Greater Cambridge Local Plan Preferred Options

The intention to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live is supported. We also consider the principle of this strategy to align with the NPPF and principles of sustainable development.

The First Proposals document states:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, we’ll continue to support infill development and affordable housing on suitable sites, but we do not propose lots of village growth”.

Across the rural areas, owing to their location, communities are not usually served by public transport links that are as well connected or indeed frequent as urban areas. However the reduced services should not be seen as a barrier or restriction to growth as rural areas provide a variety of other services and facilities and work as a network to meet local needs.

Land East of Cambridge Road, Melbourn offers a sustainable location for accommodating residential development. The Site’s position on the edge of Melbourn provides local public transport connections and pedestrian and cycle links, as well as proximity to nearby local amenities including jobs, services and facilities within the village centre.

The emerging Local Plan intends to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live. We support the principle of this strategy and consider that it aligns with the NPPF and principles of sustainable development.
The First Proposals document states:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around larger villages that have good transport links and services, and to support important employment clusters. In smaller villages, we’ll continue to support infill development and affordable housing on suitable sites, but we do not propose lots of village growth”.
Across the rural areas, owing to their location, communities are not usually served by public transport links that are as well connected or indeed frequent as urban areas. However the reduced services should not be seen as a barrier or restriction to growth as rural areas provide a variety of other services and facilities and work as a network to meet local needs.
The proposed development strategy in the First Proposals is currently too restrictive for development in the rural areas and instead provides a barrier to sustainable rural growth. We consider that by preventing growth within the Villages, the emerging Local Plan does not comply with Paragraph 68 of the NPPF (2021) in respect of providing for a sufficient mix of sites across the Greater Cambridge area.
Land West of London Road, Fowlmere, offers a sustainable location for development, which has acknowledged to have scored positively in the Councils’ HELAA assessment (Site ref: 40116). The Site benefits from good transport links, including bus services, which connect the Site to other settlements benefitting from train stations.

The intention of Policy S/JH will be to set out the levels of need in Greater Cambridge that development will meet over the Plan Period 2020 to 2041. The Objectively Assessed Need (OAN) has been calculated at 44,400 new homes, reflecting an OAN of 2,111 homes per year.

The overall housing need should be based upon a minimum (emphasis added) figure, in accordance with NPPF (2021) Paragraph 61. This is to ensure consistency with national policy and the Governments objective of significantly boosting the supply of homes (NPPF 2021; Paragraph 60).

Background studies undertaken to inform the emerging Local Plan (the Employment Land and Economic Development Evidence Study, November 2020 and Greater Cambridge Housing and Employment Relationships Report, 2020) found that the standard housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041 and would risk increasing the amount of commuting required into the Greater Cambridge area. The OAN has therefore been calculated above the standard housing figure set by government and instead is based upon the most likely level of future jobs. This approach to determine a higher number of homes than the standard method is supported and in accordance with Paragraph 61 of the NPPF (2021). It is considered that the future jobs forecast provides exceptional circumstances to justify a higher level of homes based upon current and future demographic trends and market signals, taking into consideration that the Greater Cambridge economy is dynamic and does not align with national or regional job forecasts.

This is also acknowledged by Cambridge City Council, whom state “Cambridge is a successful city with a world-class reputation for education, science and innovation, research and knowledge-based industries, and its historic environment. It is a major focus for employment. The high-value Cambridge Cluster is crucial to the UK’s economy and its international competitiveness.” This underlines the importance of the Cambridge economy, and in turn the importance of supporting this economy through the delivery of sufficient housing, both to prevent long-distance commuting but also to address and prevent worsening of the existing affordability situation.

The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) predicts the future jobs forecast for Greater Cambridge. The Study states that 81% (35,800) of the total jobs forecast in the 2018 adopted Local Plans between 2011 and 2031, were created between 2011 and 2017. This suggests that the economic growth potential in Greater Cambridge has previously been underestimated. As a result, the Study considers two job growth scenarios for the emerging Local Plan:

• Central (medium) growth scenario: considered the most likely outcome taking into account long term patterns of employment. Overall this scenario led to aggregate year on year growth comparable with that between 2001-2017 (and 1991 – 2017). A total of 58,500 jobs.
• Higher growth scenario: a higher outcome placing greater weight on fast growth in the recent past. Overall this scenario led to aggregate absolute year on year growth higher than that seen between 2001-2017 (and 1991-2017), but lower than the ‘fast growth’ period of 2010-2017. A total of 78,700 jobs.

The Study suggests that flexibility is provided in employment land in case the market delivers more jobs than anticipated, and this statement is also reflected within the First Proposals document.

We agree that the Greater Cambridge Local Plan should provide flexibility to facilitate higher job growth, and this should be considered and included within the Draft Local Plan. It is clear from the First Proposals’ evidence base that historically the employment growth across Greater Cambridge has been higher than predicted. This is also notwithstanding the recent introduction of Use Class E, which may see greater movement between the previous Class B Uses and additional employment sites coming forward with the potential intensification of existing employment sites, thereby increasing the need for housing land.

If the Local Plan does not incorporate adequate flexibility, it runs the risk of restricting jobs growth and failing to meet the economic objective of sustainable development, as set out at NPPF (2021) Paragraph 8(a). Flexibility is also required to ensure sustainable economic growth is positively and proactively encouraged, as required by Paragraph 82 of the NPPF.

In providing the required flexibility to facilitate higher jobs growth, it will be necessary for the Greater Cambridge Local Plan to also provide flexibility in the delivery of additional homes to support any additional jobs and to reduce levels of in and out commuting into Greater Cambridge, and the resulting impacts this would have on climate change and congestion. The First Proposal consultation document is clear that commuting from neighbouring authorities or further afield should be restricted, with climate change comprising one of the ‘big themes’ shaping the document.

Whilst it is acknowledged that the Councils are intending to allocate enough sites to provide approximately a 10% buffer to enable flexibility to deal with unforeseen circumstances (this is assumed in circumstances such that a site no longer comes forward for development, or delivery on a site is delayed), flexibility to support higher jobs growth should also be incorporated in the Local Plan.

This would ensure that the emerging Local Plan does not fall short of meeting criterion c) of Paragraph 82 of the NPPF (2021) by failing to provide sufficient housing to support economic growth.

To provide for appropriate flexibility for unforeseen economic growth, a range of additional contingency site allocations should be included within the housing trajectory. This will ensure the Local Plan is positively prepared, justified and effective in accordance with the NPPF (2021) tests of soundness. Land West of London Road Fowlmere lies adjacent to the expanding Manor Farm Business Park and offers a sustainable location for development, is immediately available for development and therefore able to contribute to the Councils’ short to medium housing delivery rates.

It is supported that sites should be developed that can be well-integrated with existing communities to reinforce the distinctive character of the city, towns and villages. It is acknowledged that in the urban areas, sites should be developed at densities making effective use of land (NPPF 2021; Paragraph 11(a). However, a focus on higher development density should not restrict development in sustainable locations in smaller settlements, where high density development may not be appropriate. We do not agree with the statement on page 30 of the First Proposals document “Using less land for development reduces our carbon emissions, and allows more space for nature and wildlife”. High quality development can also, at suitable lower densities, achieve carbon neutrality and provide enhancements for nature and wildlife, along with a wealth of other benefits.

Over-reliance on Existing Allocations
The proposed development strategy in the First Proposals document relies predominantly on existing allocations carried forward from the Adopted 2018 Local Plans and outstanding planning permissions, alongside a limited number of new sites.

The First Proposals document identifies 13 ‘new’ sites, totalling 11,640 homes. Of these, ‘new’ sites, three sites (Eddington - North West Cambridge, Waterbeach New Town and Northstowe), are all existing allocations. An additional 1,000 homes are proposed to be provided at Eddington, and Waterbeach New Town and Northstowe are assumed to achieve faster delivery rates of an additional 750 homes each over the plan period. The growth strategy also includes a site for 2,850 homes at Cambridge Airport comprising safeguarded land from the previous plan, which was also identified as an area for growth part of the Cambridge Local Plan (2003). As set out in greater detail below, noting the significant amount of time that this allocation has been identified within previous Local Plans, we raise significant concerns over the delivery of this site within the timescales anticipated, particularly noting larger sites by their very nature can take longer to be delivered. To encourage a more reliable delivery rate across the plan area we propose that additional sites are allocated to ensure the consistent delivery of dwellings to significantly boost the supply of homes as required by Paragraph 60 of the NPPF (2021).

It should be noted, therefore, that only 9 of these 13 sites are strictly ‘new’. In total the 9 sites will provide 6,246 dwellings (equating to approximately 12.8% of the total 48,840 homes to provide for).

The First Proposals document makes provision for a very limited number of new sites. It is clear that there is a heavy reliance on existing and previously identified sites rolled forward from the adopted Local Plans and many of these sites are on a large scale which also means they typically take longer to be brought forward.

Whilst we recognise that the inclusion of the 10% buffer seeks to provide the flexibility to deal with unforeseen circumstances, should any sites not be brought forward as planned, the heavy reliance on existing allocations and commitments is overly optimistic and along with the very limited number of new proposed site allocations, the 10% buffer is not considered sufficient. The buffer should be increased to a minimum of 20% and further sites allocated to ensure a robust strategy to account for both the current heavy reliance on existing allocations and planning permissions, as well as to accommodate any additional jobs growth as stated above. Such an approach has been adopted in other local authority areas, including most recently across Babergh and Mid Suffolk Local Authorities.
With regards to the deliverability of each of the proposed site allocations in the First Proposals document, we also have significant concerns with the deliverability of Cambridge Airport. The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan, allocated in the 2006 Local Plan and safeguarded in the 2018 Local Plans for development should the site become available.

As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030. The Topic Paper states at Page 116:

“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”. [Own Emphasis]

There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, particularly noting that Cranfield Airfield is only expected to become available from 2030 at the earliest.

Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF (2021).

It is also unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.

Relative to this and the delivery of North-East Cambridge is the requirement for relocating the existing Waste Water Treatment works at North-East Cambridge, the relocation and delivery of which could implicate the larger allocations’ housing rates/timing. Whilst it is understood that a site for the replacement facility has been identified and recent public consultation undertaken (with an intention for a DCO application to be made in 2022/23), it is acknowledged that the larger allocations will be dependent on the delivery of this new facility.

Over-reliance on Windfall Sites
In addition, we also have significant concerns regarding the heavy reliance on windfall within the development strategy, which comprises 5,300 dwellings and equates to almost 11% of the total number of homes to be provided. The NPPF (2021) definition of ‘Windfall sites’ is “Sites not specifically identified for development” whilst the First Proposal document defines ‘Windfall development’ as “Sites which have not been specifically identified as available for development in the Local Plan. They normally comprise previously developed sites that have unexpectedly become available”.

The Housing Delivery Study for Greater Cambridge (AECOM, October 2021) reports that Greater Cambridge has historically achieved a high rate of windfall development. Despite this, Greater Cambridge’s windfall reliance is considered overly high, particularly in light of the Councils’ apparent anticipation that these will mostly comprise previously developed sites. It is also noted that the settlement boundaries have been tightly drawn to the existing urban edges, which is unlikely to provide sufficient flexibility for (greenfield) windfall sites to come forward. It should also be noted that the Green Belt around Cambridge City will also represent a further constraining factor to the delivery of speculative development.

A more appropriate strategy is for the windfall requirement to be reduced and a greater range of sites explicitly allocated, including for the lower order settlements where the current development strategy is for very limited development.

Through the positive allocation of additional sustainable sites at the lower order settlements, this will ensure that the Greater Cambridge growth strategy is genuinely plan-led, as required by Paragraph 15 of the NPPF (2021) and ensure that such growth is supported by the appropriate infrastructure. In addition, by re-allocating a proportion of the anticipated windfall growth to specific sustainable sites, this will provide a greater level of certainty of the anticipated location of growth to the Councils’, developers and the local community compared with the current proposed strategy that will inevitably see a range of speculative development within the rural areas.

Lack of Development within the Villages
At page 75 of The Development Strategy Topic Paper (2021), it is stated:

“Our evidence, Sustainability Appraisal and consultation responses show that a strategy focussed on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure. As such we consider that villages should not be the primary focus for growth within the development strategy.”

Whilst it is not disputed that villages should not be the primary focus for growth, the current strategy is too restrictive and cannot be supported. Appropriate village development can be sustainable in terms of transport and carbon emissions and provide the necessary infrastructure requirements, as would be the case for Land West of London Road, Fowlmere.

The current development strategy, specifically the high percentage of growth to be delivered through windfall sites, is much more likely to lead to unsustainable village development than a strategy whereby the Council has control over ensuring village development is located where there is good access to a high quality public transport network and provides the required infrastructure.

Overall we have concerns regarding the robustness of the development strategy and its ability to bring sufficient land forward for development at a sufficient rate to address the OAN over the plan period as required by NPPF (2021) Paragraph 23.

The Draft Local Plan should increase the distribution of development across the plan area ensuring that a wide range of sites are proposed for development by including a greater number of site allocations in sustainable rural areas with good access to public transport and facilities, such as Land West of London Road, Fowlmere.

As identified by Paragraph 69 of the NPPF (2021), small and medium sized sites (such as Land West of London Road, Fowlmere) can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.

A growth strategy which solely focuses on growth within large scale settlements will also prevent the organic growth of more rural areas, which is needed in order to maintain the vitality of rural communities and support local services (NPPF 2021; Paragraph 79).

The intention of Policy S/JH will be to set out the levels of need in Greater Cambridge that development will meet over the Plan Period 2020 to 2041. The Objectively Assessed Need (OAN) has been calculated at 44,400 new homes, reflecting an OAN of 2,111 homes per year.

The overall housing need should be based upon a minimum (emphasis added) figure, in accordance with NPPF Paragraph 61. This is to ensure consistency with national policy and the Governments objective of significantly boosting the supply of homes (NPPF Paragraph 60).

Background studies undertaken to inform the emerging Local Plan (the Employment Land and Economic Development Evidence Study, November 2020 and Greater Cambridge Housing and Employment Relationships Report, 2020) found that the standard housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041 and would risk increasing the amount of longer distance commuting. The OAN has therefore been calculated above the standard housing figure set by government and instead is based upon the most likely level of future jobs. This approach to determine a higher number of homes than the standard method is supported and in accordance with Paragraph 61 of the NPPF, it is considered that the future jobs forecast provides exceptional circumstances to justify a higher level of homes based upon current and future demographic trends and market signals, taking into consideration that the Greater Cambridge economy is dynamic and does not align with national or regional job forecasts.

This is also acknowledged by Cambridge City Council, whom state “Cambridge is a successful city with a world-class reputation for education, science and innovation, research and knowledge-based industries, and its historic environment. It is a major focus for employment. The high-value Cambridge Cluster is crucial to the UK’s economy and its international competitiveness.” This underlines the importance of the Cambridge economy, and in turn the importance of supporting this economy through the delivery of sufficient housing, both to prevent long-distance commuting but also to address and prevent worsening of the existing affordability situation.

The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) considers the future jobs forecast for Greater Cambridge. The study states that 81% (35,800) of the total jobs forecast in the 2018 adopted Local Plans between 2011 and 2031, were created between 2011-17. This suggests that the economic growth potential in Greater Cambridge has previously been underestimated. As a result, the Study considers two job growth scenarios for the emerging Local Plan:
• Central (medium) growth scenario: considered the most likely outcome taking into account long term patterns of employment. Overall this scenario led to aggregate year on year growth comparable with that between 2001-2017 (and 1991 – 2017). A total of 58,500 jobs.
• Higher growth scenario: a higher outcome placing greater weight on fast growth in the recent past. Overall this scenario led to aggregate absolute year on year growth higher than that seen between 2001-2017 (and 1991-2017), but lower than the ‘fast growth’ period of 2010-2017. A total of 78,700 jobs.

The Study suggested that flexibility is provided in employment land in case the market delivers more jobs than anticipated, and this statement is also reflected within the First Proposals document.
We agree that the Greater Cambridge Local Plan should provide flexibility to facilitate higher job growth, and this should be considered and included within the Draft Local Plan. It is clear from the First Proposals’ evidence base that historically the employment growth across Greater Cambridge has been higher than predicted. This is also notwithstanding the recent introduction of Use Class E, which may see greater movement between the previous Class B Uses and additional employment sites coming forward, thereby increasing the need for housing land.

If the Local Plan does not incorporate adequate flexibility, it runs the risk of restricting jobs growth and failing to meet the economic objective of sustainable development, as set out at NPPF (2021) Paragraph 8(a). Flexibility is also required to ensure sustainable economic growth is positively and proactively encouraged, as required by Paragraph 82 of the NPPF.

In providing the necessary flexibility to facilitate higher job growth, it will be necessary for the Greater Cambridge Local Plan to also provide flexibility in the delivery of additional homes to support any additional jobs and to reduce levels of in and out commuting into Greater Cambridge, and the resulting impacts this would have on climate change and congestion. The First Proposal consultation document is clear that commuting from neighbouring authorities or further afield should be restricted, with climate change comprising one of the ‘big themes’ shaping the document.

Whilst it is acknowledged that the Councils are intending to allocate enough sites to provide approximately a 10% buffer to enable flexibility to deal with unforeseen circumstances (this is assumed in circumstances such that a site no longer comes forward for development, or delivery on a site is delayed), flexibility to support higher jobs growth should also be incorporated in the Local Plan.

This would ensure that the emerging Local Plan does not fall short of meeting criterion c) of Paragraph 82 of the NPPF (2021) by failing to provide sufficient housing to support economic growth.

To provide for appropriate flexibility for unforeseen economic growth, a range of additional contingency site allocations should be included within the housing trajectory. This will ensure the Local Plan is positively prepared, justified and effective in accordance with the NPPF (2021) tests of soundness. Land to the East Side of Cambridge Road Melbourn offers a sustainable location for development and is immediately available for development, therefore able to contribute to the Councils’ short to medium housing delivery rates.

Development should be assigned across the settlement hierarchy, with development proportionate to the provision of services and facilities and the public transport network. The proposed policy direction relating to the settlement hierarchy includes restrictions on the indicative maximum scheme sizes that will comprise acceptable windfall development for each settlement tier. Coupled with the overall development strategy for only a small number of site allocations within the rural area, the ability for sustainable developments to come forward is overly restrictive.

Paragraph 009 (Reference ID: 67-009-20190722) of the Planning Practice Guidance (PPG) states “a wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness”. It is not considered that there is robust evidence to demonstrate that the policy direction putting a limit on development in the rural areas is appropriate.

Applying restrictions on the maximum amount of development that is appropriate to any particular tier is not considered to be a justified approach, as the sustainability of settlements and the availability of suitable sites for development can vary between settlements within the same tier. A more appropriate strategy would be to identify additional site allocations within the villages, considering each of the rural settlements on an individual basis. This would assist in meeting the Government’s objective of significantly boosting the supply of homes by ensuring that that a sufficient amount and variety of land can come forward where it is needed (NPPF 2021; Paragraph 60).

It should also be acknowledged that new development can increase the sustainability of an existing settlement through the provision of additional services and facilities, or through enhancing existing services and facilities. New development that is well related to the existing settlement can also have a positive impact upon the long term viability of a place through indirect spending from future occupiers and through supporting rural schools and facilities.

Fowlmere - Settlement Hierarchy - Group Village
Fowlmere is identified in the Settlement Hierarchy as a “Group Village”. In accordance with S/SH, the Group Villages can accommodate indicative maximum scheme size of 8 dwellings, and exceptionally consist of up to about 15 dwellings where this would make the best use of a single brownfield site.

Notwithstanding our fundamental concerns with regards to the lack of development allocated to the Villages and the overly prescriptive restrictions on the quantum of development to come forward within the various tiers of the settlement hierarchy, we are also concerned by the lack of assessment given to Fowlmere in terms of its ability to accommodate growth.

The settlement hierarchy divides the Group Villages into two key categories, those with good transport links and those without good transport links. It is assumed that this division of the Group Villages is as a result of the findings within the transport evidence base, notably the Existing Transport Conditions Report (2020). We have significant concerns with regards to this approach which appears to adopt a simplistic method of categorising settlements and their ability to accommodate development.

Those Group Villages identified as benefitting from very good public transport access were subsequently assessed in terms of their ability to accommodate rural allocations for housing (as confirmed through the Councils’ Development Strategy Topic Paper 2021). Whilst it is noted on Page 263 of the Development Strategy Topic Paper 2021 that all Group Villages were assessed using the points system, only those considered to have good existing or proposed sustainable transport links were assessed in further detail in terms of their ability to accommodate development.

Fowlmere was not further assessed as it was not considered to benefit from very good transport links. We disagree with this conclusion and consider this to be an omission in the Councils’ assessment as a result of overlooking a key bus service within the settlement, as discussed below.

The Councils’ Existing Transport Conditions Report (2020) fails to identify a bus service which serves Fowlmere (Stagecoach 915). This bus service provides frequent links between Cambridge/Trumpington Park and Ride and Royston. At particular points in the day, bus services 915 and 31 collectively service Fowlmere with two buses an hour.

Bus Service 915 Bus Service 31
06:46 -
07:46 07:27
08:46 -
09:46 09:37
10:46 -
11:46 11:07
12:46 12:37
13:46 -
14:46 14:07
15:46 -
17:22 -
18:22 -
19:22 -

This bus route also connects Fowlmere with nearby Melbourn and Foxton, offering existing and future residents the ability to access a train station. It should also be noted that Fowlmere is a 6 minute journey to Foxton, which benefits from a train station and busway, and also a 9 minute journey to Melbourn, which also benefits from a train station. Fowlmere therefore represents a sustainable location for accommodating development.

A number of the Group Villages that are considered to benefit from good transport links, including Longstanton, are only currently serviced by an hourly bus service into Cambridge, which is less frequent than Fowlmere (which is occasionally throughout the day serviced by two bus services). Fowlmere is also located 2.6 miles from the train station in Foxton, which provides frequent links with Cambridge City. It is therefore unclear why Fowlmere has not been included within the Group Villages considered to benefit from good transport links.

The Councils’ Development Strategy Topic Paper 2021 clearly states that only those sites that were tested in the HELAA and identified as potential development options in the better served villages were subsequently subject to site specific consideration for allocation and for sustainability appraisal.

It is strongly considered that the failure of the evidence base to consider all modes of transport and bus services within Fowlmere and its connectivity to the surrounding settlements represents a flaw in the overall settlement assessment. Modes of public transport should not be viewed in isolation, rather should also be viewed collectively, with future residents being able to use both bus and train links to travel across the Greater Cambridge area, rather than a single mode of transport. This has subsequently resulted in sites that are being promoted within Fowlmere not being properly considered for development and not being subject to an independent site assessment.

Employment Opportunities
It is acknowledged that an existing employment site off The Way, Fowlmere, is subject to a pending Outline planning application for mixed use development comprising the demolition of the existing buildings and the erection of 45 dwellings and a new office building (reference 21/00542/OUT).

A large proportion of this employment site was previously occupied by Welding Alloys Ltd. However, Welding Alloys has moved its production element of the business to France which has left an extensive vacancy of buildings on site. The buildings on the site are understood to be purpose built for Welding Alloys and despite enquiries during the marketing of the site, the units have not been desirable to new potential occupiers, with more suitable premises elsewhere, including other premises within Fowlmere.

Despite the lack of suitability of the existing employment site leading to proposals for redevelopment, the Outline planning application includes a new office building as part of the scheme, which will be a modern and fit for purpose building. This demonstrates that Fowlmere remains a desirable location for new employment.
The desirability and suitability of Fowlmere as an employment location is reinforced by the presence of long-standing employers within the village. One of these is Ion Science (a world leader in gas detection equipment and research), who has been a key employer in Fowlmere since 1989.

In August 2021, planning permission was granted (reference 21/02683/FUL) for the erection of a new 3,050 sq.m Science Research and Development Office for Ion Science at the Butts Business Centre on the Manor Farm Business Park. The new facility will supplement production and management options at the company’s existing headquarters.

Ion Science is an established company and values Fowlmere as an employment location and are committed to staying there. The provision of the new Science Research and Development Office will allow Ion Science to continue operating in the local area and will provide additional jobs. Despite the proposed redevelopment of the existing employment site off The Way, it is evident that Fowlmere is a desirable employment location.

As well as desirable, Fowlmere is also a sustainable employment location. This is demonstrated through the car parking thresholds for the recently approved Ion Science application (21/02683/FUL). The required parking standard for the size of unit was 29 spaces, whilst the application was approved on the basis of 17 car parking spaces, taking into consideration the travel patterns of existing Ion Science employees. This demonstrates that access to Fowlmere is not reliant on the private car and sustainable modes of transport are available.

Fowlmere is an employment destination and a desirable location for companies, as shown through Ion Science’s desire to retain within the settlement. To ensure that employment growth is supported by sufficient housing, Fowlmere should accommodate housing sites, failing which could be at risk of falling short of meeting criterion c) of Paragraph 82 of the NPPF (2021). Land West of London Road Fowlmere lies adjacent to the employment opportunities at the Manor Farm Business Park, offers a sustainable and suitable location for development and is immediately available.

It is supported that sites should be developed that can be well-integrated with existing communities to reinforce the distinctive character of the city, towns and villages. It is supported that in the urban areas, sites should be developed at densities making effective use of land (NPPF Paragraph 11(a). However, a focus on higher development density should not restrict development in sustainable locations in smaller settlements, where high density development may not be appropriate. We do not agree with the statement on page 30 of the First Proposals document “Using less land for development reduces our carbon emissions, and allows more space for nature and wildlife”. High quality development can also achieve carbon neutrality and provide enhancements for nature and wildlife, along with a wealth of other benefits.

Over-reliance on Existing Allocations
The proposed development strategy in the First Proposal document relies predominantly on existing allocations carried forward from the Adopted 2018 Local Plans and outstanding planning permissions, alongside a limited number of new sites.
The First Proposals document identifies 13 ‘new’ sites, totalling 11,640 homes. Of these, ‘new’ sites, three sites (Eddington - North West Cambridge, Waterbeach New Town and Northstowe), are all existing allocations. An additional 1,000 homes are proposed to be provided at Eddington and Waterbeach New Town and Northstowe are assumed to achieve faster delivery rates of an additional 750 homes each over the plan period. A site for 2,850 homes at Cambridge Airport comprising safeguarded land from the previous plan, which was also identified as a growth area as part of the Cambridge Local Plan (2003). As set out in greater detail below, noting the significant amount of time that this allocation has been identified within previous Local Plans, we raise significant concerns over the delivery of this site within the timescales anticipated, particularly noting larger sites by their very nature can take longer to be delivered. To encourage a more reliable delivery rate across the plan area we propose that additional sites are allocated to ensure the consistent delivery of dwellings to significantly boost the supply of homes as required by Paragraph 60 of the NPPF (2021).
It should be noted, therefore, only 9 of these 13 sites are strictly ‘new’. In total the 9 sites will provide 6,246 dwellings (equating to approximately 12.8% of the total 48,840 homes to provide for).
It is clear that the First Proposals document makes provision for a very limited number of new sites. There is a heavy reliance on existing and previously identified sites rolled forward from the adopted Local Plans and many of these sites are on a large scale which also means they typically take longer to be brought forward.
Whilst we recognise that the inclusion of the 10% buffer seeks to provide the flexibility to deal with unforeseen circumstances should any sites not be brought forward as planned, the heavy reliance on existing allocations and commitments is overly optimistic and along with the very limited number of new proposed site allocations, the 10% buffer is not considered sufficient. The buffer should be increased to a minimum of 20% and further sites allocated to ensure a robust strategy to account for both the current heavy reliance on existing allocations and planning permissions, as well as to accommodate any additional jobs growth as stated above. Such an approach has been adopted in other local authority areas, including most recently across Babergh and Mid Suffolk Local Authorities.
We have concerns with the deliverability of Cambridge Airport. The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan and safeguarded in the 2018 Local Plans for development should the site become available. As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030. The Topic Paper states at Page 116:
“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”.
There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, when it is only expected to become available from 2030 at the earliest.
Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF.
It is also unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.
Relative to this and the delivery of North-East Cambridge is the requirement for relocating the existing Waste Water Treatment works at North-East Cambridge, the relocation and delivery of which could implicate the larger allocations’ housing rates/timing. Whilst it is understood that a site for the replacement facility has been identified and recent public consultation undertaken (with an intention for a DCO application to be made in 2022/23), it is acknowledged that the larger allocations will be dependent on the delivery and relocation of this new facility.

Over-reliance on Windfall Sites
In addition, there are concerns regarding the heavy reliance on windfall within the development strategy, which comprises 5,300 dwellings and equates to almost 11% of the total number of homes to be provided. The NPPF definition of ‘Windfall sites’ is “Sites not specifically identified for development” whilst the First Proposal document defines ‘Windfall development’ as “Sites which have not been specifically identified as available for development in the Local Plan. They normally comprise previously developed sites that have unexpectedly become available”.
The Housing Delivery Study for Greater Cambridge (AECOM, October 2021) reports that Greater Cambridge has historically achieved a high rate of windfall development and we have not sought to interrogate this evidence at this stage to confirm whether this conforms with NPPF Paragraph 71. Nonetheless, this windfall reliance is considered high, particularly in light of the Councils’ apparent anticipation that these will mostly comprise previously developed sites. It is also noted that the settlement boundaries have been tightly drawn to the existing urban edges, which is unlikely to provide sufficient flexibility for (greenfield) windfall sites to come forward.
A more appropriate strategy is for the windfall requirement to be reduced and a greater range of sites explicitly allocated, including for the lower order settlements where the current development strategy is for very limited development.
Through the positive allocation of sustainable sites at the lower order settlements, including Minor Rural Centres, this will ensure that the Greater Cambridge growth strategy is genuinely plan-led, as required by Paragraph 15 of the NPPF (2021) and ensure that such growth is supported by the appropriate infrastructure. In addition, by re-allocating a proportion of the anticipated windfall growth to specific sustainable sites, this will provide a greater level of certainty of the anticipated location of growth to the Councils, developers and the local community compared with the current proposed strategy that will inevitably see a range of speculative development within the rural areas.
Land to the East Side of Cambridge Road, Melbourn offers a logical and sustainable location for residential growth. The Site’s position on the edge of Melbourn provides a sustainable location for new development with local public transport connections and pedestrian and cycle links, as well as proximity to nearby local amenities including jobs, services and facilities within the village centre. The Site also lies in close proximity to Melbourn Science Park, which has recently achieved approval for a further extension, providing employment for a number of companies engaged in pharmaceuticals, biochemistry and mechanical engineering.

Lack of Development within the Villages
At page 75 of The Development Strategy Topic Paper (2021), it is stated:
“Our evidence, Sustainability Appraisal and consultation responses show that a strategy focussed on village development would be unsustainable, in particular regarding transport and associated carbon emissions, but also for supporting delivery of required infrastructure. As such we consider that villages should not be the primary focus for growth within the development strategy.”
Whilst it is not disputed that villages should not be the primary focus for growth, the current strategy is too restrictive and cannot be supported. Appropriate village development can be sustainable in terms of transport and carbon emissions and provide the necessary infrastructure requirements, as would be the case for land to the east side of Cambridge Road, Melbourn.
In fact, the current development strategy with the high reliance on windfall sites is much more likely to lead to unsustainable village development than a strategy where the Council has control over ensuring village development is located where there is good access to a high quality public transport network and provides the required infrastructure.
Overall we have concerns regarding the robustness of the development strategy and its ability to bring sufficient land forward for development at a sufficient rate to address the OAN over the plan period as required by NPPF (2021) Paragraph 23.
It is considered that there should be a greater focus on a wide range of sites being brought forward for development, by including a greater number of site allocations in sustainable rural areas with good access to public transport and facilities, such as land to the east side of Cambridge Road, Melbourn.
Smaller sites can often be brought forward quicker and provide greater certainty of delivery, particularly in the early part of the plan period. As acknowledged by Paragraph 79 of the NPPF (2021), housing in rural areas can maintain the vitality of rural communities and provide opportunities for villages to grow and thrive, especially where this will support local services.
As discussed later in this Section, it is clear that Melbourn is a sustainable location and able to support additional housing growth, which is evidenced through the two allocations proposed for the settlement. Melbourn should, however, be allocated a greater proportion of growth that is comparable to its identification as the largest village in the south west of the district (Development Strategic Topic Paper 2021; 262).

Development should be assigned across the settlement hierarchy, with development proportionate to the provision of services and facilities and the public transport network. The proposed policy direction relating to the settlement hierarchy includes restrictions on the indicative maximum scheme sizes that will comprise acceptable windfall development for each settlement tier. Coupled with the overall development strategy for only a small number of site allocations within the rural area, the ability for sustainable developments to come forward is overly restricted.
Paragraph 009 (Reference ID: 67-009-20190722) of the Planning Practice Guidance (PPG) states “a wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness”. We are unaware of any robust evidence to demonstrate that the policy direction putting a limit on development in the rural areas is appropriate.
Applying restrictions on the maximum amount of development that is appropriate to any particular tier is not considered to be a justified approach, as the sustainability of settlements and the availability of suitable sites for development can vary between settlements within the same tier. A more appropriate strategy would be to make additional site allocations, considering the rural settlements on an individual basis. This would help meet with the Government’s objective of significantly boosting the supply of homes by ensuring that that a sufficient amount and variety of land can come forward where it is needed (NPPF 2021, Paragraph 60).
New development can increase the sustainability of a wider settlement through the provision of additional services and facilities, or through enhancing existing services and facilities. New development that is well related to the existing settlement can also have a positive impact upon the long term viability of a place through indirect spending from future occupiers.

Melbourn (Minor Rural Centre)
Melbourn is identified in the Settlement Hierarchy as a ‘Minor Rural Centre’. We do not disagree with Melbourn’s position in the Settlement Hierarchy and endorse its recognition as a sustainable location and able to accommodate additional residential growth.
The policy direction in the First Proposals document, however, is that Minor Rural Centres will support an indicative maximum scheme size of 30 dwellings. It is evident that Melbourn is capable of accommodating larger sites, with the proposed allocation for 120 dwellings at land to the west of Cambridge Road (Policy reference S/RRA/CR). We do not support the overly prescriptive restriction on the quantum of dwellings to come forward within this tier in the Settlement Hierarchy, which does not align with its position and identification as the largest district within the south west of the district.

The proposed policy direction to include settlement boundaries around settlements is supported. Settlement boundaries play an important role in controlling development, however they should not be used as a basis for preventing otherwise sustainable development from coming forward. It is noted that the First Proposals states that boundaries will be defined to take into account the present extent of the built-up area and planned new development. However, the proposed development strategy to restrict the number of dwellings in certain tiers of the settlement hierarchy and the low number of site allocations proposed for the rural areas will prevent sustainable development from being brought forward unless further sites are allocated for development and included within the settlement boundary.
Should the Councils wish to continue to apply a heavy reliance on windfall development to accommodate growth, the settlement boundaries will need to be drawn more loosely around existing settlements, particularly those beyond the outer Green Belt boundary, to allow for speculative development to come forward.
Consideration should also be given to the provision of Cambridge South new station, which is anticipated to increase capacity along the existing rail line, through settlements such as Meldreth. Such infrastructure will increase the sustainability of existing settlements such as Melbourn, enabling further development to come forward within this location. Land to the East Side of Cambridge Road offers a sustainable location for residential growth located along the Melbourn Greenway, which will enhance linkages between Melbourn and Cambridge, providing a green active travel into and out of the city for walkers, cyclists and horse riders. The greenway states that a key benefit is its convenient location for Melbourn Science Park, recognising the importance of this Science Park as an employment destination and its contribution to the wider Greater Cambridge area.

The proposed policy direction to include settlement boundaries around settlements is supported. Settlement boundaries play an important role in controlling development, however they should not be used as a basis for preventing otherwise sustainable development from coming forward.

It is noted that the First Proposals states that boundaries will be defined to take into account the present extent of the built-up area and planned new development. However, the proposed development strategy to restrict the number of dwellings in certain tiers of the settlement hierarchy and the low number of site allocations proposed for the rural areas will prevent sustainable development from being brought forward unless further sites are allocated for development and included within the settlement boundary.

Should the Councils wish to continue to apply a heavy reliance on windfall development to accommodate growth, the settlement boundaries will need to be drawn more loosely around existing settlements, particularly those beyond the outer Green Belt boundary, to allow for speculative development to come forward.

Fowlmere
In particular, the adopted settlement boundary for Fowlmere is tightly drawn around the existing built edge of the settlement, restricting the ability for additional greenfield sites to come forward as windfall development.
On the basis that the settlement boundary remains unchanged through the Greater Cambridge Local Plan, it is assumed that windfall development within the settlement is anticipated to be delivered through brownfield sites.
Fowlmere predominantly comprises residential development on small plots serviced by a number of facilities, including but not restricted to a church, public house, primary school, business units and business park. There are no clear opportunities for redevelopment of previously developed land within the settlement.

A review of the sites promoted through the recent call for sites also emphasises the lack of brownfield sites available, with only one previously developed site promoted for development.

This, together with the way in which the settlement boundary is shown, suggests that there is very limited opportunity for additional growth to be delivered within Fowlmere during the emerging Local Plan period and we raise concerns with regards to the Councils’ overall spatial strategy, which could be detrimental to the vitality of these Group Villages.

Land West of London Road Fowlmere lies adjacent to the existing settlement boundary as well as to employment opportunities at the Manor Farm Business Park to the north, is suitable for development and is immediately available, thereby able to contribute to the vitality of this Group Village. In addition, the proposed development would deliver low carbon housing, electric vehicle charging at every dwelling and promote low water consumption, therefore positively contributing to reducing carbon emissions and mitigating the effects of climate change.