the Planning Inspectorate.
However, it is also important to acknowledge the employment sites/areas in Impington which will benefit from increased housing provision. The additional housing will allow people to live closer to work thus reducing car travel and increase employment opportunities. Additional housing would also contribute towards the local economy through spending on local provisions.

QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?
It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. NIAB Trust are fully committed, to engagement with the GCSPS and Histon & Impington Parish Council regarding the mix and type of housing to be delivered on Land West of South Road, Impington. The site also has the potential to provide open space to serve the new and wider local community and would trigger contributions towards improvements towards local facilities

This representation has been prepared by Strutt & Parker on behalf of NIAB Trust to support the promotion of Land north-east of Villa Road, Impington as part of the Greater Cambridge First Proposals Consultation 2021.
The site covers an area of approximately 2.19 hectares and is capable of delivering 4,100sqm of light industrial/research and development units including ancillary provisions such as car parking and landscaping. The site allocation would attract hightech firms to the area to compliment the established firms that are located within Vision Park and also NIAB’s crop research facilities at Park Farm. This would help to boost the local economy by attracting high-tech firms to the area and create job opportunities. It is also noted that this site could provide opportunities for lab space, which is in short supply in Cambridge.
In September 2021 Greater Cambridge Shared Planning Service (GCSPS) published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.
This representation provides a response to the ‘First Proposals’ Consultations. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.
The HELAA excludes the Villa Road site from allocation primarily on the basis of concerns relating to the impact on flood risk, landscape and townscape; site access; and strategic highway impact.
In response to the areas of concern, a feasibility study has been prepared which considers the potential development opportunities including scale, access, connectivity, flood relief and biodiversity improvements. A technical note on flood management has also been produced to respond to the concerns raised regarding flood risk. Further analysis of this is set out within section 7 of this report.
In support of this report, the following document have been prepared;
• Prospective Site Feasibility Study by pHp architects;
• Flood risk management note by Cannon Consulting Engineers

QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?
Yes, land north-east of Villa Road, Impington should be allocated for employment development and would represent a sound allocation as part of the emerging Local Plan as it complements the objectives of the Greater Cambridge economic growth strategy. The land off Villa Road site was promoted originally at Call for Sites and Issues & Options stages.
We acknowledge that the focus of the economic strategy is to support the development of the Biomedical Campus, however, the crop science and food production research sectors are an equally important and rapidly expanding part of the Greater Cambridge economy and should be supported as well.

This representation has been prepared by Strutt & Parker on behalf of NIAB Trust to support the promotion of Land West of South Road, Impington as part of the Greater Cambridge First Proposals Consultation 2021.
In September 2021 Greater Cambridge Shared Planning Service (GCSPS) published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.
Since the Call for Sites and Issues and Options consultations feedback received has been considered and changes have been made to the Land West of South Road site. Previously the site covered an area of approximately 20.62 hectares and was considered to be suitable to deliver a development including 450 dwellings. However, following feedback received at the First Proposals the decision has been taken to greatly reduce the area of the site and quantum of potential development. The revised site is approximately 5.2 hectares in area, and can accommodate 78 dwellings.
It is noted that the NIAB Trust has also put forward two other sites at Park Farm (Villa Road and Redgate Road).
This representation provides a response to the ‘First Proposals’ Consultations. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.
The HELAA excludes the Land West of South Road from allocation for 3 main reasons: a) In relation to Landscape and Townscape: “The site is isolated from the main part of the village and is outside the village framework. Any development of the site would have a negative landscape impact because of the extensive views from the north west and south”. b) In relation to Site Access: “The proposed site does not to have a direct link to the adopted public highway” and there is “No possibility of creating a safe access”. c) In relation to Strategic Highway Impact: “Within Highways England Zone 3 - A14 CNB. No capacity for growth. Sites would need to ensure no net increase in vehicles trips on the Strategic Road Network”.
A Prospective Site Feasibility Study, prepared by pHp architects has been produced to support this representation (Appendix B). As set out in the study, in relation to Landscape and Townscape, the site would be smaller, and would be read as part of the existing village. The smaller site would also have less of a negative landscape impact as it would be well aligned with the existing western edge of Impington. Additionally, the density of the dwellings has been greatly reduced, increasing the openness of the site, and reducing landscape harm. In relation to Site Access, as shown on page 7 of the study, a safe site access could easily be provided to South Road/Mill Road where there is an existing field access to the north of the existing Green Space. A large additional area of green space could be provided directly to the south of the South Road Green Space to compensate for land required for the widening of the access link. In relation to Strategic Highway Impact, the number of dwellings proposed has been greatly reduced, minimising any potential harm. Additionally there is an opportunity to provide a new pedestrian/cycleway link over the existing A14 crossover. This new link would provide a sustainable transport link which could even reduce overall pressure on the Strategic Road Network. It is considered that the revised site addresses many of the issues previously raised, and that several of the assessment criterions used to assess the site should be re-categorised. It has been demonstrated in the supporting information provided that the allocation of this site would not have a significant adverse impact on the landscape or road network, and as such that the site should be put forward for allocation. Further analysis of this is set out within section 7 of this report.
In support of this report, the following document has been prepared;
• Prospective Site Feasibility Study, produced by pHp architects.

QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?
Yes, Land west of South Road, Impington should be allocated for development and would be a sound allocation as part of the emerging Local Plan. The land west of South Road, Impington site was promoted originally at call for Sites Stage. We have also demonstrated that the site could be delivered without any adverse impacts on landscape or the road network.