Greater Cambridge Local Plan Issues & Options 2020

Response to Question 2 A number of sites were promoted in a variety of locations to the call for sites process in March 2019 on behalf of Ely Diocesan Board of Finance (EDBF). The representations to the Issues & Options consultation document will refer to those promoted sites where relevant.

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Neither agree nor disagree

Partially agree, partially disagree. The four potential big themes - climate change, biodiversity and green spaces, wellbeing and social inclusion, and green spaces - are related to the social and environmental objectives of sustainable development and are supported. However, there is no economic theme, despite the fact that the Cambridge and Peterborough Devolution Deal commits the authorities in the area to planning to double economic output by 2040 and Greater Cambridge will have a significant role in delivering that commitment. It is requested that there emerging GCLP must include a specific economic theme. The economic theme will be important in terms of ensuring that housing and economic growth are aligned and also in terms of selecting suitable employment allocations. EDBF is promoting land off Fulbourn Old Drift in Fulbourn, located adjacent to Capital Park, for employment development for Class B1 office and research and development uses. It is also requested that the relationship between the big themes (and the additional economic factor) and the overarching theme of sustainable development is further explained in the emerging GCLP. Paragraph 8 of the NPPF is clearly framed such that sustainable development is the overarching theme of the planning system to which all other themes relate. Therefore, sustainable development should be the overarching theme for the emerging GCLP, to be consistent with the NPPF and in order to avoid one of the big themes being given greater importance than another.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding which sites to allocate for development, the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. It should be acknowledged that in some instances net biodiversity gains would be more appropriately provided on alternative or existing sites rather than within a development site. It is suggested that the emerging GCLP should also include a policy mechanism that allows for net biodiversity gains to be delivered on alternative sites. The sites promoted by EDBF would retain any ecological features on site and seek to provide ecological enhancements. It should be noted that for most sites there is sufficient space within the site to include those ecological enhancement measures in conjunction with development, or EDBF owns other land in the vicinity that could accommodate offsite ecological enhancements. The circumstances at each site will need to be assessed in terms of their suitability and availability for ecological enhancements.

It is considered that meeting housing and affordable housing needs is part of the well-being and social inclusion theme because housing falls within the social objective of sustainable development (as set out in Paragraph 8 of the NPPF). There are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer commuting. Paragraph 8 and Chapter 8 of the NPPF identifies the other factors that relate to the wellbeing and social inclusion theme, which are about creating well-designed and safe developments, providing access to services and facilities, and providing open space. It is suggested that to achieve ‘good growth’ the emerging GCLP will need to allocate suitable sites that deliver housing and affordable housing, are accessible to services and facilities, include open space and recreation facilities. The sites promoted by EDBF are typically located within and on the edge of villages. It is considered that additional residential development in these villages would support the existing services and facilities within those villages and maintain their vitality and viability, which is consistent with Paragraph 78 of the NPPF. It is considered that the sites promoted for development by EDBF would contribute towards ‘good growth’ for those villages and for Greater Cambridge.

Section 4.3.3 of the Issues & Options consultation document identifies the factors that are relevant to the creation of safe and inclusive communities. As set out in the response to Question 16, there are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer commuting. It is considered that the emerging GCLP should include a development strategy that seeks to meet housing and affordable housing needs in full and locate housing closer to employment opportunities to reduce in-commuting. Paragraph 61 of the NPPF expects a wide range of house types, sizes and tenures to be provided to meet a variety of housing needs including affordable housing. The developments promoted by EDBF would provide housing and affordable housing, and as such would contribute towards the delivery of inclusive communities.

Paragraph 91 of the NPPF seeks to deliver healthy, inclusive and safe places, and identifies a number of approaches to support healthy lifestyles. It promotes social interaction through mixed-use developments, strong neighbourhood centres, street layouts that include pedestrian and cycle connections, and active street frontages for example. It enables and supports healthy lifestyles, by providing green infrastructure, sports facilities, local shops, access to healthier food, allotments, and layouts that encourage walking and cycling for example. NHS England Healthy Towns Initiatives identified ten principles to deliver healthy places, which relate to the provision of health services, meeting local and community health needs, and development design matters. In terms of design matters it is suggested that compact neighbourhoods, active travel, healthy eating opportunities, play and leisure facilities would contribute towards the delivery of healthy places. It is considered that the sites promoted for development by EDBF would be consistent with guidance and initiatives to support healthy lifestyles. The majority of the villages where EDBF is promoting sites for development include services such as convenience stores, allotments, and health services. The sites promoted for development by EDBF would either provide open space and/or are accessible to existing areas of open space and recreation. All of these services and facilities would support healthy lifestyles. Those sites are also accessible to the services and facilities available in the villages by walking and cycling. In addition, the sites promoted by EDBF at Fulbourn, Stapleford and Sawston for example are well-related to the transport infrastructure improvements proposed by the Greater Cambridge Partnership including new cycle routes and greenways. Those new cycle and greenway routes typically connect villages to employment sites, railway stations, and Cambridge. The availability of walking and cycling routes within and close to the villages where EDBF is promoting sites means that residents could travel by active modes of transport, leading to healthier lifestyles.

Very important

Very important. The NPPF is clear that planning policies should create the conditions in which businesses can invest, expand and adapt and that significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. Paragraph 20 requires strategic policies to set out an overall strategy for the pattern and scale of development including employment development. Paragraph 81 expects planning policies to set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, and to allocate sites to meet the anticipated need. 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. The Cambridge and Peterborough Devolution Deal commits the authorities in the area to planning to double economic output by 2040. Greater Cambridge is situated within the Oxford to Cambridge Arc, which is an area of significant economic strength and opportunity and a key economic priority for the Government. Greater Cambridge is experiencing strong economic growth which is expected to continue into the future. The growth potential of the area is acknowledged at a national and regional level. There is already a commitment to substantially increase economic output. Therefore, it will be very important for the emerging GCLP to support economic growth in Greater Cambridge.

Paragraph 82 of the NPPF states that planning policies and decisions should recognise and address the specific locational requirements of different business sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified the national importance of knowledge intensive businesses located in the Greater Cambridge area. Therefore, it is requested that sufficient land and business space should be identified in the emerging GCLP to meet the ongoing needs and growth of knowledge intensive businesses in the Greater Cambridge area. EDBF is promoting land off Fulbourn Old Drift in Fulbourn (located adjacent to Capital Park) and land at Milton Park & Ride for employment development for Class B1 office and research and development uses. As set out in the call for sites submission, there are no constraints to development at this site. The allocation of these sites would meet the needs of knowledge intensive businesses within an established location for these uses.

The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 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. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs, and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: • There is a growth strategy in place to promote and facilitate additional growth; • Strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally, and; • An authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met.

Yes, somewhat agree

Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. 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.