Greater Cambridge Local Plan Preferred Options

We believe there should be more allocations proposed within this area including the allocation of a number of small sites under 1 ha to allow the plan to be in accordance with NPPF paragraph 69.

We question some of the findings of the HELAA assessment process in particular site 40461.

This site was dismissed as it scored one RED result in the matrix which related to landscape. The comments received were as follows:
“Development throughout this site would have a
significant adverse impact to the existing settlement
character, an encroachment into the landscape,
permanent and removal an existing paddock upon the edge of the existing settlement. Development would also cause a creep of development towards the A10 joining Meldreth to the Industrial/Agricultural site on the other side of the A10. This creep may create precedent for further development which may further diminish the separation between Meldreth and Melbourn. Development has the potential to change the character of the edge of the village and extend its urban edge up to A10 and beyond.”
We disagree with this assessment and would like to make the following points:
Firstly, the site has been incorrectly referred to as a paddock, it is a vacant area of scrubland land with no current use.
The area between the trainline and the A10 already forms a distinct separation gap between Meldreth and Melbourn. We believe this creates an defined landscape gap between the two settlements. Site 40461 relates more closely to Melbourn, by nature of the character of the area. The development of a small number of homes (circa 8 dwellings) will not diminish the separation between both settlements. The site is screened on all sides and not visible from the wider landscape from any direction. There are no views into the site from the A10, to the north, and the site is surrounded by mature vegetation which screens the site from all public view points.
The owner of the site encourages the Shared Planning Service to undertake a site visit to fully appreciate its context and character and to amend the HELAA assessment.
This site, due to its size, will make a positive contribution to the smaller sites of under 1 ha needing to be identified to meet the NPPF paragraph 69 guidance.

The amount of development allocated within the First Proposals document for the rural area seems disproportionate and extremely low growth amount given the sustainable nodes of transport surrounding some of the rural villages. Cambourne has been allowed, and grown significantly along with Bourn Airfield where no current and effective public transport shuttle route is available. We believe the south west railway corridor area between Melbourn and Cambridge needs additional consideration as its own cluster. With the improvements within the Melbourn Greenway and also new proposed Travel Hubs at Foxton and the proposed Cambridge South West Travel Hub and new railway station for Addenbrookes we do not believe this option has been explored adequately. We request that this is given further consideration and additional growth proposed in this area where growth can easily be accommodated. This can be achieved without the same landscape impacts as proposed with the Green Belt release sites in the Rural Southern Cluster proposals.

It is unclear as to whether these allocations are existing commitments or proposed allocations. There seems to be discrepancy within the wording and mapping along with inclusion within the main development strategy and the table included at page 32.

We question the development strategy approach to elevate this area to its own policy section context over and above other rural public transport and employment clusters such as the area surrounding Melbourn – Cambridge. We believe this south western area should be explored in equal depth as an opportunity area to support existing communities with strong existing public transport connections and employment opportunities.

We agree that no further growth in Cambourne or the surrounding area should not be considered appropriate by the Councils’ until there is certainty that the Oxford-Cambridge route will be going ahead and will include a station at Cambourne. Also, we note that the GCP C2C busway project is still ongoing, with slow progress. Accounting for any additional housing in this area over the next plan period seems an unsustainable choice until these projects are actually committed. We note from the GCP website that the partnership “recognises that housing developments in Cambourne West and Bourn Airfield require the C2C project to be opened by 2025 to provide reliable public transport services, otherwise that planned growth will be put at risk.”
The First Proposals document states that 1,950 additional homes are being accounted for within the plan period and we assume these are based on the West Cambourne planning permission and therefore should be considered as an existing commitment rather than a new allocation and this requires amending within the document. Additionally, we note that no plan of this area of Cambourne where the identified 1,950 additional homes was included within the First Proposals Document.

This allocation is heavily reliant on major infrastructure either being relocated (the airport itself) or implemented such as the GCP Cambridge Eastern Access scheme. This allocation could leave the plan vulnerable at Examination stage due to deliverability and viability development risks.

We question the deliverability and viability of 4,000 homes being delivered from this allocation within the plan period given the reliance on the relocation of the sewage treatment works and also the remediation which will be required as part of any development proposal. This allocation may cause the plan to be vulnerable to challenge at Examination stage.

We welcome the approach to fully review the existing settlement boundaries within this new Local Plan. However, we believe that development boundaries should be removed and replaced with a criterion-based assessment. This will add flexibility to the policy and allow for individual sites to be judged on their own merits. It would also still prevent inappropriate development in the open countryside but allow for additional development on small sites in sustainable locations. The NPPF seeks to prevent development on ‘isolated’ sites but Local Plans should include a flexible approach to allow for the sustainable credentials of each site to be evaluated rather than preventing development completely just because a site falls outside of a boundary line. A similar approach has recently been adopted in Huntingdonshire which has enabled this flexibility. This is particularly important around existing communities and settlements which have changed in character over time.

The settlement hierarchy review within the strategy topic paper appears to assess each settlement in terms of the services located within Parish boundaries rather than considering how different settlements interact and support each other. Paragraph 79 of The NPPF states that “Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”
When assessing each settlement perhaps the distance to the nearest service should be the criteria (such as was used within the HELAA site assessments) rather than just whether the service is available or not in the Parish. For example, the village of Meldreth is closely supported by the facilities of Melbourn. We question whether the Shared Planning Services had considered an analysis of existing communities under the 20-minute neighbourhood principles, how would Cambourne perform under such analysis? This may indicate what additional services are required within existing communities to help achieve a more local sustainable growth to our communities. Identifying shortfalls in community service and facilities in this manner may help local communities plan and encourage other benefits and facilities within neighbourhood plans, for example.

We disagree with the current amount and distribution of development within the Development Strategy, we believe it does not allow for enough growth and is disproportionate. More growth should be considered and other sustainable corridors such as the South West railway corridor and this should be reviewed in much the same way as the Rural Southern Cluster approach. The area between Melbourn and Cambridge not only benefits from the railway but also is an area which will also take advantage of the GCP Melbourn Greenway project which will help Active Travel choices between settlements and to the nearby railway stations. The amount of development which has been considered appropriate in this location seems inconsistent with the vision and aims set out for the area.
The Development Strategy also does not accord with the NPPF paragraph 69 a) which requests that all Local Plans have at least 10% of their overall housing target ‘identified’ on sites of less than 1 ha. We understand that the First Proposals document states that existing commitments and windfall developments within the area already result in this figure being achieved, but the NPPF is clear that these sites should be ‘identified’ within the Local Plan. This appears not to have been demonstrated within this document and within the Strategy Topic Paper. Within this evidence base document, the figure quoted at page 45 has included windfall sites as well as sites with planning permission which were not identified as allocations. We believe there are sites included within this figure where planning permission was achieved through a lack of 5-year housing supply at the time and not through allocation in previous plans. We believe Greater Cambridge should identify at least 4,440 homes on allocated smaller sites of less than 1ha and, as a result, more smaller sites need to be identified through this plan making process. We would like to see a further breakdown of the smaller sites and an indication as to whether these are, in fact, identified as allocations in previous plans.
Further Clarification Needed:
The table of proposed housing allocations on page 32 of the First Proposals paper seems unclear as to which sites are proposed allocations and what are existing commitments. For example Cambourne is included within this table but within the commentary for this policy (S/CB) it would appear that these 1,950 homes already have planning permission within the West Cambourne proposal and surely this is therefore an existing commitment?
The proposed allocations within the Rural Southern Cluster are not clear as Duxford (S/RSC MF) and Great Shelford (S/RSC site HW) are included in the table at page 32 but Comfort Café (S/RSC/CC) is excluded. More clarification is required on what actual new allocations are proposed.