Greater Cambridge Local Plan Preferred Options

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

OBJECT

Dudley Developments is promoting land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road, Cambridge for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the edge of Cambridge, and specifically the decision to not release additional land from the Green Belt at sustainable locations on the edge of Cambridge.

The overall development strategy is very reliant on the delivery of an extensions 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; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. 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 predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; 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. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will 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 affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. 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. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The promoted development by Dudley Developments at land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road in Cambridge is located within the Green Belt, and in these representations it is requested that the site is released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

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, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high too. The Housing Needs of Specific Groups Report (GL Hearn October 2021) provides further information on affordability and affordable housing needs. Table 42 of the GL Hearn Report identifies an affordable housing need of 199 dwellings per annum for Cambridge and 105 dwellings per annum for South Cambridgeshire, which equates to a combined total of 304 affordable dwellings per annum or a total of 6,384 dwellings during the plan period from 2020 to 2041. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely those journeys are undertaken by car this would add to traffic congestion and air pollution. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation, and not just the Rural Southern Cluster. The site at land off Limekiln Road in Cambridge is in a sustainable location for development in transport terms. It is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to Cambridge. Cherry Hinton contains a very good range of services and facilities.

Paragraph 141 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 identified 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 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 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 promoted development at land off Limekiln Road in Cambridge is accessible by sustainable modes of transport. Queen Edith's Way and Cherry Hinton Road are on bus routes. The Greater Cambridge Partnership’s Making Connections project identifies Cherry Hinton as a key location on a bus corridor, with improved bus links to Addenbrooke’s and Cambridge Station. There is a dedicated cycle path on Cherry Hinton Road. The Greater Cambridge Partnership’s proposed Fulbourn Greenway project, which includes new dedicated walking and cycling routes and improvements, passes through Cherry Hinton. Therefore, the release of the land off Limekiln Road in Cambridge 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.

As set out in representations to Section 2.3: Edge of Cambridge and the HELAA Site Assessments (for Site Ref. 40528), the land off Limekiln Road in Cambridge makes a limited contribution to openness and the purposes for including land within the Green Belt, and does not contribute towards the wider landscape of Cambridge, and should be released from the Green Belt in emerging GCLP.

There are two other paragraphs in the NPPF that suggest additional allocations should be made in on the edge of Cambridge. 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. 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.

The site at land off Limekiln Road in Cambridge is in a sustainable location for development in transport terms. It is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to Cambridge. There are primary and secondary schools in the local area and elsewhere in Cambridge. Cherry Hinton contains a range of services and facilities, including convenience stores, health facilities including doctor’s surgeries and dentists, public houses, and restaurants. The promoted development would support the existing services and facilities in Cherry Hinton. As set out above, the site is highly accessible by walking, cycling and bus services. Therefore, the promoted development at land off Limekiln Road in Cambridge is accessible by a range of sustainable modes of transport and is accessible to an excellent range of services and facilities and to employment opportunities. It would be consistent with national policy to direct additional development to this site.

As highlighted above, there is a significant need for affordable housing in Cambridge and across Greater Cambridge. There are limited previously developed land opportunities within and on the edge of Cambridge that have not already been identified. It is considered that all opportunities should be identified to meet housing and affordable housing needs, including small Green Belt sites on the edge of Cambridge and well-related to existing neighbourhoods where no significant constraints to development exist. The smaller sites in the Green Belt are always overlooked for potential release to meet housing and affordable housing needs. The promoted development by Dudley Developments at land off Limekiln Road in Cambridge would include housing and affordable housing.

For all these reasons, small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge, including small sites within the Green Belt.

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 take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

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 small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge including land off Limekiln Road in Cambridge which is close to Cherry Hinton, because it is accessible by sustainable modes of transport, it could support the existing services and facilities, and it would deliver affordable housing to meet identified needs in Cambridge.

As requested in Dudley Developments’ representations to Section 2.3 Edge of Cambridge, the land off Limekiln Road in Cambridge should be released from the Green Belt and allocated in emerging GCLP for residential development.

OBJECT

The strategy for the edge of Cambridge is focussed on the delivery of strategic allocations, but ignores potential small sites on the edge of Cambridge that are also located in this area. It is considered that the small scale release of land from the Green Belt in sustainable locations and well related to existing neighbourhoods must be part of the strategy for the edge of Cambridge in emerging GCLP. The promoted development by Dudley Developments at land off Limekiln Road in Cambridge, is located close to Cherry Hinton.

Paragraph 69 of the NPPF 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. Paragraph 104 expects transport issues to be considered at the earliest stages of plan-making, and includes opportunities to promote walking, cycling and public transport use.

As set out in the representations to Policy S/DS: Development Strategy, there are few small scale development opportunities within the urban area of Cambridge that are not already allocated for housing or that have been assessed for residential use. Small scale housing sites on the edge of Cambridge, currently located within the Green Belt, are always overlooked as potential housing allocations regardless of whether there are any significant constraints to development or what the level of harm would be to Green Belt purposes arising from development at those sites. These sites could make a contribution towards meeting housing and affordable housing needs, and they are typically in very sustainable locations.

Dudley Development’s representations to the assessment of the land off Limekiln Road in Cambridge in the HELAA (Site Ref. 40528) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed. In summary, the site is largely surrounded by development, with residential to the north and a caravan and motorhome site to the south. There is limited visibility of the site and the existing trees at the site boundary would be retained as part of the promoted development. The promoted development includes open space, and there is other parks and open spaces available in Cherry Hinton. It is noted that Policy BG/BG: Biodiversity and Geodiversity is likely to include a requirement for developments to provide mitigation measures to address recreational impacts on nature conservation sites.

Requested Change

It is requested that the development strategy for the edge of Cambridge includes an additional residential allocation at land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road in Cambridge, as promoted by Dudley Developments, with the following policy requirements:

• Site Area of 0.88 Ha
• Capacity for approx. 14 dwellings, including affordable housing
• Retain and enhance existing trees and vegetation at site boundary
• Provide open space and green infrastructure
• Upgrade existing vehicular access on to Limekiln Road

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Dudley Developments that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils.

Dudley Development’s representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Dudley Developments representations to Policy S/DS, there is the over reliance on the existing new settlements and planned new neighbourhoods to meet the housing requirements. The key parts of the development strategy for emerging GCLP is the delivery of extensions to Cambourne, the planned new settlements at Northstowe, Waterbeach and Bourn Airfield, and the new communities on the edge of Cambridge at North East Cambridge and Cambridge East. These are all complex developments that also require the delivery of transport and community infrastructure. The predicted housing delivery rates at these developments are challenging. Most of these developments will provide less affordable housing than required by policy, at least in the initial phases, to reflect the amount of infrastructure that is needed. The proposed redevelopments at North East Cambridge and Cambridge East are complex and involves the relocation of the existing uses. The Sustainability Appraisal and the assessment of the development strategy simply assume that delivery of these developments will be as predicted without any delays and that the delivery of less affordable housing is acceptable. An alternative approach to address these housing related matters should have been recommended in the Sustainability Appraisal to improve sustainability outcomes e.g. additional small allocations in sustainable locations that deliver affordable housing such as on the edge of Cambridge. Small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge, including at Cherry Hinton on land within the Green Belt, because such sites can also deliver affordable housing to meet identified needs.

The promoted development by Dudley Developments at land off Limekiln Road in Cambridge was assessed in the SA against a series of sustainability objectives and compared against other edge of Cambridge Green Belt site options – see Table 4.19 in SA (Site Ref. 40528 Land North of Cherry Hinton Caravan Club, Limekiln Road, Cambridge). The assessment of the site has not fully taken into account what is proposed in the promoted development or the submitted Vision Document and technical reports prepared for the site.

Dudley Development’s comments on the findings of the SA for the site are as follows:

• SA Objective 1: Housing – A minor positive effect is identified. The promoted development for 14 dwellings, would be required to include a proportion of affordable housing, making a contribution towards the identified affordable housing needs of Cambridge.
• SA Objective 2: Access to Services and Facilities – A significant positive effect likely/minor positive effect is identified. The promoted development at land off Limekiln Road in Cambridge is accessible by sustainable modes of transport. Queen Edith's Way and Cherry Hinton Road are on bus routes. The Greater Cambridge Partnership’s Making Connections project identifies Cherry Hinton as a key location on a bus corridor, with improved bus links to Addenbrooke’s and Cambridge Station. There is a dedicated cycle path on Cherry Hinton Road. The Greater Cambridge Partnership’s proposed Fulbourn Greenway project, which includes new dedicated walking and cycling routes and improvements, passes through Cherry Hinton. It is requested that the assessment score for access to services and facilities is changed to ‘significant positive effect likely’ only.
• SA Objective 3: Social Inclusion and Equalities – A negligible effect is identified. No comments.
• SA Objective 4: Health – A minor positive effect/negligible effect is identified. Cherry Hinton contains doctor’s surgeries, leisure centres for residents to improve their health and fitness, and walking and cycling facilities for active travel.
• SA Objective 5: Biodiversity and Geodiversity – A significant negative effect likely is identified. A Preliminary Ecological Appraisal is submitted with the representations to the HELAA site assessment (Site Ref. 40528).The promoted development includes open space. There are parks and open spaces in the local area. The site is close to Cherry Hinton Chalk Pits SSSI. It is noted that Policy BG/BG: Biodiversity and Geodiversity of emerging GCLP is likely to include a requirement for developments to provide mitigation measures to address recreational impacts on nature conservation sites. The promoted development would provide mitigation measures. The promoted development would provide on-site ecological mitigation measures including enhancement of existing trees, planting of species rich calcareous grassland, and providing bird and bat boxes and hedgehog domes. The promoted development would need to make off-site contributions to address recreational pressure on nature conservation sites, in accordance with emerging Policy BG/BG.
• SA Objective 6: Landscape and Townscape. A minor negative effect likely is identified. The site is not visible from the surrounding area. The promoted development would retain the tree within the site and the hedgerows and vegetation at the site boundary. Additional trees and landscaping would be provided within the site to enhance landscape character. It is requested that the landscape and townscape score is changed to ‘negligible effects’.
• SA Objective 7: Historic Environment: A minor negative effect is identified. The promoted development does not affect any heritage assets. It is noted that the site assessment in the HELAA scored the site ‘green’ for historic environment matters. It is requested that the heritage score is changed to ‘negligible effects’.
• SA Objective 8: Efficient Use of Land – A minor negative effect is identified. It is acknowledged that the site is currently greenfield. The density of the promoted development is appropriate for the site, and compatible with the character of the site and the surrounding area.
• SA Objective 9: Minerals: A significant negative effect likely identified. An assessment of the mineral resource at the site will need to be undertaken to determine what resources exist. If there are any suitable mineral resources it is unlikely that the site would be suitable for mineral extraction because of the close proximity of residential areas, and the need for substantial buffers to be provided at mineral extraction sites to protect residential amenity.
• SA Objective 10: Water – A negligible effect is identified. The promoted development would need to meet water conservation standards.
• SA Objective 11: Adaptation to Climate Change – A negligible effect identified. The promoted development would need to meet climate change adaptation requirements.
• SA Objective 12: Climate Change Mitigation – A minor positive effect identified. The promoted development would need to incorporate climate change mitigation measures.
• SA Objective 13: Air Quality – A minor negative effect is identified. The promoted development is small scale. It is accessible by sustainable modes of transport, and there are realistic alternatives to the car for most journeys from the site to reduce potential increases in traffic and associated impacts on air quality. The phasing out of petrol and diesel vehicles and the requirement for new residential developments to include electric vehicle charging points should help to improve air quality. It is not clear what impacts on air quality would arise from the promoted development.
• SA Objective 14: Economy – A negligible effect is identified. The additional housing and affordable housing provided at the promoted development would meet the needs of employees and support the economy of Cambridge. It is requested that the economy score is changed to ‘minor positive effect likely’.
• SA Objective 15: Employment – A significant positive effect likely is identified. The promoted development is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to employment opportunities in Cambridge. All of the employment opportunities are accessible by walking, cycling or public transport.

It is requested that the above comments are taken into account when the SA is updated.