Greater Cambridge Local Plan Issues & Options 2020

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Southern & Regional development (Joscelyn) identifies that it is essesntial for a Local Plan todemonstrate that it has discharged its statutory Duty to Co-Operate with neighbouring authorities and other relevant organisations to ensure that it is sound. Without due consideration of cross-boundary issues, including housing requirements and economic functions, a Plan will not have demonstrated its requirements as contained within the Duty to Co-Operate. Although the Greater Cambridge Local Plan is at an early stage of its preparation, it is vital that is able to demonstrate that it has taken into appropriate consideration cross-boundary issues. These issues will influence the strategies of the new Plan, including the approach in achieving residential and other types of development across the Local Plan area. Those issues which have been identified within the Issues and Options document address significant considerations which will inform the trajectory of the Plan during the preparation process. It is considered that those areas of concern relating to cross-boundary factors are appropriate. Although it is recognised that the Cambridge HMA is relatively self-contained, with a travel to work area similar in size and pattern to the housing market area itself, this should not result in a Plan which reduces the significance in cross-boundary impacts on the ability of the Planning Authorities in delivering their housing needs. For instance, given that the neighbouring Authorities are generally unconstrained, with no Green Belt, it is likely that they will be able to meet their own needs within their own jurisdiction. As such, there may be lesser need for Greater Cambridge to assist in accommodating cross-boundary housing numbers. However, it is considered that the emerging Local Plan must take into account the impacts that a rapidly growing local economy will have on these cross-boundary issues. This includes the influence of strategic infrastructure projects, such as East-West Rail and the Oxford-Cambridge Expressway which will open the housing market up further to additional influxes of people commuting to the expanding job market within Cambridge. This in turn will have a material impact on strategic residential need as a result of increasing demand and exacerbate housing costs. A careful approach to cross-boundary considerations is therefore required, to ensure that the new Plan remains responsive to these issues given that they arise from outside the Local Plan area and are beyond the control of the Local Authorities. Summary of Comments: The list of cross-boundary considerations is appropriate, however the Local Plan should acknowledge the degree of importance and significance to each.

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Southern & Regional Developments (Joscelyn) contend that the emerging Local Plan should identify the strategic issues that will influence the plan area over the new Plan period and beyond. It is considered that although the themes that have been identified attempt to overcome significant issues that will have wide impacts, such as Climate Change; the approach to this is not considered to be coherent. It is understood that issues relating to Biodiversity and Climate Change are important, however the Plan's regard to these factors is inappropriate. Considerations relating to ecology, the natural environment and Climate Change are interlinked through the strategic theme of environmental sustainability and so should inform the strategic approach comprehensively. Presently, the approach of the Plan inappropriately provides emphasis towards environmental sustainability, which results in a reducing the value of social and economic sustainability and the associated contribution to realsigin environmental benefit. A more positive approach would be for these factors to be attributed equal significance so that the objectives of the Plan can be satified by delivering changes positively through economic growth and addressing social inequalities . The current arrangement of big themes is contrary to the National Planning Policy Framework, which asserts that all aspects of sustainable of development must demonstrate economic, social and environmental as equal components in achieving sustainable development. This is in the effort to ensure development that will not compromise the ability of future generations from meeting their own needs. Southern & Regional Developments (Joscelyn) consider that for the emerging Local Plan to provide an ambitious and positive approach to addressing climate change and environmental issues, economic and social factors must be recognised as informing development solutions. The delivery of enivronmental objectives should not be to the detriment of the other elements of sustainable development. Greater Cambridge is experiencing unprecedented levels of growth and so it is vital that the new Plan identifies an appropriate and deliverable strategy to meet the demands of this growth. This includes sufficient land and sites to meet the specific needs of Cambridge city, as well as the rural requirements of the larger area of South Cambridgeshire. Presently, there is insufficient emphasis on these other aspects of development. Summary of Comments: The big themes do not provide the correct balance between the elements of sustainable development, with inappropriate emphasis on climate change.

Wellbeing and Social Inclusion, Great Places, Climate Change, Biodiversity and Green Spaces

Southern & regional Developments (Joscelyn) believe that achieving net zero carbon emissions as an objective of the plan is an ambitious goal which does comply with paragraph 16a of the National Planning Policy Framework's assertion that Plan-making should be ambitious. However, the NPPF also stresses that with this aspiration, Plan-making should be deliverable. Given the cost and complexities involved in achieving such a target, European Property ventures (Cambridge) consider that this is not a realistic objective over the life time of the Plan alone, particularly given the proposed timeframe that is until 2040, not 2050. Whilst the Plan should incorporate aspirational efforts in realising a net zero carbon Plan area, these efforts should not be to the detriment to the existing communities with Plan area and not to the other aspects of the Plan in ensuring sustainable development is achieved. As such, the requisite levels of development must be planned for and implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land are implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions beyond the plan period, when infrastructure is to be delivered and standards beyond national requirements may give rise to issues of viability and deliverability if restrictive planning policies relating to this objective are applied.

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Southern and Regional Developments(Joscelyn) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date and covers the minimum time frame. The timescale of any plan should however also respond to long-term requirements and opportunities including major improvements to infrastructure It is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond this proposed plan period so that a sustainable strategic approach is adopted that has longevity. This is demonstrated by the strategic plan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positively to address the associated strategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040, whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adopts. Major infrastructure projects that will provide for long term requirements have already been identified at the New Towns of Northstowe and Waterbeach. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Swavesey must be recognised as a method of delivering a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Kingfisher Way, Cottenham can demonstrate this important contribution to assist in meeting the demanding housing needs for Greater Cambridge. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing to cover this period.

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Southern and Regional Developments(Joscelyn) consider that the emerging Greater Cambridge Local Plan must plan for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review has recognised that the Combined Authority Area (Cambridgeshire and Peterborough) has experienced a higher rate of economic growth than forecast. This is a significant indicator that the new Plan for Greater Cambridge must consider actively planning for through delivery of a significantly higher number of homes. Furthermore, if implemented into the spatial strategy, an increase in the number of homes to be delivered will allow a better degree of flexibility that will otherwise not be available if the Plan only provides for the minimum. Given the evidence that is available, it would not be an appropriate or sound approach if the Plan were to avoid strategising for a higher number of homes than the government figure suggests - instead the government figure should be consdiered the minimum level required. If the economic trend is to continue within the Plan area, which the CPIER report establishes, it would be a failure of the Plan's statutory requirement to "make sufficient provision" for housing numbers and boost delivery, as asserted in the NPPF. If the Plan is to support the economic growth of the area over the new Plan period, a higher housing quantum will need to be incorporated into strategic policy. If insufficient homes are delivered over the new period, this will supress any potential for economic growth within the Plan area and result in diminishing the expansion of the jobs market in Cambridge and South Cambridgeshire. Summary of Comments: Higher quantum of housing is needed to assure flexibility and to support the significant economic growth experienced in the Plan area.

Southern & regional Developments (Joscelyn) consider that it is important for the Plan to deliver a varied range of housing, particularly with respect to bedroom size and tenure mix that reflects the findings of the Strategic Housing Market Assessment. However, to ensure that development can truly address local needs and respond to locational characteristics, such development requirements for residential proposals should not be overly or inappropriately prescriptive. Schemes for residential development should be required to deliver a housing mix that most appropriately caters for the needs of the community it will serve and should not be controlled by a restrictive development management policy which applies particular obligations for development to deliver at the strategic level. It is recognised that affordability is a major issue within Greater Cambridge, particularly within the rural areas and villages. It is considered that there is a need for the emerging Local Plan policy to address this issue and ensure that a mix of types and tenures is catered for across the whole of the plan area. Similarly, where settlements are dominated by a particular housing type or scale, there should be the opportunity through emerging plan policy for Development Frameworks to be suitably amended. Southern & Regional Developments (Joscelyn) maintain that although the new Plan should include policy guidance on housing types, including size and tenure mix, such guidance should be supported by the most up to date evidence and have the ability to respond directly to specific local requirements. The wording of any policy should reflect this and provide suitable provisions for housing mix to be informed by local circumstances and market influences. Taking into account the size of the plan area and the varied characteristics of the area, it is important that any policy guidance includes an appropriate degree of flexibility in its requirements for housing development. For example, housing mix requirements will differ between settlements across the entire Plan area, given that the needs of rural South Cambridgeshire will be different from those within Cambridge City. It is therefore important that any attempt to include specific housing mix and type requirements within development management policies should ensure a degree of flexibility and acknowledge locational considerations. Summary of Comments: Policies for housing mix/type should not be prescriptive and should reflect the requirements as identified in the latest SHMA.

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Southern and Regional Developments(Joscelyn) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options across the plan area and reduce travel distances within communities so reducing climate impacts. They support the direction established by the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the Dairy Farm site at Boxworth End, Swavesey benefits from good access to social infrastructure, with close walking distance, with amenities to includes a medical clinic, secondary school, post office and village shop. As these are within close proximity to the site, it should be recognised that the site is a sustainable location to accommodate new development. Furthermore, the site is not designated Green Belt and so its development will not result in wider impacts or harm to the strategic purposes of it. Summary of Comments: As such, review of Green Belt sites alone will not go far enough in ensuring an adequate spatial strategy, given that there are suitable locations for development that exist beyond it and located in sustainable settlements that are able to and have the capacity to accommodate new development to meet the needs of the new Plan period.

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It is considered that the Local Plan should be flexible towards development of both jobs and homes on the edge of villages. It is considered that the Local Planning Authority should be more flexible to the scale of development within the village framework and should allow a more flexible approach to development on the edge of villages. The adopted settlement hierarchy of the South Cambridgeshire Local Plan recognises that there are sustainable villages within the District that can appropriately accommodate levels of growth that can both contribute towards meeting the strategic needs of the Plan area and a flexible approach to development should be applied to the most sustainable settlements. The site controlled by Southern and Regional Developments (Joscelyn) at Kingfisher Way, Cottenham represents a deliverable and appropriate example of an edge of village site that can be sensitively developed to contribute towards the strategic requirements of the new Local Plan. Cottenham is a higher order settlement within the settlement hierarchy that indicates that the village benefits from an extensive and established range of services and amenities. The site is not designated as Green Belt and offers a good opportunity to provide additional housing in a sustainable location. It is considered that an extensive landscape strategy can be adopted for the site which will contribute to the softening of the development edge. A spatial strategy which considers development at the edge of villages should ensure that it maximises sustainable development opportunities. It is considered that site at Kingfisher Way, Cottenham represents such an opportunity. Summary of Comments: Development at the edges of villages is supported, as it is a sustainable approach which can contribute towards meeting the OAN of the Plan area.

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It is advanced on behalf of Southern & Regional Developments (Joscelyn) that the approach of the South Cambridgeshire Local Plan should encourage further development at sustainable villages through the expansion of existing village frameworks. The application of overly prescriptive guidance of what is then acceptable at such villages is not considered to be compliant with the National Planning Policy Framework's assertion to support development where it is demonstrated to be required whilst also achieving the best and most efficient use of land. It is acknowledged that development within rural settlements must respond to their context, including historical built form and rural character. However, it is maintained that many of these settlements demonstrate sustainability credentials that complies with the objectives of the Framework. Access to public transport and existing services are primary considerations that should support growth within the villages, particularly where these are recognised in the adopted settlement hierarchy at Rural Centres, Minor Rural Centres and Group Villages. Achieving appropriate densities in line with the requirements of the Framework currently cannot be achieved by existing policies, particularly with respect to the opportunities to deliver housing on infill sites and achieve affordable homes. The nature of development at villages is also dictated by the quantum of housing to be attributed to such settlements village frameworks and therefore, a more flexible approach should be adopted by the new Plan in order to achieve varying levels of development at such locations. Summary of Comments: A more flexible approach is considered appropriate to ensure that efficient and appropriate densities are achieved in sustainable village locations.