Planning Statement
Commercial Estates Group Cambridge South East September 2012 Commercial Estates Group Cambridge South East September 2012
Table of Contents
1 INTRODUCTION...... 1
2 TOWARDS A DEVELOPMENT STRATEGY FOR SOUTH CAMBRIDGESHIRE ...... 3 The importance of Cambridge ...... 3 Urban Intensification ...... 4
3 HOUSING GROWTH OPTIONS...... 8 Housing and Employment Growth Imbalance ...... 8
4 EMPLOYMENT – THE NEED TO BUILD HOUSES CLOSE TO JOBS ...... 12
5 BROAD LOCATIONS FOR SUSTAINABLE DEVELOPMENT ...... 14
6 BROAD LOCATION 7 – LAND BETWEEN BABRAHAM ROAD AND FULBOURN ROAD...... 16 Benefits of the Proposal ...... 17 Social Infrastructure and Community Facilities...... 19 Recreation & Open Space...... 19 Summary of Benefits of the Proposal...... 20
7 CONCLUSIONS...... 21
Appendix A – Housing and Employment Technical Paper
Appendix B – Response to Sustainability Appraisal
Appendix C – Green Belt
Appendix D - Transport
Appendix E – Master-planning Issues and Principles Commercial Estates Group Cambridge South East September 2012
1 INTRODUCTION
1.1 This planning submission document provides the justification for the need to release land from the Cambridge Green Belt, known as Cambridge South East (identified by the Council as Broad Location 7), to ensure that the most sustainable development option is delivered to serve the development needs of Cambridge and South Cambridgeshire District Council to 2031. Cambridge South East is being promoted by CEG which has a development agreement with the landowners. The site is highly sustainable, available and deliverable in the plan period.
1.2 The work of Commercial Estates Group (CEG) spans office, residential, retail, industrial and mixed- use sectors. This experience also encompasses working in partnership with communities and Local Authorities, using unique expertise to find viable solutions to complex development and planning policy issues. CEG's success is attributed to the quality and experience of its high-calibre team in the four core business areas of strategic planning, development, asset and investment management. This enables CEG to seek comprehensive solutions, manage risk, promote developments and deliver the most exemplar projects across its entire portfolio.
1.3 CEG has sourced a project team appropriate to the promotion of land south of Fulbourn Road and North of Babraham Road, Cambridge (known as Broad Location 7 in the City and SCDC Draft Issues and Options Document). The project team includes:
CEG (Promoter);
Bidwells (Planning, Landscape, Green Belt and Sustainability);
Civic Studio (Masterplanning);
Bryan G Hall (Transport);
Brookbanks (Infrastructure & Services);
MKA Ecology (Ecology);
CgMs Archaeology (Archaeology);
Curtin & Co (Political Contact Strategy)
1.4 The project team believes the site represents the most sustainable release of land from the Green Belt for new development to serve Cambridge and SCDC.
1.5 The draft conceptual proposals for the site currently envisage the development of a new residential led, mixed use neighbourhood for the city and SCDC, comprising:
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A range of between 3,000 and 4,000 dwellings as appropriate of market, affordable and key worker dwellings;
9.7 hectares of R&D/B1a Employment Development;
Two Primary Schools
Very Substantial Protected Areas/Landscaping maintaining the setting for Cambridge
A neighbourhood centre;
Public open space;
Strategic landscaping;
Highways and other supporting infrastructure.
1.6 The site straddles Cambridge City and South Cambridgeshire District Council borders with the majority of the proposed development likely to take place within the Cambridge City boundaries including approximately 3,000 dwellings and the employment development. Approximately 1,000 dwellings are expected to be provided within SCDC.
1.7 The site currently falls within the Cambridge Green Belt and would require revisions to the Green Belt boundary to facilitate the development, but the development will be contained within areas of the site which do not impact on the Visual Zone of Influence of Cambridge.
1.8 Subject to the site's allocation, by both Cambridge City Council and SCDC within their respective Local Development Frameworks, the site will help to meet the respective Councils' future housing land supply requirements by delivering sustainable development within the Plan period to 2031.
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2 TOWARDS A DEVELOPMENT STRATEGY FOR SOUTH CAMBRIDGESHIRE
The importance of Cambridge
2.1 In considering the spatial options available to accommodate the required level of housing and employment growth, it is first important to reflect upon the historic planning policy approaches adopted in the past and the patterns of growth that have developed as a result.
2.2 Ever since the publication of the Holford Report in the 1950s Cambridge has sought to protect the historic character of the City by limiting its size and dispersing housing to villages and towns beyond the Cambridge Green Belt. With the exception of high technology related industries, a policy of restraint towards housing population and certain economic growth has therefore been operated within the Cambridge area up until the last ten years.
2.3 Whilst this has largely managed to achieve its purpose in limiting the size of the City and protecting its character, efforts to limit employment growth within and close to Cambridge and encourage the spin out of hi-tech clusters across the wider Sub-region and other centres have proved difficult and only partially successful. Most hi-tech companies have proved unwilling to move too far from Cambridge amid concerns that the benefits of expertise and technology linkages would be reduced and it would be further from their core labour supply. Whilst there is now some cluster development in the surrounding market towns and outlying business parks within the Sub-region, job growth has significantly outstripped house building in the immediate vicinity of Cambridge and the area has seen significant house price rises. As a result, many of those employed in Cambridge live some distance away from the City resulting in longer distance, car-borne commuting into Cambridge and surrounding market towns and villages.
2.4 The 2003 Cambridgeshire and Peterborough Structure Plan acknowledged the deficiencies in the spatial planning policies adopted for the Sub-region over previous decades and the resultant imbalances and unsustainable travel patterns that this was generating. In doing so, it proposed a fresh approach to the development of the Sub-region with a change in emphasis in the spatial planning policies which sought to direct a greater level of housing growth to the City and its immediate area by setting out a hierarchy for directing new growth in the Sub-region in a more sustainable and balanced manner. Accordingly, new development was to be directed in the following sequence:
i Within the built up area of Cambridge;
ii On the edge of Cambridge subject to a review of the Green Belt boundary;
iii A new settlement at Longstanton/Oakington (Northstowe);
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iv Market towns, previously established new settlements and rural centres.
2.5 As part of this Spatial Strategy, a fundamental review of the Cambridge Green Belt was undertaken to identify sites which could be released from the Green Belt. This identified a series of sites on the edge of the City to provide sustainable urban extensions and thereby accommodate a step change in housing delivery within and on the edge of the City.
2.6 In addition, the Structure Plan also provided for the development of a new settlement at Northstowe which provided a new focus for significant new development in the Sub-region over the longer term. A limited amount of development was also then directed to a number of the larger Rural Centres within SCDC and the various market towns within the wider Sub-region.
2.7 Yet as explained in our Technical Appendix A, despite this shift in emphasis since the adoption of the 2003 Structure Plan, housing delivery has remained below the levels required to meet ongoing housing requirements and address the long-standing issues of acute housing need and lack of affordability of new housing.
2.8 Nevertheless, it is worth noting that between 2005 and 2007, prior to the recession, the rate of house-building within the City and SCDC did increase and there were signs that housing delivery was being achieved closer to the prescribed targets than had been the case previously. This suggests that the Councils' approach towards the provision and delivery of new housing fostered by the adoption of the Structure Plan in 2003 and the subsequent Cambridge Local Plan and South Cambridgeshire Local Development Framework was beginning to work in achieving a step change in housing delivery within the Sub-region. Given that this is now proving successful CEG respectively suggests that this should continue.
2.9 It can be inferred that in normal market conditions, the adoption of a sustainable plan for growth within the area will need to increase housing delivery which could help to address the chronic housing shortages within the Cambridge area.
Urban Intensification
2.10 Urban intensification within Cambridge itself was identified as the first preference for accommodating new development within the Cambridgeshire Structure Plan and subsequently within the East of England Plan. This will in many cases be the most sustainable option since it will involve development in the most sustainable settlement within the Sub-region where there is ready access to a range of employment, shopping, leisure, cultural and other needs by a range of modes of transport. This will also provide some potential for the development of previously developed land in a number of cases.
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2.11 Given the limited number of such sites and the likely constraints associated with delivery of development on these sites, it is not considered that the Greater Cambridge Area’s housing and employment needs can be met solely through such a limited strategy and that other spatial growth options need to be fully considered in order to ensure that the identified needs are appropriately met over the Plan period to 2031.
Urban Extensions
2.12 Urban extensions are highly sustainable forms of development which allow for strategic development needs to be met through the delivery of significant levels of new housing and other complementary uses, whilst maximising the benefits associated with proximity and accessibility to existing employment opportunities, services and facilities. In many instances they also provide opportunities to enhance and supplement existing services and infrastructure to the benefit of the local area.
2.13 The provision of urban extensions to the City formed a large component of Cambridge's growth strategy in the 1950s, 1960s and 1970s with the development of 'White Land' on the edge of the City which had been excluded from the original Green Belt boundaries. The use of urban extensions to accommodate the City's and SCDC's strategic growth needs then became far more limited in the 1980s and 1990s as the reserve of White Land inside the inner Green Belt boundary had been largely used up. Rather than seek to review Green Belt boundaries, the Local Planning Authorities pursued a policy of dispersing growth to the villages and market towns beyond the Green Belt.
2.14 The 2003 Cambridgeshire and Peterborough Structure Plan brought with it a shift in Policy back towards the development of urban extensions on the edge of the City in order to rebalance the area's growth in a more sustainable manner. A series of urban extension sites was identified following a review of the Cambridge Green Belt. These included sites at NIAB and North West Cambridge in the north-west of the City, Clay Farm and Trumpington Meadows on the Southern Fringe and Cambridge East. Most of these sites are only now beginning to come forward in delivering new development, a reflection of the long lead-in times associated with delivering such schemes. However, in the case of Cambridge East, which was to form the main urban extension site for a new urban quarter of up to 8,000 new dwellings and other uses, the vast majority of the site will no longer be coming forward for development, at least in the period up to 2031, following the decision of Marshalls to remain at their current site for the foreseeable future.
2.15 Given the scale of the on-going housing needs of the area, identified in Appendix A, and with Cambridge East no longer able to deliver significant growth in the current Plan period, it is considered that there is a critical need to undertake a fundamental review of the Cambridge Green
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Belt in order to identify and release further sites on the edge of the City to accommodate new urban extensions. These would provide a sustainable and appropriate growth option to accommodate the area's future development needs in a manner which would ensure development is easily accessible to a wide range of services and facilities by a range of modes of travel.
New Settlements
2.16 It is appropriate that new settlements should form part of the consideration of options for housing and employment growth in order to provide a longer-term focus for new housing and employment growth in the Sub-region.
2.17 However, it is both unreasonable and unrealistic to expect further new settlement sites to meet SCDC's housing and employment needs over the next 20 years whilst Northstowe is still uncertain to be delivered satisfactorily by 2031. The difficulties associated with bringing forward development at Northstowe underline the challenges associated with the delivery of new settlements due to the large amount of upfront infrastructure that needs to be provided and the associated long lead-in times and costs of providing this. This provides a huge burden on the developer and ensures that such sites are not only slow to come forward but slow to fully implement.
2.18 Whilst there has been some suggestion from Central Government that Waterbeach forms an appropriate location for a further new settlement, it is considered that any such attempt to build out a second new settlement alongside Northstowe would seriously undermine and threaten the viability of the two developments since these would place undue pressure on the marketability of Northstowe. It is therefore considered that new settlements are not a viable option to accommodate the housing and employment needs of SCDC over the period to 2031.
Summary
2.19 It is therefore clear that the focus of any spatial strategy for growth within the Sub-Region should remain in line with the hierarchy established within the Cambridgeshire Structure Plan and subsequently be carried forward by the East of England Plan. Thus, where feasible and deliverable, a significant proportion of additional growth should be accommodated around Cambridge through the development of sustainable urban extensions to Cambridge.
2.20 The current Local Plan has not been successful in some respects as it has not yet delivered enough housing to meet real need. Housing need is very acute with the City's and SCDC's housing waiting lists growing longer year on year and in April 2012 stood at 4,054 for SCDC. House prices remain very high and beyond most people's means. The Council's current housing commitments are not nearly sufficient to meet these identified needs. Until sufficient land is
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released through allocations in the new Local Plan the housing problem will not be solved. A Local Plan can only be considered successful if policies have the positive effect of delivery on the ground. It is considered that Cambridge South East is part of the solution to this problem. This is explained further in Appendices A - E.
2.21 The proposed strategic objectives for the place SCDC should be in 2031 must result in a positive outcome. The basis of the objectives must be based on sustainability (quite correctly) with Economic, Social and Environmental enhancements to be delivered. For example, we agree with paragraphs 2.4, 2.5 and 2.7 as new housing and jobs for Cambridge should also serve the needs of the Sub-Region as development in and on the edge of Cambridge represents the most sustainable solution for a proportion of the housing for SCDC.
2.22 We agree that it was necessary for the City and SCDC to implement the change in growth strategy introduced by the 2003 County Structure Plan which was required to redress the imbalance between houses and jobs in, and close to, Cambridge. This strategy remains the most sustainable strategy as it formed the basis for the 2006 Local Plan releasing land from the Green Belt and allocating a number of urban extensions. The NPPF requires new development to be as sustainable as possible, thus the strategy must continue in a managed way to redress the imbalance between housing and jobs in and close to Cambridge.
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3 HOUSING GROWTH OPTIONS
Housing and Employment Growth Imbalance
3.1 The Greater Cambridge Area has seen considerable economic growth over the last few decades driven by the area’s dynamic economy and the ‘Cambridge Phenomenon’. This growth has placed severe pressures on the local housing market and provided particular challenges in terms of the delivery of suitable housing of the right type, the right quantity, in the right location whilst protecting the environment and quality of life.
3.2 Historically, previous policies sought to protect the historic character of Cambridge by dispersing housing to market towns and villages beyond the Green Belt. As a result, with job growth within and around the City outstripping housing supply, a large proportion of the City’s workforce has been forced to live some distance from the City with high rates of commuting into the City.
3.3 To emphasise this key issue it is worth noting that there are approximately 60,000 daily employment related trips (by all travel modes) which originate in South Cambridgeshire. Of these, approximately 21,000 (ie 35%) travel to Cambridge city and a further 2,000 travel to Cambridge Science Park (ie 4%).
3.4 There are approximately 42,000 employment car trips per day originating in South Cambridgeshire: of these, approximately 14,000 travel to Cambridge city (ie 34%) and a further 1,700 travel to Cambridge Science Park (ie 4%).
3.5 With regard to in-commuting into Cambridge, census data indicates that there are approximately 80,000 daily work related trips (by all travel modes) which have a destination in Cambridge and Cambridge Science Park. Of these, approximately 33,000 trips (ie 41%) originate in Cambridge with the remainder originating from outside of the city. Approximately 29% of employment related work trips in Cambridge and Cambridge Science Park originate in South Cambridgeshire.
3.6 There are approximately 46,000 daily employment related car trips which have a destination in Cambridge and Cambridge Science Park. Of these, approximately 24% originate in Cambridge, with the remainder travelling from outside of the city. Approximately 35% of employment car trips in Cambridge and Cambridge Science Park originate in South Cambridgeshire.
3.7 It is acknowledged that the census data referred to above is over ten years old. Transport provision in Cambridge has changed in the interim, most notably with the opening of the Cambridge Guided Busway. Nevertheless, the census data is the most up to date information available and it confirms that the imbalance between jobs and housing availability in Cambridge has lead to significant levels of commuting into the city by car.
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3.8 The County Council, in its consultation document for the Transport Strategy for Cambridge and South Cambridgeshire, states that Cambridgeshire commuters already travel further to work than the England average (16.15km compared to 13.31km). The County Council warns that, “unless the imbalance between housing supply and demand in Cambridge is addressed, and affordable housing is available, travel distances are likely to increase”.
3.9 With housing delivery in and around the City highly constrained and unable to meet supply, house prices and affordability ratios have seen significant increases. Affordability ratios have also risen significantly since 2001 in Cambridge City and SCDC with house price growth having far outstripped earnings growth over this period with the cost of the average house within SCDC now over eight times the average wage. This has resulted in many people, even on above average wages, unable to access the housing market.
3.10 The significant increase in house prices over the last few decades outstripping earnings growth has led to growing issues in the local Cambridge housing market with regard to housing need. A range of evidence over recent years has confirmed that there are significant levels of housing need within the Cambridge area. Evidence produced as far back as 1999 to inform the production of Regional Planning Guidance Note 6 (RPG6) for the East of England highlighted issues of acute housing need within the Cambridge Market.
3.11 Affordable and key worker housing needs have consistently increased over the last decade. The latest assessment of housing need within the Sub-region produced a part of the Cambridge Sub- region SHMAA 2010 update (published September 2011) indicates that the Sub-region and Cambridge in particular have significant levels of housing need. The 2010 SHMA Update identifies a backlog of 845 affordable dwellings per annum between 2009/10 and 2014/15 required to address existing housing needs in SCDC.
3.12 Despite these levels of housing need, the delivery of new housing within SCDC over the last ten years has been fairly limited and has fallen well short of the housing targets. The 2003 Cambridgeshire Structure Plan proposed housing targets of 1,176 dwellings per annum in SCDC. The East of England Plan, which was adopted in 2008, continued this annual requirement.
3.13 Actual housing delivery rates within SCDC have fallen significantly below both of these targets with housing completions ranging from 525 dwellings in 2001/02 and peaking at 1,274 dwellings in 2007/08 before subsequently falling back during the recession. However, on only one occasion in the last ten years has housing delivery within South Cambridgeshire met the lower housing requirements set out within the 2003 Structure Plan and the higher annual East of England target has never been met.
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3.14 Whilst the recession and associated economic difficulties have reduced some of these pressures to a limited degree, the Cambridge Housing Market is continuing to experience significant pressures. Demand for housing has remained strong due to the growth in the number of households, strong local economy and the backlog of need. However, housing delivery has failed to meet identified needs or to match wider demand and, as a result, continued housing shortages have led to significant increases in house prices and house price affordability. The underlying issues and challenges highlighted in the development of the Cambridgeshire Structure Plan therefore remain as relevant now as they have at any time over the last 15-20 years with planning policies having so far failed to address these underlying issues.
3.15 We have given consideration to the approach of SCDC in setting out three options for housing growth. Our representation to Issue 4 demonstrates the fundamental flaws in the Council's approach as it does not plan for meeting real housing need to 2031. However, this can be remedied before submission Draft publication.
3.16 We have prepared a technical paper (Appendix A) which critically analyses SCDC's evidence base including its housing and employment technical papers. The technical paper also examines the way SCDC has interpreted housing and employment need for the plan period and how that approach has arrived at the current growth options for consultation and whether those options respond effectively to the approach employed.
3.17 We consider that there is an acute dwelling need which justifies a requirement in accordance with a new option (Option 4) which would need to be developed over the plan period. We agree that there are advantages of 'high' levels of growth which are reflective of the three bullet points stated under a high housing growth Option. The perceived disadvantages stated under the higher growth Options are not, however, a real outcome. The sustainable release of appropriate land from the Green Belt to accommodate new allocations is necessary in order to make a major contribution to the overall need, supply and location of housing close to jobs. The location of housing beyond the Green Belt is in our view unsustainable. (See our representations to Question 9 – Development Strategy and Appendix D on Transport.)
3.18 The primary purpose of Green Belt around Cambridge (to protect the historic setting) would not be undermined if a detailed review is carried out and subject to effective and exemplar masterplanning. Effective masterplanning would also plan positively for infrastructure and transport in the consideration that the edge of Cambridge is the most sustainable location for growth.
3.19 The new local plan needs to release sufficient land to meet housing need in an area where people want to live. The most sustainable locations are on the edge of Cambridge. The Council must
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seek to bring house prices down by providing sufficient housing numbers to meet demand so that market prices are affordable. SCDC must plan for need. Given the scale of housing need SCDC should seek to deliver as much housing as possible in the most sustainable location. Such an approach would accord with the principles set out in the NPPF. The LPA will also need to consider data from the 2011 Census which will be available later this year/early 2013. In this respect, we reserve our position on the Growth Options and will make further representations on this issue to forthcoming consultations.
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4 EMPLOYMENT – THE NEED TO BUILD HOUSES CLOSE TO JOBS
4.1 Given the continued and growing importance of the Knowledge Economy to the UK's future economic prospects in the 21st Century and given the importance of the Greater Cambridge economy and associated hi-tech cluster to the UK Knowledge Economy, that it is essential that appropriate plans and policies are put in place to facilitate the sustainable growth of the Cambridge economy with SCDC. Whilst this clearly needs to be managed in an effective manner such that the quality of the area's historic and natural environments are maintained, it is nonetheless essential to the UK's national economic interests that the local authorities and their strategic partners within the area develop appropriate policies to deliver the sustainable development within the Greater Cambridge area.
4.2 We believe SCDC should recognise and emphasise the crucial need for balance between existing jobs together with new job creation and new homes and its cumulative importance to the Cambridge sub-regional economy and 'UK plc'. Such omission would, in our view, be remiss to a sound plan. Our representations to Question 3 proffer the need to refer to this issue to build a strong and competitive economy through sustainable development for homes and jobs together and close to Cambridge. This approach is the most sustainable option rather than new homes and jobs growth in surrounding settlements where new development will add to the increase in longer distance vehicle movements. Planning new growth at distances from Cambridge is unsustainable, is a drain on resources of energy and time thereby reducing the effectiveness of the Cambridge economy.
4.3 We support a high job growth Option (ii) on the clear relationship between homes and jobs. The importance of the Cambridge economy locally, regionally, nationally and internationally must not be jeopardised by not planning for economic growth. Cambridge is too important to neglect on this issue. Planning for too few jobs is dangerous and literally unproductive. We are concerned with the anomalies of employment forecasting models. We have prepared a technical assessment of the Council's approach in planning for new jobs to 2031 (see Appendix A). We comment on historic job growth trends where data used over the last ten years is unreliable. Longer term trends offer a more robust assessment. It is essential that the planning for new jobs must be aspirational in order to meet the objectives of economic policy. We have assessed job growth and employment land requirements by analysing job growth projections, the need to replace lost sites (to housing), the need for choice of range and quality of sites to meet current and future business needs which require flexible floorspace as current provision is insufficient, poorly located and too restricted.
4.4 Our analysis of the various growth options provided, suggests that Option iii is the minimum required to support economic needs of SCDC (surrounding Cambridge) given its strategic
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importance to the economy. It is also important to stress that demographic projections will require re-assessment following the release of the 2011 Census data later this year/early 2013.
4.5 SCDC must seek to ensure that the growth options for new housing and new jobs readdress any existing imbalance between these two important delivery items. The significant absence of dwellings to both meet previous, existing and future dwelling requirements, and the need for realistic job growth to protect and enhance the future operation of the economic engine of Cambridge in the national interest must be given the most serious attention in the new Local Plan. If SCDC fails to plan positively (which it is required to do) on these important strategic priorities, then house prices will increase further and commuting will increase, both of which are unsustainable. In consequence the plan will be found unsound.
4.6 It is obvious there is insufficient physical capacity within the City's urban area for the necessary future housing and employment needs. Urban extensions into the Green Belt are necessary as this is the most sustainable option for development. There is insufficient physical capacity in the urban area of Cambridge to deliver the growth which is needed.
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5 BROAD LOCATIONS FOR SUSTAINABLE DEVELOPMENT
5.1 The most suitable solution, which will require a co-ordinated approach between the City and SCDC, is to maintain the most sustainable planning policy basis established by the former RPG for East Anglia, RPG6, Structure Plan P1/1 and East of England Plan May 2008, which follow the sequential approach to development in order of preference:
In the built up area of Cambridge, subject to consideration of environmental capacity
On the periphery of the built up area of Cambridge on land released from the Green Belt
At the new settlement of Northstowe
On land within or on the peripheries on the market towns
5.2 This philosophy must continue as it reflects the most sustainable approach (endorsed by Inspectors) to new strategic scale development. On the basis that the built up area of Cambridge will not be able to physically accommodate the number of dwellings and employment land needed (including the back-log of unmet need) the new Local Plan will need to identify sustainable sites to release land from the Green Belt to accommodate at least 12,500 dwellings on the edge of Cambridge.
5.3 The Council has undertaken a Green Belt Appraisal on the Inner Green Belt 2012 which is based on two Green Belt reviews undertaken in 2002: the Cambridge City Council Inner Green Belt Review 2002 and Landscape Design Associates 2002 Cambridge Green Belt Study.
5.4 Whilst some of the Cambridge South East site is acknowledged to be of Lower Importance to the Green Belt by the City Council in Figure 1 of the 2012 report, it is considered that much more of the site is of lower value than has been recognised. This is due to the limitations of the original methodology. Not only is the methodology limited, it is not consistent, comprehensive or transparent. It is not in enough depth to properly identify land which could be released from the Green Belt.
5.5 We conclude that an in-depth, robust and comprehensive review must be undertaken to accommodate housing needs in the most sustainable locations of Cambridge.
5.6 We respectfully suggest that the Council's potential capacity for up to 2060 new homes within the built up area of Cambridge has been overestimated and the actual capacity is considered to be in the region of 750. There are a number of sites which are unlikely to be delivered on the ground within the Plan period because the redevelopment of some of these sites relies on existing businesses being relocated, and some sites are subject to planning application/consent for non
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residential uses. It is also noteworthy that the 800 dwelling element of the 2060 which relates to 'windfall' should not be included within the capacity calculations as the City has a record of under- delivery and therefore the 800 dwellings could contribute toward the 20% additional dwelling requirement to provide a realistic prospect of achieving the planned supply as required by Policy 47 of the NPPF.
5.7 This shortfall in the SHLAA capacity will necessitate the sustainable release of appropriate Green Belt land on the edge of Cambridge (see Appendix A).
5.8 It is noteworthy that Option 9 makes reference to allocated sites within existing commitments however, there are a number of errors in the Council's calculations and additionally a number of the existing allocations are unlikely to be delivered on the ground in the Plan period (they are also left over from previous Plans) with several sites due to receive planning consent for non residential uses. We estimate that the figure of 10,612 dwellings stated in Option 9 is inaccurate and calculate a more accurate commitment of 10,442 dwellings.
5.9 The combination of the overestimated SHLAA capacity and existing commitments has implications for policy as it will not be possible to redevelop urban sites to the degree to which the City Council requires. This will mean that a sustainable alternative must be employed to ensure delivery is achieved within the Plan period. The sustainable alternative is the release of land in the Green Belt in the most appropriate location(s).
5.10 We consider Option 16 to be the most appropriate site for an urban extension. It is highly sustainable, available and deliverable in the plan period. The site is considered in detail in the next section of the report.
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6 BROAD LOCATION 7 – LAND BETWEEN BABRAHAM ROAD AND FULBOURN ROAD
6.1 We support Broad Location 7 under Issue 12 as the site represents the most sustainable release of Green Belt land for necessary mixed use development. We have prepared evidence to demonstrate:
It is the most sustainable location to help meet the Cambridge area's unmet need for dwellings and job growth
It is the best location to help meet the lack of physical capacity for new dwellings within the urban area
It is the most appropriate and sustainable in connectivity terms for all modes of transport away from the A14/M11 close to Babraham Park and Ride and Addenbrooke's Hospital.
6.2 A number of statements within the Council's assessment of this Broad Location 7 (in Appendix 2 of the plan) are incorrect and need to be changed to ensure correct, factual information. Key stakeholders need to be fully briefed in order to understand the numerous attributes and sustainability credentials of this site in considering its release from the Green Belt.
6.3 As the Council acknowledges, areas of the site are of low significance. We consider that a much larger part of the site is in fact of lower significance and elevated land will not be subject to development. This will be demonstrated in a Masterplan which will be submitted shortly. With exemplar urban design the development would benefit the existing local community.
6.4 CEG has undertaken detailed investigations into the Council's evidence base on its approach to the Green Belt and its interim Sustainability Appraisal. Our findings confirm that the Council's Green Belt approach and Sustainability Appraisal can be improved to ensure that the Plan is found sound. Detailed objections have been prepared in response to the Interim Sustainability Appraisal and Green Belt Options. These are detailed at Appendix B and C of this statement.
6.5 By employing CEG's approach to the Green Belt and Interim Sustainability Appraisal it is clearly demonstrated that Broad Location 7 is the most appropriate Option to release Green Belt land for sustainable strategic scale mixed development.
6.6 Broad Location 7 is able to deliver sustainable development by making economic, social and environmental gains through the mixed development proposal, providing a balance of jobs, homes and supporting these elements by exemplar movement, community, educational servicing, infrastructure and recreation planning (forming the social function); whilst respecting and
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enhancing the Green Belt and countryside element by improving public access and increasing biodiversity in the area (public open space, creating chalk grassland and wildlife corridors).
6.7 This planning submission and the associated technical appendices on Green Belt, Sustainability, Transport and Masterplanning demonstrate that the following evolving important draft Local Plan Issues can be successfully employed and incorporated into the proposal.
Securing high quality design (Question 28)
Enhancing landscape character (Question 30)
Contributing positively to biodiversity (Question 32)
The creation and enhancement of green infrastructure (Question 33)
The provision of superfast broadband (Question 65)
Following the principles of developing new communities (Question 82)
Following the principles for planning for sustainable travel (Question 97)
6.8 A very detailed review of the Green Belt should be undertaken. The assessment undertaken by the Council at Appendix B is insufficient to form a refined (and sound) judgement to be made about the broad locations and possible Green Belt releases.
Benefits of the Proposal
6.9 The proposed development, once complete, could provide up to 4,000 new residential units; 1,000 of which would be in SCDC. The site could therefore make a significant contribution to the two Districts' residual future housing requirements.
6.10 In addition, in line with the Greater Cambridge Community Strategy objective of achieving socially balanced communities, up to 40% or 1,600 dwellings (400 in SCDC) of the total number of residential units to be provided as part of the proposed development could be set aside as affordable housing, subject to viability testing. This level of provision would make a significant contribution towards affordable housing supply and meeting the two District's respective affordable housing needs and thereby helping to reduce the housing waiting lists. Indeed, these would represent approximately 10% of the City Council's current housing waiting lists.
6.11 It is therefore clear that the proposed development has the potential to provide a wide range of housing types to meet a range of housing needs and requirements within the local Housing Market Area.
6.12 Of particular significance in this context, the location of the site on the south east fringe of Cambridge and close to the major employment area focussed on Addenbrooke's Hospital ensures
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it is ideally located in order to meet the needs of Addenbrooke's and its workforce and providing key worker housing for the benefit of lower paid key workers based at the hospital. As such the proposed development is ideally placed to help to address the longstanding concerns of the Hospital Trust regarding the lack of affordable housing close to the Hospital and associated impacts on the attraction and retention of nursing and other medical and support staff at the hospital.
6.13 The proposals will make a significant and positive contribution to the local economy and help to provide appropriate commercial floorspace to meet the future needs of ARM and other high- technology firms within the area and contribute towards the City's future job growth. In doing so, the scheme will respond to the Government's objectives contained within its recent Plan for Growth.
6.14 The proposals are, therefore, consistent with and supportive of a range of national, regional and local economic strategies and objectives including those within the NPPF and the Greater Cambridge Community Strategy.
6.15 The Housing and Employment Technical Appendix (A) has highlighted the growing difficulties of many on lower and moderate incomes accessing the housing market. In many cases, this has resulted in existing residents moving out to the market towns within the Sub-region and has affected the ability of key workers to move to the area to take up vacancies. This is turn has impacted on staff recruitment and retention, particularly in the public sector and has led to various skill shortages. It is therefore important to the social and economic balance of the area that there is greater access to the housing market for a wider spectrum of the local community.
6.16 In providing a significant amount of new housing, including a mix of tenures and dwelling types, the proposed development will help to meet the underlying demand for new housing within the area. In doing so, it will ensure that the housing needs of various sectors of the local community are met including those on the Council's housing waiting lists and those on lower and moderate incomes who are currently struggling to access the housing market.
6.17 This will in turn help to ensure that Cambridge receives a more balanced community with a broad spectrum of people across all socio-economic classifications and with a more balanced workforce to meet the wide range of skills and requirements to sustain the jobs market and to service 'Cambridge UK PLC'.
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Social Infrastructure and Community Facilities
6.18 The proposed development will seek to incorporate adequate provision of social infrastructure and community facilities in order to both meet the needs of the future residents of Cambridge South East and to contribute towards the needs of the wider community within the area.
6.19 It is envisaged that a range of new social and community facilities will be provided within the proposed Cambridge South East Development in order to help meet the day-to-day needs of residents and provide a mixed and balanced community that contributes to the wider needs of the area without placing undue pressure on existing social and community infrastructure. These are likely to include additional primary health care facilities, new primary schools and the provision of community space.
6.20 In addition, the proposed development can provide a superfast home broadband network of 100- 200Mbs to all dwellings delivering broadband speeds that are at least three times faster than other planned networks. The superfast 100–200MBs network will therefore ensure the site is an ideal location to enhance home-working and help attract the highly skilled professions for which Cambridge is well known. At a more basic level, Fibre to the Home will allow all television services to be delivered through the communication network, avoiding the need for unsightly aerials and satellite dishes.
6.21 Moreover, Cambridge South East is unconstrained from an infrastructure delivery perspective, can provide unique betterments to the City and can be highly sustainable in terms of the built form.
Recreation & Open Space
6.22 The proposed development will seek to incorporate substantial provision of and access to, appropriate open space in order to both meet the needs of the future residents of Cambridge South East and to contribute towards the open space and recreation needs of the wider community within the area.
6.23 Accordingly, the scheme will make provision for open space across the development well in excess of the Councils’ respective open space standards, providing a suitable mix of informal and formal open space including areas for children's play, young people's space, natural and semi natural green space and playing pitches. In addition, it is envisaged that the proposed development will incorporate land for public sports pitches. This is highlighted on the constraints plan in Appendix E.
6.24 The proposed development will, therefore, provide significant open space and recreate an extensive area of chalk grassland to meet the immediate needs of the future residents and also help to improve provision for the existing residents and the people of Cambridge to access further countryside.
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Summary of Benefits of the Proposal
6.25 It is clear, therefore, that there would be a number of significant benefits associated with the proposed development at Cambridge South East (Broad Location 7). In brief, these are as follows:
The proposed development will enable the expansion of the City, in a sustainable manner, and forms one of the last remaining opportunities for a sustainable urban extension to the City.
The proposed development will provide for up to 1,000 additional dwellings, including up to 400 affordable and key worker homes, in order to help to meet the ongoing housing needs of SCDC over the plan period. This will ensure that there is a rolling supply of housing land within a sustainable location within cycling distance of the City Centre and a range of employment sites including Addenbrooke's, the Cambridge Bio-Medical Campus and ARM.
In providing a significant amount of housing on the edge of the City, the Cambridge South East site would help to address the significant housing shortages and high levels of affordable housing need within the City and South Cambridgeshire and help to bring down both Councils' affordable housing waiting lists. This will in turn help to stabilise house prices for the delivery of new housing in the market.
The proposed development can deliver a range of social and community benefits through inclusion of appropriate community, education and neighbourhood facilities.
The proposed development can provide significant public open space and recreation areas in a manner which improves public access and increases biodiversity through the creation of new habitats and wildlife areas and the recreation of chalk grassland.
The proposed development can deliver a range of sustainability benefits including the inclusion of super-fast broadband services to help facilitate home working.
20 Commercial Estates Group Cambridge South East September 2012
7 CONCLUSIONS
7.1 CEG welcomes the consultation on the Issues and Options for the new South Cambridgeshire Local Plan. In considering the appropriate growth strategy for the District for the period to 2031 the Council must take full account both of current needs and issues facing the District as well as future requirements and ensure that its chosen options are based on a sound and comprehensive evidence base of objectively assessed needs.
7.2 The dynamic Cambridge economy is at the forefront of the Knowledge Economy with one of the world's most advanced and concentrated technology clusters. The area has a relatively high- skilled, high income economy driven by the dynamic R&D sector and its underlying links with the University. However, the success of the local economy and the ‘Cambridge Phenomenon’ has placed severe pressures on the local housing market and provided particular challenges in terms of the delivery of suitable housing of the right type, the right quantity in the right location whilst protecting the environment and quality of life.
7.3 The current Local Plan has not been successful in responding to these ongoing challenges as it has not yet delivered enough housing to meet real need. Levels of housing need within the District are acute with the housing waiting list growing longer year on year. In April 2010 this stood at 4,054 with a five year requirement of 845 dwellings per annum to address the backlog of housing need alone. House prices remain very high and beyond most people's means. The Council's current housing commitments are not nearly sufficient to meet these identified needs. Until sufficient land is released through allocations in the new Local Plan the housing problem will not be solved. A Local Plan can only be considered successful if policies have the positive effect of delivery on the ground.
7.4 CEG therefore considers that the new Local Plan should seek to significantly increase the supply of housing in response to these needs and should provide a minimum of 27,200 additional dwellings. Based on an existing supply of approximately 10,600 dwellings through existing commitments and deliverable SHLAA sites, this would result in a potential residual requirement of at least 16,600 additional dwellings. Consequently, of the current Consultation Options, it is considered that a new Option 4 (27,200 dwellings) has the most merit as an appropriate housing target.
7.5 Moreover, given the importance of the Greater Cambridge economy and associated hi-tech cluster to the UK Economy, particularly in helping to lead the country back to growth, it is essential that the policies within the Local Plan seek to positively facilitate employment growth within Cambridge as far as possible. Consequently, the Council should seek to adopt an aspirational, high growth employment target which provides the greatest prospect of the local economy fulfilling its potential
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as a globally significant, high-tech cluster. Of the various employment growth scenarios it is considered that Option C (29,200 additional jobs) is the most appropriate although this should be regarded as a minimum target with appropriate flexibility provided through the allocation of suitable employment sites to meet a range of potential needs in line with the NPPF.
7.6 In accommodating these levels of growth the most sustainable solution, which will require a co- ordinated approach between the City and SCDC, is to maintain the sequential approach to development established by the Cambridgeshire Structure Plan Policy 1/1 with growth allocated in order of preference:
In the built up area of Cambridge, subject to consideration of environmental capacity;
On the periphery of the built up area of Cambridge on land released from the Green Belt;
At the new settlement of Northstowe;
On land within or on the peripheries on the market towns.
7.7 Given the scale of housing and employment growth required, the built up area of Cambridge will not be able to physically accommodate the number of dwellings and employment land needed (including the back-log of unmet need). The new Local Plan therefore, will need to identify sustainable sites on the edge of Cambridge to release from the Green Belt to accommodate the additional housing required.
7.8 Accordingly, the Council should be seeking to undertake a comprehensive Green Belt Review in order to assess the suitability and capacity of sites to accommodate these levels of growth in line with Government guidance and policy objectives. CEG does not consider that the assessment undertaken by the Councils goes into enough detail to allow a more refined judgement to be made about the broad location options and possible future Green Belt releases.
7.9 In this context, CEG supports Broad Location 7 as the site represents the most sustainable release of Green Belt land for necessary mixed use development being the most sustainable location and having the greatest physical capacity to help meet the unmet need for dwellings and job growth. Moreover, it allows the City to deliver 3,000 dwellings in its own authority area and 1,000 dwellings in SCDC. It is also the most appropriate and sustainable in connectivity terms for all modes of transport away from the A14/M11 and close to Babraham Park and Ride and Addenbrooke's Hospital.
7.10 Broad Location 7 is able to deliver sustainable development by making economic, social and environmental gains through the mixed development proposal, providing a balance of jobs, homes and supporting these elements by exemplar movement, community, educational servicing,
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infrastructure and recreation planning (forming the social function); whilst respecting and enhancing the Green Belt and countryside element by improving public access and increasing biodiversity in the area (public open space, creating chalk grassland and wildlife corridors).
23 Housing & Employment Technical Paper
Appendix A
Commercial Estates Group Cambridge South East September 2012 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
Table of Contents
1 Introduction...... 1 Purpose of the Report ...... 1 Background to the Proposals...... 1 Structure of the Report...... 1
2 Contextual Considerations ...... 3 Importance of Cambridge to the UK Economy...... 3 National Planning Policy Framework ...... 6
3 Issue 3: Jobs Target...... 9 Introduction...... 9 Historic Jobs Growth and Demographic Trends...... 9 Economic Projections...... 10 Employment Target Options...... 12 Meeting Employment Needs...... 13
4 Issue 4: Housing Targets...... 15 Introduction...... 15 Historic Growth and Demographic Change...... 16 Future Demographic Projections ...... 17 Housing Need ...... 18 Housing Waiting List...... 21 Housing Need Assessments...... 22 Housing Delivery...... 23 Housing Land Supply ...... 26 Housing Options ...... 27
5 Conclusions ...... 31 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
1 Introduction
Purpose of the Report
1.1 This Housing and Employment Technical Paper has been produced by Bidwells, on behalf of Commercial Estates Group Ltd (CEG), to support their submissions in response to the South Cambridgeshire Local Plan Issues and Options Consultation. CEG are currently promoting proposals for a large residential led, mixed use urban extension to the south of Fulbourn Road and north east of Babraham Road, Cambridge, known as Cambridge South East (Fringe Site 7).
1.2 This report provides a critical analysis of the Council's current evidence base in relation to housing and employment needs for South Cambridgeshire having regard to the Council's evidence base. It seeks to examine the various forecasts and other background evidence and their adequacy for robustly assessing housing and employment needs for the District during the Plan period to 2031. It also seeks to examine the way that the Council has interpreted this in developing options for consultation and whether the options adequately respond to the assessment identified.
Background to the Proposals
1.3 The draft conceptual proposals for the site currently envisage the development of a new residential led, mixed use neighbourhood for the city, comprising approximately 4,000 market, affordable and key worker dwellings along with 9.7 hectares of R&D/B1a Employment Development a neighbourhood centre, public open space and supporting infrastructure.
1.4 The site straddles Cambridge City and South Cambridgeshire District Council (SCDC) boundaries with the majority of the proposed development likely to take place within the Cambridge City boundaries including approximately 3,000 dwellings and the employment development. Approximately 1,000 dwellings are expected to be provided within SCDC.
1.5 The site currently falls within the Cambridge Green Belt and would require revisions to the Green Belt boundary to facilitate the development. It is envisaged that the site would help to meet both Councils’ future housing land supply requirements for the period up to 2031.
Structure of the Report
1.6 The report considers the housing and employment needs for the District having regard to Chapter 3 of the Council’s Issues and Options Report. Accordingly, the remainder of this report is structured as follows:
Section 2 considers the strategic importance of the Greater Cambridge economy;
1 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
Section 3 reviews the Councils approach to setting housing and employment targets having regard to the requirements of the NPPF and relevant best practice guidance;
Section 4 considers job growth projections and future requirements and the extent to which these are reflected in the Council's options
Section 5 considers future housing requirements having regard to existing housing need, delivery and supply and the extent to which these are reflected in the Council's options;
Section 6 provides our conclusions in relation to these issues;
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2 Contextual Considerations
Importance of Cambridge to the UK Economy
2.1 The Greater Cambridge area is widely seen as an economic success story both in the context of the UK Economy and also in terms of its international significance. Over the last 50 years it has increasingly developed into a strong, diverse and dynamic economy that is at the forefront of the Knowledge Economy with one of the world's most advanced and concentrated technology clusters.
2.2 The economic success associated with the Cambridge Phenomenon has resulted from Cambridge benefiting from a unique mix of characteristics including:
The presence of successful, highly regarded Universities acting as a source of leading academic research and learning and providing a world class pool of academic talent;
The presence of world class research institutions at the forefront of scientific innovation;
The presence of a strong mix of innovative companies;
The presence of angel investors keen to invest seed-capital funding and promote high- technology business start-ups;
The growing presence of a network of support for entrepreneurship and innovation;
The availability of science parks promoting high technology clusters;
An attractive environment providing a good quality of life.
2.3 The foundation of the area's success is Cambridge University which is consistently ranked among the top five universities in the world. The University's outstanding international reputation and track record for scientific research and innovation over hundreds of years is underlined by the fact that the University has had 88 Nobel prize winners amongst its affiliates, more than any other university in the world, with laureates in every Nobel category.
2.4 The University is also one of the largest employers in the East of England directly employing over 11,700 people in 2004 and a further 65,000 indirectly. According to the 2004 report 'The Impact of the University of Cambridge on the UK Economy and Society' the University directly and indirectly contributes over £25bn to the economy.
2.5 Cambridge University, along with Anglia Ruskin University, also provide a large pool of academic talent and highly skilled labour. Between them they have over 30,000 students including 10,000 post-graduate students from around the world at any one time. Partly as a result, both South Cambridgeshire and Cambridge City have one of the highest skilled workforces of any area in the Country with over 40% of the working age population being educated to NVQ Level 4 or above.
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2.6 The area also benefits from leading, internationally respected research institutions such as The Babraham Institute, The Sanger Institute (Wellcome Trust), the Cambridge Research Institute and the Cambridge Institute for Medical Research. This, in turn, has attracted a number of global organisations such as Nokia, Microsoft and Toshiba to establish research and development facilities in close proximity to the University and the research institutions.
2.7 As a result of the combined strength of its Universities, research institutions and the growing cluster of high-technology enterprises, the Greater Cambridge Economy has grown in significance over the last 30 years and Cambridge has now become one of the UK's most successful cities and an important asset for the UK Economy attracting investment in knowledge intensive industries that otherwise might not come to the UK at all. Cambridge University is now looking to grow its post- graduate activity, which will further fuel the Cambridge Phenomenon.
2.8 The City and surrounding area perform strongly in relation to a range of economic indicators. The Greater Cambridge area now hosts approximately 27,500 businesses employing more than 700,000 people, contributing £15 billion to the economy and attracting over 20% of the venture capital in the UK . The most recent research by CCCRG suggests that there are now in the region of 1,500 technology firms within the City alone, employing around 48,000 people. These include a number of high-tech firms of global significance, including:
ARM - leading designers and licensers of semi-conductor microchips, employing over 2,000 people worldwide with Headquarters in Cambridge employing 850 people;
Autonomy – specialising in IT infrastructure software it was recently sold to Hewlett Packard for £7.1 billion;
Cambridge Silicon Radio – specialising in the development of wireless technology, it had a turnover in 2009 of £400m and employed 1,400 people worldwide with its Headquarters based in Cambridge;
Domino – specialising in inkjet printing it employs 2,000 people worldwide and had a turnover in 2009 in excess of £200m.
2.9 A number of these have been founded on links with the University either as direct spin-outs or having been started by Cambridge alumni.
2.10 As a result of its dynamic high-technology focussed economy, the Greater Cambridge area has been identified one of the places most likely to lead the UK back to growth.
2.11 Yet whilst the area currently performs well in terms of its competitiveness, there are many threats and challenges facing the area's economy which suggest that the continued success of its
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economy can not be taken for granted. The Cambridge hi-tech cluster and the hi-tech businesses within it operate within an international context and are increasingly having to compete with a growing number of hi-tech clusters globally. These include both the traditional clusters such as Silicon Valley in California and Boston, along with new, emerging clusters in developing economies, particularly in China and other parts of Asia. Many of these competing clusters enjoy distinct competitive advantages in comparison to Cambridge with many enjoying state support, more favourable legislation and policy frameworks and, in a number of cases, cheaper labour. As a result, hi-technology businesses within the Cambridge cluster must compete with these other global clusters for business and investment as well as the talented workers to help to drive business success in the first place.
2.12 The continued competitiveness of the Cambridge hi-tech cluster is particularly important since the Coalition Government expects the development of the Knowledge Economy to play an increasingly key role in helping to diversify the UK Economy and lead the UK back towards economic growth. The important role of the Knowledge Economy in this regard is set out clearly within the Government's Plan for Growth published in March 2011 which highlights the need to encourage growth in knowledge-intensive sectors such as healthcare and life sciences, advanced manufacturing, digital and creative industries and professional and business services.
2.13 The significance of the Knowledge Economy to the UK's ongoing economic prospects and global competitiveness is highlighted by The Work Foundation in its report 'A Plan for Growth in The Knowledge Economy' in June 2011. The report highlights the contribution of the Knowledge Industries to UK GDP growth and growth in GVA over the last 40 years and emphasises the extent to which the sector has significantly outperformed other sectors of the economy in this regard. Between 1987 and 2006, the value of the UK's knowledge based service exports grew from less that £13billion to just under £90billion whilst employment in knowledge-intensive market based services increased by 93 per cent between 1979 and 2010 compared to 13% across all sectors.
2.14 It is therefore clear that, given the continued and growing importance of the Knowledge Economy to the UK's future economic prospects in the 21st Century and given the importance of the Greater Cambridge economy and associated hi-tech cluster to the UK Knowledge Economy, it is essential that appropriate plans and policies are put in place to facilitate the sustainable growth of the Cambridge economy. Whilst this clearly needs to be managed in an effective manner such that the quality of the area's historic and natural environments are maintained, it is nonetheless essential to the UK's national economic interests that the local authorities and their strategic partners within the area develop appropriate policies to deliver the sustainable development of the Greater Cambridge area.
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National Planning Policy Framework
2.15 The National Planning Policy Framework (NPPF) was published in March 2012 and replaces a range of Government planning policy statements and guidance notes in setting out a comprehensive planning policy framework to guide local planning authorities in preparing development plans and managing development.
2.16 The NPPF introduces a ‘presumption in favour of sustainable development’ which it advises should be seen as a 'golden thread' running through both plan-making and decision taking. This requires local planning authorities to positively seek opportunities to meet the development needs of their area. Local Plans are required to meet objectively assessed needs with sufficient flexibility to adapt to rapid change unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits or if specific policies in the Framework indicate development should be restricted.
2.17 The overarching emphasis of the NPPF is on the importance of supporting growth and economic development. Local planning authorities are required to 'proactively drive and support' sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. It emphasises that 'every effort should be made objectively to identify and then meet the housing, business and other development needs of their area and respond positively to wider opportunities for growth' (paragraph 17).
2.18 Accordingly, the document confirms that the planning system should help to build a strong and competitive economy securing economic growth, creating jobs and prosperity, building on the country's inherent strengths and responding to global competition. Removing obstacles to business investment is a core theme running throughout the NPPF which emphasises that the planning system should encourage and not act as an impediment to economic growth. It confirms that significant weight should be placed on the need to support economic growth (Paragraph 19).
2.19 In line with this approach, the NPPF emphasises that local planning authorities should plan proactively to meet the development needs of business and support the economy (Paragraph 20). In drawing up local plans, local planning authorities should:
Set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth;
Identify strategic sites for local inward investment to match the strategy and meet anticipated needs over the plan period;
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Support existing business sectors and where possible identify and plan for new or emerging sectors. Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow rapid response to changes in economic circumstances;
Plan positively for the location, promotion and expansion of clusters where networks acknowledge driven hi-technology industries.
2.20 In order to facilitate this aim, the NPPF advises that local planning authorities should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence taking full account of economic and market signals with regard to business needs. The suggestion being that plan making should not simply provide a means of protecting existing levels of economic activity, although this is clearly an important consideration, it should also seek to facilitate the realisation of aspriational economic growth targets. Given Cambridge's role as a world leader in higher education, research and knowledge based industries any policy approach which does not seek to respond positively to opportunities to secure economic growth would be contrary to the clear objectives of the NPPF.
2.21 The NPPF also sets out the Government's objective to 'boost significantly' the supply of housing in order to deliver a wide choice of high quality homes to meet future housing needs (Paragraph 47). Accordingly, to boost the supply of housing, LPAs should:
Use their evidence base for Local Plans to meet the objectively assessed needs for market affordable housing including identifying key sites;
Identify and update annually deliverable sites to provide five years' worth of housing along with an additional 5% buffer. LPAs with ‘a record of under delivery’ should provide a 20% buffer;
Identify a supply of sites or broad locations for growth for years 6-10 and where possible years 11-15;
Illustrate the expected rate of housing delivery and set out a housing implementation strategy;
Impose housing density guidelines which reflect the local area.
2.22 The NPPF does not seek to define the term 'a record of under delivery', however given that South Cambridgeshire District Council has failed to meet its adopted housing target at any point in the period 2001-2011 (Structure Plan, East of England Plan or Option 1), it would be reasonable to assumes that the 20% buffer would be applicable in this case. In simply terms, it will therefore be necessary for the District Council to identify a six year rolling supply of housing sites.
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2.23 In this context, the NPPF acknowledges that the supply of new homes can sometimes best be achieved through planning for larger scale development such as urban extensions.
2.24 Accordingly, to deliver a wide choice of high quality homes local planning authorities should:
Plan for a mix of housing based on current and future demographic and market trends and the needs of community groups;
Identify the size, type, tenure and range of housing by location reflecting local demand;
Identify and set policies to address the need for affordable housing (on and off site).
2.25 In preparing their Local Plans the NPPF underlines that local planning authorities should have a clear understanding of housing needs in their area and ensure that their housing strategies are based on adequate, up-to-date and relevant evidence. To achieve this they should prepare a Strategic Housing Market Assessment to assess their full housing needs, working with neighbouring authorities where appropriate. This should include identifying the scale and mix of housing that the local population is likely to need over the plan period which:
meets household and population projections, taking account of migration and demographic change;
addresses the need for all types of housing including affordable housing and different community groups; and,
caters for housing demand and the scale of housing supply necessary to meet this demand.
2.26 Additionally, local planning authorities should also prepare a Strategic Housing Land Availability Assessment (SHLAA) to establish realistic assumptions about the availability, suitability and viability of land to meet the identified need for housing over the plan period.
2.27 In this context, the NPPF provides acceptance that landowners and developers need to be incentivised to bring forward development and emphasises the need to pay careful attention to viability and costs in plan-making and decision-taking (Paragraph 173).
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3 Issue 3: Jobs Target
Introduction
3.1 This section considers the potential job growth requirements for South Cambridgeshire in more detail. Whilst the Council’s current evidence base reviews high level employment growth targets the Council’s Employment Land Review is still being prepared and is not currently available for comment. We therefore consider these matters based on our own evidence and reserve the right to add to this as further information becomes available.
Historic Jobs Growth and Demographic Trends
3.2 In order to inform the consideration of projections of future population and employment growth it is first beneficial to consider the historic context. Table 3.1 below sets out population and employment change in the District since 1991.
Table 3.1: Historic Growth Patterns in South Cambridgeshire
Population Resident Workforce Total Jobs
1991 121,900 77,000 52,800
2001 130,600 81,800 68,200
2011 148,800 89,100 83,100
Change 1991-2001 8,700 4,800 15,400 (7.1%) (6.2%) (29.2%)
Change 2001-2011 18,200 7,300 14,900 (13.9%) (8.9%) (22%)
Change 1991-2011 26,900 12,100 30,300 (22.1%) (15.7%) (57.4%)
3.3 It is evident from the table above that the District has seen significant jobs growth over the last 20 years despite this period including two periods of recession (1991-92 and 2008-09). Jobs growth over the period has exceeded both the growth in the population and the growth in the labour force within the District with growth of approximately 1,500 jobs per annum over the last 20 years. As a result, the previous imbalance between housing and employment within the District has been largely redressed and there now appears to be a more sustainable balance between homes and jobs within the District.
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3.4 Whilst there have clearly been fluctuations in jobs growth over the last 20 years, particularly during the 2008-09 recession, it is worth noting that the South Cambridgeshire economy still managed to add 4,000 new jobs over the last four years, equivalent to 1,000 jobs per annum. This level of job creation has comfortably exceeded the more pessimistic expectations within the Cambridgeshire Development Study of 2009, reflecting the relative resilience and dynamism of the local economy and the fact that this is driven by globally facing companies at the forefront of science and innovation.
3.5 In considering appropriate job growth targets for the future it is also instructive to consider previous employment targets. These are summarised in the table below.
Table 3.2: Summary of Historic Job Growth Targets
Development Plan Plan Total Annual Comments Period Requirement Requirement
2003 Cambridgeshire 1999-2016 No job-growth N/A Provision for X Hectares of Employment Structure Plan target Land.
2007 South 1999-2016 No job-growth N/A Provision for X Hectares of Employment Cambridgeshire Core target Land. Strategy
2008 East of England 2001-2021 17,610 880 Based on RSS Sub-regional target Plan (RSS14) disaggregated for South Cambs by 2008 Employment Land Review.
Draft RSS Review 2011-2031 21,200 1,060 Figures based on Cambridgeshire Development Study. Draft RSS never examined and has no formal status.
Economic Projections
3.6 The As part of their consideration of future job growth requirements for the District to 2031, the Council has had regard to various economic forecasts for the Plan period. The two main economic forecasting models which have been considered are:
East of England Forecasting Model (EEFM) produced by Oxford Economics;
Cambridge Econometrics Local Forecasting Model.
3.7 As part of the forecasting models, a range of scenarios have been tested, particularly with regard to the Cambridge Econometrics Model. A summary of the findings of the two models is produced in the Table below.
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Table 3.3: Comparison of Employment Growth Projections 2009-2031
2001 2011 2021 2031 2011-2031
EEFM 2012 Lost Decade 68,200 83,100 90,900 99,900 16,800
EEFM 2012 Baseline 68,200 83,100 98,400 107,900 24,800
EEFM 2012 High Growth 68,200 83,100 101,300 114,400 31,300
CE Low - 81,200 88,400 95,200 14,000
CE Baseline - 81,200 91,300 103,500 22,300
CE Population-led - 81,200 91,100 104,400 23,200
CE High - 81,200 94,000 110,400 29,200
3.8 The job growth forecasts for South Cambridgeshire for the period between 2011 and 2031 range from approximately 14,000 jobs (700 per annum) to 31,300 jobs (1565 per annum) between the various forecasts, a difference of approximately 17,000 jobs. In order to provide a more robust evidence base in this regard, further economic forecasting should be undertaken in order to provide further sensitivity testing of potential economic growth scenarios and their implications. Nonetheless, it is evident that the Council's highest option in relation to employment targets of 29,200 new jobs is below the highest potential jobs growth scenario of 31,300 jobs.
3.9 Whilst the assumptions about future job growth over the next few years may be open to question in view of the on-going economic difficulties, it is, however, important that policies seek to positively facilitate job growth within the Greater Cambridge Area as far as possible given the strategic importance that the local economy has in seeking to lead the UK back to growth. Consequently, in considering the results of these models and the various scenarios tested in order to establish appropriate job growth targets for the Plan period, the Council should seek to adopt an aspirational target which provides the greatest prospect of the local economy fulfilling its significant potential as a globally significant high-tech cluster. Such an approach is essential to enable the local economy to effectively compete against other global clusters and thereby help to lead the UK economy back to growth, recognising its national importance.
3.10 This is particularly important given that the NPPF emphasises the need for the planning system to help build a strong and competitive economy which secures economic growth, creates jobs and prosperity in a manner which builds on the Country's inherent strengths and responds to global competition. In particular, the NPPF's requirement for Local Planning Authorities states they should plan proactively to meet the development needs of businesses and support the economy and encourage sustainable economic growth. This needs to be given considerable weight in developing
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an appropriate job growth strategy as part of the Local Plan. Indeed, the NPPF specifically highlights the need to plan positively for the location, promotion and expansion of clusters in knowledge-driven high technology industries.
3.11 Moreover, it is also important to bear in mind that the various employment projections are based on differing assessments of job growth within the District over the previous ten years since 2001. This is because, in the absence of any 2011 Census data, the projections are based on 2001 Census data and subsequent estimates of job growth in the intervening period. In this regard, there are disparities between the various assessments of employment change over this period depending upon whether consideration is given to Annual Business Inquiry (ABI) or Annual Population Survey (APS) data.
3.12 Of the various employment growth scenarios considered by the Council we consider that the EEFM 2012 High Growth scenario and the Cambridge Econometrics High Growth Forecast should be given the most weight in light of the considerations highlighted above. Moreover, we would stress that this level of job growth is in-line with historic job growth trends between 1991 and 2011, despite this being a period which saw two recessions. This is also in-line with previous targets of 20,000 jobs or 1,000 jobs per year over the Plan period between 2011 and 2031 established within the draft review of the East of England Plan however, given the aspirational nature of the former growth targets, we consider that this should be regarded as a minimum level of employment provision.
Employment Target Options
3.13 Based on the latest employment projections discussed above, the Council's Issues and Options document sets out three options for the jobs target for the Local Plan. These are summarised in Table 3.4 below.
Table 3.4: Summary of Housing and Employment Options
Option Reference Total Requirement Annual Comments 2011-2031 Requirement
A – Lower jobs growth 14,000 700 This level of growth would be even lower than growth experienced between 2007-2011
B – Medium jobs growth 23,100 1,200
C – High jobs growth 29,200 1,500 Accords with historic levels of job growth
12 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
3.14 With regard to the employment options we consider that the High Growth Scenario – 29,200 jobs (Option C) has the most merit based on the evidence currently available and given the strategic importance of the Cambridge economy.
3.15 As noted above, it is vital that the policies within the Local Plan seek to positively facilitate job growth within Cambridge as far as possible given the strategic importance that the local economy has to the UK's future economic prospects in seeking to lead the Country back to growth. Consequently, the Council should seek to adopt an aspirational, high growth target which provides the greatest prospect of the local economy fulfilling its significant potential as a globally significant high-tech cluster. Such an approach is essential to enable the local economy to effectively compete against other global clusters and thereby help to lead the UK economy back to growth.
3.16 However, given that historic job growth in the District has exceeded this level and that certain growth scenarios suggest potential for higher levels of job growth the Council should not seek to unduly limit employment growth to this level given the strategic importance of the local economy. This should therefore be regarded as a minimum target with appropriate flexibility provided through the allocation of a range of suitable employment sites to meet a range of potential needs in line with the NPPF requirements.
3.17 Nonetheless, we have concerns regarding the Council's current evidence base in relation to employment. It is of particular concern that the current consultation has been undertaken without the Council's updated Employment Land Review having been completed. The absence of this document from the background consultation documents is disappointing and we reserve the right to supplement our comments in relation to employment matters once this document has been publicly released.
3.18 In addition, it will be important that the Council updates its evidence base in relation to employment projections as more employment data becomes available from the 2011 census to ensure that the Plan is based on up-to-date, reliable evidence and is sound.
Meeting Employment Needs
3.19 Notwithstanding the absence of the Council’s updated Employment Land Review, we have now sought to review the high growth job scenarios in more detail and the associated variations between different industrial sectors in order to establish whether any further conclusions can be drawn with regard to the potential nature of future job growth and its implications for employment land supply.
13 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
3.20 In determining the nature and extent of future commercial floorspace and employment land requirements it is first necessary to look at the employment forecasts in more detail in order to establish the forecast changes within the different employment sectors. The EEFM 2012 high growth scenario provides employment forecasts for the period from 2011 to 2031 in relation to each of the 41 Standard Industrial Classification (SIC) codes. It is evident that the main sectors of growth are likely to be in education, professional services and computing services. In addition, there is also forecast to be significant growth in health and social work along with other business services, employment activities, retail and the hotels and restaurants sectors.
3.21 Conversely, these forecasts suggest that there is likely to be further contraction in the more traditional economic sectors such as agriculture, manufacturing and other production related industries.
3.22 In general terms, these forecasts therefore suggest that there will be a growing need for significant further office and R&D floorspace over the Plan period to 2031 since the key sectors of likely growth, professional, business and computing services, would all operate from office and R&D floorspace. In total, these office and laboratory based sectors are forecast to create at least 23,000 net additional jobs alone under the High Growth forecasts. In this context, we consider below the extent and nature of office and R&D floorspace availability both in terms of existing provision and also having regard to future commitments and pipeline supply within the Greater Cambridge area.
3.23 There is clear evidence that South Cambridgeshire does not have sufficient pipeline employment land allocations of the right type and in the right location to accommodate the levels of demand expected going forward. If the area is to maintain national and global importance as an R&D centre, it is essential that further land allocations are made in areas close to Cambridge which will attract the type of companies that made the area the successful place that it currently is. It is of national importance that these land allocations are made sooner, rather than later, to allow the growth of well established companies such as ARM and also attract new companies, where new research can be fostered with the University, which will ultimately lead to the continued success of the University itself.
3.24 There is therefore a strong and growing need for additional, well located sites to come forward to provide significant employment allocations to satisfy on-going demand close to Cambridge. In particular, there is a need for further significant allocations of B1 employment development close to Cambridge to provide for ongoing needs for hi-tech companies and related business service companies seeking high quality, flexible office and R&D space. This is essential for the area to maintain its place as a premier R&D location in the UK economy.
14 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
4 Issue 4: Housing Targets
Introduction
4.1 As noted above, the NPPF highlights that in preparing their Local Plans, local planning authorities should ensure they have a clear understanding of housing needs in their area having regard to adequate, up-to-date and relevant evidence.
4.2 The need for new housing is driven by a number of variables and the assumptions regarding these individual elements will all have a bearing on the resultant outcome. These include assumptions regarding the natural change in the population arising from the balance of births and deaths, the extent of migration into or out of the area, along with changes in the size of households and the associated rate of new household formation.
4.3 In addition, it is also important that any assessment of housing need fully takes into account the extent and nature of any unmet housing need at the beginning of the forecast period to ensure that the assessment of housing needs adequately considers both existing as well as newly arising / future housing needs.
4.4 The standard approach does not however consider the labour force requirements associated with meeting economic objectives. This is a fundamental issue which cannot be overlooked when seeking to set housing targets. A policy approach which does not seek to align housing and employment growth will inevitably result in undesirable outcomes. For example, if housing growth outstrips job creation there may a rise in unemployment. Conversely, if job growth exceeds housing delivery workers may be forced further afield, resulting in unsustainable patterns of commuting.
4.5 Such issues are particularly relevant to the District. Indeed there has been an imbalance between housing and employment growth for many years, largely brought about by the strategic growth strategy imposed by the 1989 and 1995 Cambridgeshire Structure Plans which sought to expand the economic role of the Cambridge area but did not match this growth with housing development close to Cambridge. In order to reverse this trend, the plan making process must adopt a balanced and sustainable approach which acknowledges the synergies between housing and employment growth.
4.6 Indeed, the NPPF makes it clear that a wide ranging and robust evidence base should be taken into account when generating housing targets, including population, housing market, economic, social, sustainability and infrastructure considerations. It is therefore crucial that policy makers seek to properly balance all available data in order to objectively assess the full extent of housing need across the identified plan period. A policy approach which does not strike this balance will fail
15 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
to comply with the requirements of the NPPF and perhaps more concerning will conceal the true extent of housing need.
Historic Growth and Demographic Change
4.7 In order to inform the consideration of projections of future population and household growth it is first beneficial to consider the historic context. Table 4.1 below sets out population and household change in the District since 1991.
Table 4.1: Historic Growth Patterns in South Cambridgeshire
Population Households Dwellings
1991 121,900 45,900 48,300
2001 130,600 52,200 54,200
2011 148,800 60,000 61,850
Change 1991-2001 8,700 6,300 5,900 (7.1%) (13.7%) 12.2 (%)
Change 2001-2011 18,200 7,800 7,650 (13.9%) (14.9%) 14.1 (%)
Change 1991-2011 26,900 14,100 13,550 (22.1%) (30.7%) 29.1 (%)
Table 4.2: Summary of Historic Housing Requirements
Development Plan Plan Total Annual Comments Period Requirement Requirement
2003 Cambridgeshire 1996-2016 23,520 1,176 This was part of a growth strategy that Structure Plan sought to rebalance growth around Cambridge.
2007 South 1999-2016 20,000 1,176 Based on RSS. Still forms Adopted Plan. Cambridgeshire Core Strategy
2008 East of England 2001-2021 23,500 1,175 This requirement was never accepted as Plan (RSS14) being deliverable by the Council. RSS due to be abolished.
Draft RSS Review 2011-2031 21,000 1,050 Figures based on Cambridgeshire Development Study. Draft RSS never examined and has no formal status.
16 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
Future Demographic Projections
4.8 Analysis of the Council's evidence base confirms that there are a number of different demographic projections for South Cambridgeshire which need to be considered in determining future housing and other requirements. These include the various projections produced as part of the 2012 run of the East of England Forecasting Model (EEFM) produced for Cambridgeshire County Council to inform the various development plan reviews across the County, along with the County Council Research Group's own figures and Government projections. These are summarised in Table 4.3 below.
Table 4.3: Comparison of Population and Household Projections
Population and Household ONS CCCRG EEFM Low EEFM EEFM High Projections Baseline
Population in 2011 147,800 146,000 149,400 149,400 149,400
Population in 2031 180,100 188,400 192,200 192,400 197,900
Rise in Population 2011-31 32,300 42,400 42,800 43,000 48,500
Household numbers in 2011 58,000 61,600 59,800 59,800 59,800
Household numbers in 2031 81,000 80,600 80,500 80,600 82,900
Rise in Households 2011-2031 23,000 19,000 20,700 20,800 23,100
Annual rise in household numbers 1,150 950 1,035 1,040 1,155
4.9 Whilst there are variations between the various projections, however there appears to be a broad consensus within most of the projections that the District is likely to experience population growth in the region of 42,000 – 43,000 people and household growth of 21,000 to 23,000 during the period to 2031.
4.10 However, it is considered that a degree of caution should be applied in interpreting the population projections referred to above (and indeed previous projections considered as part of the RSS Review) since they all rely on 2001 Census data and population and household estimates over the subsequent 11 year period. Given the age of the base data and the potential for inaccuracies and disparities to build up over the subsequent 11 years of estimates, their reliability as a basis for the assessment of future requirements is open to doubt.
4.11 It is understood that further work in relation to demographic and household projections by the County Council Research Group is on-going having regard to the 2011 Census data the first data release having just been issued by ONS. This data is more up to date, comprehensive and reliable although this will itself be subject to further refinement over the next 12 months. Consequently, it
17 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
will be particularly important in supplementing the Council's evidence base and the Council are likely to need to review this to take account of this further information when it becomes available further into the Plan preparation process.
4.12 Nonetheless, demographic and household projections will only form one indicator of potential housing and employment requirements over the Plan period. Given that they will again be based on past trends, the projections may be of limited benefit in reflecting future housing needs to 2031 since the population and household projections seek to forecast population change and household formation but do not properly take account of existing unmet housing need.
4.13 It is clearly important that in assessing future housing requirements, appropriate regard is given to economic considerations and the need for housing growth to match demand arising from job growth within the District over the period to 2031. This is necessary to ensure an appropriate balance between future job growth and future housing growth, particularly as employment growth can significantly influence levels of in-migration.
4.14 However, it is considered that the housing requirements associated with the economic-led housing projections should be regarded as a minimum requirement since they only reflect the housing requirement associated with or directly arising from future job growth. They do not however address or redress existing housing needs or, for that matter, any existing imbalances between jobs and homes within the District.
Housing Need
4.15 The Council's Sustainability Appraisal Scoping Document reviews existing levels of housing need, past housing delivery and future supply having regard to the Strategic Housing Market Assessment (SHMA) for the Cambridge Sub-Region along with the Council's latest Annual Monitoring Report (AMR) dated December 2011 and Strategic Housing Land Availability Assessment (SHLAA) dated May 2012.
4.16 As noted above, the NPPF highlights that in preparing their Local Plans, local planning authorities should ensure they have a clear understanding of housing needs in their area having regard to adequate, up-to-date and relevant evidence including a Strategic Housing Market Assessment. In general terms the Council's approach has regard to these requirements to a certain extent. However, we are concerned that much of the data within the SHMA for the Cambridge Sub-region is a few years out of date with much of the information dating from 2009. This needs to be brought up-to-date to reflect the accurately current position.
4.17 A range of evidence over recent years has confirmed that there are significant levels of housing need within the Cambridge area. Evidence produced as far back as 1999 to inform the production
18 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
of Regional Planning Guidance Note 6 (RPG6) for the East of England highlighted issues of acute housing need within the Cambridge housing market.
4.18 The 2003 Cambridgeshire Structure Plan highlighted the need for a greater provision of affordable housing in the Cambridge Sub-region to address rising housing need arising from the escalation of house prices and the difficulties in key workers accessing the housing market. Similarly, the South Cambridgeshire Housing Strategy highlights the availability of housing that is affordable and accessible to those in housing need as being a particular problem in the District.
4.19 The analysis provided below demonstrates that despite the objectives set by the Housing Strategy, and indeed the South Cambridgeshire Core Strategy, little progress has so far been made in addressing issues of housing need within South Cambridgeshire. Indeed the evidence available would suggest that the situation has worsened in recent years.
4.20 As can be seen from Table 4.4 and Fig 4.1 below, house prices and affordability ratios have increased substantially over the last 10 years, notwithstanding the recent effects of the recession and its impact on the housing market. By the third quarter of 2011, the average cost of a house within South Cambridgeshire was £287,251 well above the County and national averages of £236,276 and £238,567 respectively.
Table 4.4: Change in Average House Prices 2001-2011
2001 2011 Difference % Change
South Cambridgeshire £155,175 £287,251 £132,076 85.1%
Cambridgeshire £127,719 £236,276 £108,557 85.0%
England £114,192 £238,567 £124,375 109.9% Source: DCLG Live Housing Tables
4.21 As can be seen in Fig 4.1 below, whilst house prices fell slightly between 2008 and 2009 from the pre-recession peak in 2007, prices have subsequently recovered with further house price growth since 2009 in South Cambridgeshire.
19 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
Fig 4.1 House Price Growth 1996-2011
350,000
300,000
250,000
200,000
150,000 House Prices (£)
100,000 Cambridge South Cambridgeshire Cambridgeshire 50,000 East of England England
0 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 Year
4.22 Similarly, affordability ratios have also risen significantly since 2001 in South Cambridgeshire with house price growth having far outstripped earnings growth over this period. As can be seen from the Table 4.5 below, the cost of the average house within the District is over eight times the average wage.
4.23 Table 4.5: Change in Average Housing Affordability Ratios 2001-2011
Earnings 2001 Ratio 2001 Earnings 2011 Ratio 2011 Change
South Cambridgeshire £25,054 6.21 £30,729 8.66 +2.45
Cambridgeshire - 4.94 £30,426 7.08 +2.14
England - 4.47 £27,569 6.65 +2.18
Source: Cambridge Sub-Region SHMAA and DCLG Live Housing Tables, 4.24 Lower quartile house prices in South Cambridgeshire have also increased significantly over the last 10 years. In South Cambridgeshire the average house price to income ratio increased from 4.33 in 1997 to 8.10 in 2010.
20 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
Fig 4.2: Ratio of Lower Quartile House Prices to Earnings 1997-2010
12.00
10.00
8.00
6.00
House price ratio 4.00
Cambridge South Cambridgeshire 2.00 Cambridgeshire East of England England 0.00 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Year
Housing Waiting List
4.25 The significant increase in house prices over the last few decades outstripping earnings growth has led to growing issues in the Greater Cambridge housing market with regard to housing need. One of the key measures of housing need is the number of households registered on the Council's Housing Waiting List for affordable housing. Table 4.6 below illustrates how the numbers of households on the Council's Housing Waiting List has grown over the last decade.
Table 4.6: South Cambridgeshire Housing Waiting List 2001 - 2010
Year 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
No. Households on 1,500 1,733 2,207 2,553 3,538 4,155 4,661 3,628 3,800 4,054 Waiting List
Source: Shelter Housing DataBank
21 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
4.26 It is evident from the table above that, with the exception of a small fall following the 2008-9 recession, the Council's Waiting List for affordable housing has continued to grow over the last decade and that the numbers of households on the Council's Waiting List is at near record levels.
Housing Need Assessments
4.27 In accordance with previous best-practice guidance a detailed assessment of housing need for the South Cambridgeshire and other districts within the Cambridge Sub-region Housing Market has previously been undertaken and forms part of the Council's evidence base. The latest assessment of housing need within the Sub-region produced a part of the Cambridge Sub-Region SHMA 2010 update (published September 2011) indicates that the Sub-Region and both South Cambridgeshire and Cambridge City in particular have significant levels of housing need. The 2010 SHMA Update identifies a backlog of 845 affordable dwellings per annum between 2009/10 and 2014/15 required to address existing housing needs in South Cambridgeshire. This rises to 1,372 including newly arising needs. The SHMA derived housing need is summarised in Table 4.7 below having regard to the key components of housing need.
4.28 Given that newly arising need is likely to vary depending on various factors this is considered to be of less significance but the backlog of housing need is regarded as a particularly critical measure that the Council must seek to address as part of its housing and growth strategy going forward.
Table 4.7: SHMA Derived Housing Need in South Cambridgeshire
Housing Need Newly Arising Total Need Backlog Need
5-Year Annual Requirement 845 527 1,372
Total 5-Year Requirement 4,225 2,635 6,860
Subsequent Annual Requirement 0 527 527
Total 20 year Housing Need 4,225 10,540 14,765
Equivalent Housing Requirement based on 10,562 26,350 36,912 40% affordable housing
Source: Cambridge Sub Region SHMA
4.29 The NPPF is quite clear that local planning authorities are expected to meet objectively assessed needs for both market and affordable housing. Inspectors tasked with examining emerging planning policy documents have already shown a willingness to take a firm line where councils are found wanting in this respect. Recently, Hertsmere (a 90% Green Belt area Authority, Hull City Council and Wigan Metropolitan Borough Council have been informed that the examination of their
22 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
respective core strategies has been suspended for a period of six months while they gather the necessary evidence to demonstrate that they can meet objectively assessed housing needs. It is therefore considered that a policy approach which fails to either properly assess or adequately meet the full extent of identified housing needs is at risk of being found unsound.
4.30 The housing options identified within the South Cambridgeshire Local Plan Issues and Options document are not sufficient to meet the level of housing need identified by the evidence base currently available to the Council. Even if it is possible for 40% of all new dwellings to be provided as affordable housing, there would still be a significant shortfall in delivery against the 14,765 affordable homes required over the plan period. This is illustrated by Table 4.8 below:
Table 4.8: Comparison of Housing Options with Housing Needs
Growth Option Housing Target 40% of Housing Target Housing Need Deficit
A – Lower Housing Growth 18,500 7,400 -7,365
B – Medium Housing Growth 21,500 8,600 -6,165
C – High Housing Growth 23,500 9,400 -5,365
4.31 It is clear from the above that it is unlikely that the affordability problem in South Cambridgeshire will not be resolvable through housing delivery alone but the Council nonetheless has a responsibility to set housing targets which make a meaningful contribution to meeting the affordable housing needs of the District.
4.32 However, whilst the affordable housing needs are an important indicator of future housing requirements wider supply and demand issues associated with open market housing also need to be considered.
Housing Delivery
4.33 Despite the relative buoyancy of the local economy, at least up to 2007, the delivery of new housing within South Cambridgeshire over the last 10 years has fallen well short of the housing targets within the Adopted Development Plan. The 2003 Cambridgeshire Structure Plan initially proposed housing targets of 1,176 dwellings per annum in South Cambridgeshire. The East of England Plan which was adopted in 2008 maintained these house building requirements requiring 1,175 dwellings per annum.
4.34 As can be seen from Table 4.9 below, actual housing delivery rates within the District have fallen significantly below these targets with housing completions ranging from 525 in 2001/2 and peaking at 1,274 in 2007/8 before subsequently falling back during the recession. Indeed, with the
23 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
exception of 2007/8, at no other point in the last 10 years has housing delivery within the District met the annual housing requirements set out within either the Adopted Core Strategy or the Council's 'current target' based on the draft RSS Review figures.
Table 4.9: South Cambridgeshire Housing Target Delivery Comparison 2001-2010/11
01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11
Annual 1,176 1,176 1,176 1,176 1,176 1,176 1,176 1,176 1,176 1,176 Requirement
Delivery 525 653 979 571 877 924 1,274 610 611 659
Difference -651 -523 -197 -605 -299 -252 98 -566 -565 -517
Cumulative 1176 2,352 3,528 4,704 5,880 7,056 8,232 9,408 10,584 11,760 Requirement
Cumulative 525 1,178 2,157 2,728 3,605 4,529 5,803 6,413 7,024 7,683 Delivery
Cumulative -651 -1,174 -1,371 -1,976 -2,275 -2,527 -2,429 -2,995 -3,560 -4,077 Difference NB: Based on Housing requirements within South Cambridgeshire LDF and Completions listed in Cambridge AMR.
4.35 The significant shortfall in new housing provision within South Cambridgeshire in comparison to policy requirements is underlined by Fig 4.3 below which illustrates the cumulative shortfall in housing provision over the last ten years.
24 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
Fig 4.3: South Cambridgshire Housing delivery 2001-2011
25000 Cumulative Requirement Cumulative Completions Completions
20000
15000
10000 HouseCompletions
5000
0 2001/02 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/10 2010/11 Year
4.36 It is clear from the table that total housing completions over the period have been significantly below the total required under planning policy requirements with a total of 7,683 new houses having been delivered in comparison with an overall requirement for 11,760 new homes, a shortfall of 4,077 dwellings.
4.37 However, whilst the Council's Sustainability Appraisal sets out the level of housing delivery over the last 10 years, it fails to consider the extent to which delivery has met the housing targets during this period either in terms of those within their adopted Core Strategy or their preferred ‘Option 1’ target of 1,050 dwellings per annum. The significant extent of the shortfall in housing delivery and its implications for future housing delivery is not discussed.
4.38 This is of particular concern given the extremely high levels of housing need highlighted above which have been consistently growing over the last 10 years partly due to this lack of delivery. Indeed, in this regard, the Council's approach to developing housing options fails to reflect the lack of delivery despite the evident housing need. It is considered that this must be properly taken into account in considering appropriate housing requirements for the Plan period.
4.39 This is partly a reflection of the longer lead-in times associated with bringing forward strategic urban extension sites which have only recently started to deliver new housing following their
25 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
allocation in the Council's Local Development Framework. Moreover a number of further allocations have yet to come forward due to difficulties in relocating the existing uses, in particular Cambridge East.
4.40 This underlines the need for the Council to give full consideration to the deliverability of both existing and future allocations and to ensure that the future housing targets provide sufficient flexibility to account for the potential for a certain proportion of sites not to come forward. This is particularly important given the Council's poor record of housing delivery. In this regard, the NPPF emphasises the importance of boosting significantly the supply of housing and suggests that local planning authorities with a record of under delivery should provide a 20% buffer in relation to deliverable sites to provide flexibility.
Housing Land Supply
4.41 In order to establish the extent of residual future housing requirements it is first necessary to establish the baseline position in terms of existing, deliverable housing supply. Based on data from the Council's latest Strategic Housing Land Availability Assessment (SHLAA) published in July 2012 the Council has sought to establish the extent of committed housing supply within the District as set out within the Council's housing trajectories.
4.42 Table 4.10 below provides a summary of the Council's and our own assessment of the extent of committed housing supply within South Cambridgeshire. A more detailed breakdown is provided at Appendix 1.
Table 4.10: Housing Delivery and Committed Housing Supply 2001-2031
SCDC Bidwells
Completions April 2001 - March 2011 7,683 7,683
Committee Sites With Planning permission (March 2011) 2,897 2,897
Other Deliverable Allocation Sites 11,300 7,703
Total Supply 2011-2031 14,197 10,600
Source: South Cambridgeshire SHLAA 2012
4.43 It is evident from Table 4.10 that the Council currently has a committed housing supply of 14,197 dwellings which could be delivered over the Plan period between 2011
4.44 However, having reviewed the Council's SHLAA Housing trajectories in some detail we dispute the deliverability of some of the sites identified within the SHLAA. The Council's Housing Trajectory nonetheless assumes the delivery of houses from a number of sites over which there is considerable uncertainty as to whether and/or when these may come forward. There are a number
26 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
of sites where housing delivery is unlikely to meet the levels suggested within the AMR. In particular, the Council's Housing Trajectory assumes significant development at Northstowe despite the uncertainty over the delivery of the site. Only 1,500 dwellings can be completed prior to any upgrading of the A14 which is still subject to significant uncertainty over funding and delivery timescales. As such, the Council's assumptions regarding housing delivery at Northstowe are considered to be optimistic and can not be relied on. We consider that a lower level of growth at Northstowe should be assumed for the period to 2031. A trajectory setting out our estimation of delivery at Northstowe is set out at Appendix 1.
4.45 It is therefore considered that the ‘existing’ housing supply suggested within the Council’s Housing Trajectory of 14,197 dwellings should actually be approximately 3,600 lower than currently indicated. Taking all of the above considerations into account we consider that a more realistic (and objective) assessment of future housing supply for the period 2011-2031 is approximately 10,600 dwellings.
Housing Options
4.46 The Issues and Options Consultation document set out three housing options and three employment options for the period 2011-2031. These are summarised in Table 4.11 below.
Table 4.11: Summary of Housing Options
Option Reference Total Requirement Annual Comments 2011-2031 Requirement
A – Low Housing Growth 18,500 925 Based on Low Employment Growth projections
B – Medium Housing 21,500 1,075 Based on Draft RSS / Cambridgeshire Growth Development Study
C – High Housing Growth 23,500 1,175 Based on High Employment Growth projections. Equates to continuation of prevailing policies / targets.
4.47 The Council's approach to assessing future housing requirements and the basis upon which the housing options have been derived is totally clear. However, we are concerned that these options are all based purely on different assumptions regarding future employment growth and bare little relation to the extent of existing and future housing need. Moreover, the Council has failed to consider the need to address residual housing requirements arising from the under-delivery of housing over the past 10 years.
27 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
4.48 This is symptomatic of the Council’s overall approach in giving insufficient recognition to the importance of meeting the acute levels of housing need. The approach adopted therefore does not give adequate regard to the requirements of the NPPF which makes it clear that as part of the development of their Local Plans, local planning authorities should make every effort to meet in full the objectively assessed housing needs in their area having regard to a range of considerations. Such failures will mean that the Local Plan will be found unsound.
4.49 A comprehensive comparison of various potential housing requirements and growth scenarios for the Plan Period is provided in Table 4.12 below. This includes clarification of residual housing needs on the basis of the committed supply referred to above of 10,600 dwellings.
Table 4.12: Comparison of Housing Requirement and Growth Scenarios 2011-2031
Housing Scenario Annual Total Residual Requirement Requirement Requirement
Historic Policy-led Structure Plan / Adopted Core 1,176 23,520 12,920 Strategy
Structure Plan / Core Strategy with 1,380 27,597 16,997 Residual
Adopted RSS Target 1,175 23,500 12,900
Adopted RSS Target with residual 1,379 27,577 16,977
RSS Review Target 1,050 21,000 10,400
RSS Review Target with residual 1,254 25,077 14,477
Population-led ONS Population & Household 1,150 23,000 12,400 Projections
CCC Population & Household 950 19,000 8,400 Projections
Jobs-led East of England Forecasting Model 1,040 20,800 10,200 (EEFM) Baseline Scenario
East of England Forecasting Model 1,035 20,700 10,100 (EEFM) Lost Decade Scenario
East of England Forecasting Model 1,155 23,100 12,500 (EEFM) High Migration Scenario
Needs-led Housing Need at 40% delivery 2,447 36,912 26,312
Delivery-led Historic Delivery Rates 768 15,366 4,766
4.50 As can be seen from the table, the housing growth forecasts range from approximately 19,000 houses under the CCCRG forecasts to nearly 37,000 houses under the housing needs-led
28 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
scenario where this is delivered at 40% affordable housing levels. Whilst the latter is clearly a scenario which is likely to raise questions regarding deliverability and environmental sustainability, it is nonetheless an important reminder of the high levels of housing need evident within SCDC.
4.51 In considering appropriate housing targets it is considered important to ensure that the proposed level of housing provision is consistent with future job growth targets to ensure that growth is delivered in a mixed and balanced and sustainable manner. The East of England Forecasting Model Scenarios suggest the need for 23,100 new dwellings to support these levels of jobs growth.
4.52 However, in considering appropriate housing requirements, it is also important to address the acute levels of housing need and in particular the significant backlog of existing unmet housing need established through the Council's Housing Waiting List. The NPPF confirms the Government's objective to 'boost significantly' the supply of housing in order to deliver a wide choice of high quality homes to meet future housing needs and emphasises that 'every effort should be made objectively to identify and then meet the housing, business and other development needs of their area and respond positively to wider opportunities for growth'. In this regard, the Council's evidence base in relation to housing fails to provide a robust, comprehensive and up-to-date assessment of housing needs and demand as required by the NPPF.
4.53 It is clear from the information within the Council's evidence base that SCDC's 'current' housing target of 21,000 dwellings gives insufficient consideration to this issue. Levels of housing need within the District are acute with the Housing Waiting List having risen to 4,054 and a five year requirement of 845 dwellings per annum to address the backlog of housing need alone. The latest assessment of housing need for the Plan period is for 14,765 additional affordable dwellings up to 2031. This needs to be given significant weight in establishing appropriate housing forecasts for the District to 2031.
4.54 Similarly, it is also important that any assessment of future housing requirements takes into account the extent and nature of previous shortfalls in housing delivery. This is particularly significant given that the shortfall in the number of dwellings delivered between 2001 and 2011 of 4,077 based on the Council's adopted housing requirements corresponds closely with the backlog of existing unmet housing need of 4,225 dwellings.
4.55 Taking the employment-led housing requirement together with the shortfall in housing delivery between 2001 and 2011 would suggest that the Council should be seeking to provide a minimum of 27,200 additional dwellings (1,360 per annum). Based on an existing supply of approximately 10,600 dwellings through existing commitments and deliverable SHLAA sites, this would result in a potential residual requirement for at least 16,600 additional dwellings to be identified through new sites in accordance with the established settlement growth hierarchy for the Cambridge Sub-
29 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
region. Consequently, of the current Consultation Options, it is considered that Option 3 (23,500 dwellings) is the most appropriate of the Council's options but is nonetheless insufficient to meet housing needs for the plan period 2031. Further housing sites will need to be identified to address the backlog of housing need and provide flexibility. Windfall sites would clearly help in this regard but should not be included within the requirement. Therefore, a further option (Option 4 of 27,200 dwellings) needs to be given serious consideration.
30 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
5 Conclusions
5.1 Having reviewed the Council's approach to setting housing and employment targets we consider that the Council has not approached matters correctly having regard to Government guidance in the NPPF and has developed housing options based on future employment growth rather than an objective assessment of future needs and requirements based on a wide range of indicators. This is of particular concern giving the importance of the local economy and the extent of local housing needs.
5.2 The Greater Cambridge area is widely seen as an economic success story both in the context of the UK Economy and also in terms of its international significance with one of the world's most advanced and concentrated technology clusters. As a result of its dynamic high-technology focussed economy, the Greater Cambridge area is identified as one of the places most likely to lead the UK back to growth.
5.3 Moreover, the NPPF emphasises the importance of supporting growth and economic development and requires local planning authorities to 'proactively drive and support' sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. It emphasises that 'every effort should be made objectively to identify and then meet the housing, business and other development needs of their area and respond positively to wider opportunities for growth'.
5.4 It is therefore vital that the policies within the Local Plan seek to positively facilitate job growth within South Cambridgeshire as far as possible given the strategic importance that the local economy has to the UK's future economic prospects in seeking to lead the Country back to growth. Whilst this clearly needs to be managed in an effective manner such that the quality of the area's historic and natural environments are maintained, it is nonetheless essential to the UK's national economic interests that the local authorities and their strategic partners within the area develop appropriate policies to facilitate and deliver the sustainable growth of the Greater Cambridge area.
5.5 Consequently, the Council should seek to adopt an aspirational, high growth target which provides the greatest prospect of the local economy fulfilling its significant potential as a globally significant high-tech cluster. Such an approach is essential to enable the local economy to effectively compete against other global clusters and thereby help to lead the UK economy back to growth.
5.6 The Council's current evidence in relation to future jobs growth projections suggests that the various higher growth scenarios would result in the region of 30,000 new jobs. Of the various employment growth scenarios it is therefore considered that Option C (29,200 additional jobs) is the most appropriate. However, since certain growth scenarios suggest potential for higher levels
31 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
of job growth the Council should not seek to unduly limit employment growth to this level given the strategic importance of the local economy. This should therefore be regarded as a minimum target with appropriate flexibility provided through the allocation of a range of suitable employment sites to meet a range of potential needs in line with the NPPF requirements.
5.7 In considering appropriate housing targets it is considered important to ensure that the proposed level of housing provision is consistent with future job growth targets to ensure that growth is delivered in a mixed and balanced and sustainable manner. The East of England Forecasting Model Scenarios suggests the need for 23,100 new dwellings to support these levels of jobs growth.
5.8 However, in considering appropriate housing requirements, it is also important to address the acute levels of housing need and in particular the significant backlog of existing unmet housing need established through the Council's Housing Waiting List. The NPPF confirms the Government's objective to 'boost significantly' the supply of housing in order to deliver a wide choice of high quality homes to meet future housing needs and emphasises that 'every effort should be made objectively to identify and then meet the housing, business and other development needs of their area and respond positively to wider opportunities for growth'. In this regard, the Council's evidence base in relation to housing fails to provide a robust, comprehensive and up-to-date assessment of housing needs and demand as required by the NPPF and consequently must be regarded as an unsound basis for plan preparation.
5.9 Nonetheless, it is clear from the information within their evidence base that the Council's 'current' housing target of 21,000 dwellings gives insufficient consideration to this issue. Levels of housing need within the District are acute with the Housing Waiting List having risen to 4,054 and a five year requirement of 845 dwellings per annum to address the backlog of housing need alone. The latest assessment of housing need for the Plan period is for 14,765 additional affordable dwellings up to 2031. This needs to be given significant weight in establishing appropriate housing forecasts for the District to 2031.
5.10 Similarly, it is also important that any assessment of future housing requirements takes into account the extent and nature of previous shortfalls in housing delivery. This is particularly significant given that the shortfall in the number of dwellings delivered between 2001 and 2011 of 4,077 based on the Council's adopted housing requirements corresponds closely with the backlog of existing unmet housing need of 4,225 dwellings.
5.11 Taking the employment-led housing requirement together with the shortfall in housing delivery between 2001 and 2011 would suggest that the Council should be seeking to provide a minimum of 27,200 additional dwellings (1,360 per annum). Based on an existing supply of approximately
32 Commercial Estates Group Cambridge South East – SCDC Issues & Options Representations September 2012
10,600 dwellings through existing commitments and deliverable SHLAA sites, this would result in a potential residual requirement for at least 16,600 additional dwellings to be identified through new sites in accordance with the established settlement growth hierarchy for the Cambridge Sub- region. Consequently, of the current Consultation Options, it is considered that Option 3 (23,500 dwellings) is the most appropriate of the options put forward by the Council but is nonetheless insufficient to deliver the number of dwellings needed by 2031. Further housing sites will need to be identified to address the backlog of housing need and provide flexibility. Windfall sites would clearly help in this regard and should not be included within the minimum requirement. Therefore, a further option (Option 4 of 27,200 dwellings) needs to be given serious consideration.
5.12 Given the scale of housing growth required, the Council should be seeking to undertake a comprehensive Green Belt Review in order to assess the suitability and capacity of sites to accommodate these levels of growth in line with Government guidance and policy objectives. Further analysis is required in this respect but, given the scale of newly arising housing need forecast for the Plan period the Council should seek to provide a significant amount of housing on the edge of Cambridge in accordance with the established growth hierarchy for the Cambridge Sub Region to ensure the most sustainable pattern of development possible.
33 Suggested Northstowe Delivery
2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Phase 1 100 150 150 250 350 350 150
Phase 2 100 150 150 250 350 350 350
100 150 150 250 350 350 250 150 150 250 350 350 350
SCDC's Housing trajectory for Northstowe (AMR Jan 2012)
2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 100 175 275 460 520 500 500 500 500 500 500 500 500 500
Assumptions for Phase 1 application (1,500 dwellings)
Outline planning application decision = Winter 2012 Section 106 = Spring 2013 Reserved matters application = Summer 2013 Reserved matters decision = Autumn 2013 Discharge of conditions = Autumn 2013 Delivery of infrastructure = Winter 2013 Commencement = Spring 2014 2027/28 2028/29 2029/30 2030/31 Total
1500
350 350 350 350 3100
350 350 350 350 4600
2027/28 2028/29 2029/30 2030/31 Total 500 500 500 500 8030 Comments on the Sustainability Appraisal Scoping Report and the Initial Sustainability Appraisal Report
Appendix B
Commercial Estates Group Cambridge South East September 2012 Commercial Estates Group Cambridge South East September 2012
Table of Contents
EXECUTIVE SUMMARY...... 1
1 INTRODUCTION...... 2 Purpose of the Report ...... 2 Background to the Proposals...... 2 Structure of the Report...... 2
2 POLICY AND LEGISLATIVE BACKGROUND...... 4
3 THE SA PROCESS...... 7 The SA Process to date ...... 7 SA Scoping Report...... 9 Appraisal of Site Options...... 12 ISA of South Cambridgeshire Local Plan...... 14
4 SUSTAINABILITY MATRIX UNDERTAKEN FOR CAMBRIDGE SOUTH EAST...... 15
5 COMPARISON WITH SUSTAINABILITY MATRIX UNDERTAKEN HERE FOR CSE AND SCDC MATRIX ON BROAD LOCATION 7...... 28
6 APPRAISAL DISCUSSION OF BROAD LOCATION 7...... 29
7 COMPARISON OF SUSTAINABILITY MATRIX UNDERTAKEN HERE AND SCDC MATRIX ON THE EFFECTS OF NO GREEN BELT RELEASE ...... 32
8 DISCUSSION ON EFFECTS OF NO GREEN BELT RELEASE...... 33 Appraisal of Site Options...... 33
9 CONCLUSION...... 37 EXECUTIVE SUMMARY
The Sustainability Appraisal Scoping Report and the Initial Sustainability Appraisal Report should help ensure that the emerging policies and proposals achieve sustainable development. The process and methodology is in enough detail to be transparent. However, there are some issues associated with the Appraisals which do not allow the proper identification of the very most sustainable site options. The differential between the very most sustainable site options and lesser options may not be fully understood leading to poor decision making. The National Planning Policy Framework is clear that the purpose of the planning system is to contribute to the achievement of sustainable development.
The on-going effect of the reduced need to travel due to the sustainable location of new development is not properly considered. The long term effect on climate change and air quality has not been taken into account in the Appraisal.
The Decision Making Criteria related to the Sustainability Objective of reducing the need to travel in particular is not helpful in identifying the most sustainable locations for development because it does not allow for walking; it does not take into account that short cycle journeys are much more likely to be undertaken than longer journeys. We propose an additional Decision Making Criterion to allow for short cycle journeys on foot or by cycle. The likelihood of using the cycle decreases markedly for journeys greater than 5km and therefore the weighting used is skewed to favour longer journeys. Also, it is not recognised that the City offers alternative locations for services and facilities other than in the centre of town. These factors are not accounted for in the Sustainability Appraisal undertaken but should be in order to ensure there is a proper balanced view of sustainability.
A Sustainability Appraisal of Cambridge South East is undertaken according to the Decision Making Criterion so that the Council has the most up to date understanding of the base line associated with CSE.
Notwithstanding the problems outlined, even so, comparing the Sustainability Appraisal of CSE against the option of undertaking no Green Belt review and the most sustainable new settlement identified by South Cambridge District Council, it can clearly be seen that development of CSE is the most sustainable location for development.
1 1 INTRODUCTION
1.1 This report reviews sustainability issues with special regard to Broad Location 7: Land between Babraham Road and Fulbourn Road.
Purpose of the Report
1.2 This report entitled 'Comments on the Sustainability Appraisal Scoping Report and the Initial Sustainability Appraisal Report' has been produced by Bidwells on behalf of Commercial Estates Group Ltd (CEG) to support its submissions in response to South Cambridgeshire's Issues and Options Consultation. CEG is currently promoting proposals for a large, residential led, mixed-use, urban extension to the south of Fulbourn Road and north east of Babraham Road known as Cambridge South East.
1.3 This report provides a review of the Council's Sustainability Appraisal Scoping Report June 2012 (SR) and the Initial Sustainability Appraisal (ISA) July 2012. Specifically it seeks to examine the way the Council has interpreted its own key sustainability issues in relation to Broad Location 7.
Background to the Proposals
1.4 The Cambridge South East (CSE) site comprises approximately 214 hectares of land on the south eastern fringe of Cambridge, south of Fulbourn Road and north east of Babraham Road. The draft conceptual proposals for the site currently envisage the development of a new, residential led, mixed-use neighbourhood of Cambridge, comprising:
x Up to 3,100 market, affordable and key worker dwellings;
x 9.7 hectares of R/D/B1a Employment Development;
x a neighbourhood centre;
x Public Open Space;
x strategic landscaping; and
x Highways and other supporting infrastructure.
1.5 The site straddles the South Cambridgeshire District Council (SCDC) and Cambridge City Council boundary, with the majority of the proposed development likely to take place within Cambridge City. It is anticipated that development within SCDC will comprise approximately 1,000 houses.
Structure of the Report
1.6 The report is structured as follows:
2 x Policy and Legislative Background; x The Sustainability Appraisal Process; x Sustainability Matrix undertaken for CSE; x Comparison with Sustainability Matrix undertaken here on CSE and SCDC Matrix on Broad Location 7; x Appraisal Discussion on Broad Location 7; x Comparison of Sustainability Matrix undertaken here and SCDC Matrix on the effects on no Green Belt release; x Discussion on effects of no Green Belt release; and x Conclusion.
3 2 POLICY AND LEGISLATIVE BACKGROUND
2.1 Since the 1980's probably the most quoted definition of sustainability as part of the concept of sustainable development is 'sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs' Brundtland Commission of the United Nations 1987.
2.2 Urban extensions are widely recognised as a particularly sustainable form of development which allow for strategic development needs to be met through the delivery of significant levels of new housing and other complementary uses, whilst maximising the benefits associated with proximity and accessibility to existing employment opportunities, services and facilities. In 2003 Cambridgeshire and Peterborough Structure Plan directed new development in the Cambridge Sub-Region in the most sustainable sequence as follows:
i within the built up area of Cambridge;
ii on the edge of Cambridge subject to a review of the Green Belt boundary;
iii a new settlement at Longstanton/Oakington (Northstowe); and
iv market towns, previously established new settlements and rural centres.
2.3 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these are applied. At the heart of the NPPF is a presumption in favour of sustainable development.
2.4 The NPPF defines sustainable development as five principles as set out in the UK Sustainable Development Strategy: living within the planet's environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.
2.5 NPPF paragraph 150 states that 'Local Pla ns ar e t he key to deliver ing sus tainable d evelopment that reflects the vision and aspiration of local communities'.
2.6 Section 39(2) of the Planning and Compulsory Purchase Act 2004 requires that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development.
2.7 NPPF paragraph 152 states that in plan making 'local planning authorities shou ld seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development and net gains across all three'.
2.8 For plan making the NPPF paragraph 14 sets out that this means:
4 Local pl anning aut horities should positively seek opportunities t o meet the deve lopment needs of their area;
Local Plans should meet objectively assessed needs, with suf ficient flexibility t o adapt to rapid change, unless:
Any adv erse impac ts of doing so w ould sig nificantly and demonst rably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or
Specific policies in this Framework indicate development should be restricted'.
2.9 The NPPF shows how sustainable development should be interpreted. Those which are of particular relevance to SCDC Local Plan are:
Building a strong, competitive economy, paragraphs 18-22;
Ensuring the vitality of town centres, paragraphs 23-27;
Promoting sustainable transport, paragraphs 29-41;
Supporting a high quality communications infrastructure, paragraphs 42-46;
Delivering a wide choice of high quality homes, paragraphs 47-55;
Requiring good design, paragraphs 56-68
Promoting healthy communities, paragraphs 69-78;
Protecting Green Belt land, paragraphs 79-92;
Meeting the challenge of climate change, flooding and coastal change, paragraphs 93-108; and
Conserving and enhancing the natural environment, paragraphs 109-120.
2.10 The Council's vision is that South Cambridgeshire will demonstrate impressive and sustainable economic growth with residents having a superb quality of life in an exceptionally beautiful, rural and green environment. The NPPF requires local planning authorities to set out a clear economic vision for their areas which proactively encourage sustainable economic growth. Sustainable growth should be of paramount importance in the consideration of how South Cambridgeshire should grow.
2.11 A Sustainable Appraisal is the process of assessing the likely impacts of a plan on the environment, the community and the economy. By law, a Sustainability Appraisal must be carried out on plans that set out the spatial planning requirements of a local authority.
5 2.12 In addition, the European Directive 2001/42/EC also requires certain plans to undergo a Strategic Environmental Assessment (SEA). This directive was incorporated into UK law in 2004. The Government recommends that these two processes are integrated and simply referred to as SA.
2.13 To avoid confusion, the term Sustainability Appraisal or SA will be used to describe the Sustainability Appraisal including Strategic Environmental Assessment required by legislation.
2.14 The NPPF sets out the overarching sustainability issues which need to be taken into account in the overall SA framework of a Plan. SCDC has set out its Sustainability Objectives in the Scoping Report issued in June 2012.
6 3 THE SA PROCESS
The SA Process to date
3.1 The requirement to provide a Sustainability Appraisal (SA) of the South Cambridgeshire Local Plan (SCDCLP) is held in law under the terms of the EU Strategic Environmental Assessment Directive (2001/42/EC). The Directive has been in force since June 2001 and as such a Sustainability Appraisal is a well established part of the formal plan making process.
3.2 In this case, SCDC has undertaken an initial SA of the emerging SCDCLP. The purpose of the SA is to provide a mechanism for considering the sustainability issues resulting from the SCDCLP approach, and alternatives to that approach, with a view to mitigating any adverse impacts and maximising positive impacts.
3.3 The SA process is a five stage approach as follows:
Stage A reviews evidence to identify the draft SA Framework and the output is the Scoping Report;
Stage B appraises the draft Plan issues and options set against the SA framework and makes recommendations to minimise any negative impacts and to enhance the positive impacts;
Stage C reports on the SA findings and Interim (or Initial) SA and Final SA reports are produced;
Stage D consults stakeholders on SA findings resulting in a Revised Final SA report if necessary; and
Stage E Monitors the implementation of the Plan post adoption.
3.4 To date, SCDC has produced a Scoping Report June 2012 representing Stage A, undertaken Stage B and sets out the SA findings in an Initial SA Report July 2012 representing Stage C.
3.5 The Scoping Report (SR) seeks to collate baseline evidence in order to build an understanding of the sustainability issues that will need to be addressed. This process provides the basis of the SA Framework, from which the scope of the assessment is determined. Accordingly, the SA process is limited by the availability and accuracy of the data available at the time of writing. The Council states that comments can be made on the Scoping Report at the Issues and Options Stage.
3.6 It is recognised that SA is an iterative process. The SCDCLP is at an early stage. The Council is currently looking to consult on an 'Issues and Options' document and acknowledges the iterative nature of the SA approach. The ISA represents an appraisal of all options presented and is
7 published alongside the plan document 'to prov ide the public and s tatutory bodies w ith an opportunity t o express their opinio ns on it and so t hat views can be cons idered bef ore t he L ocal Plan is drafted'.
3.7 SCDC has drawn on its Strategic Housing Land Availability Assessment (SHLAA) of the sites proposed for development together with the Sustainability Appraisal of each site and a summary assessment that draws together the two assessments and reaches a view on the 'Sustainable Development Potential' of each site.
3.8 The Council goes on to describe that a different approach is taken to land in the Green Belt on the edge of Cambridge, with a co-ordinated approach taken with Cambridge City Council (CCC) to look at broad locations in the Green Belt around Cambridge.
3.9 In order for the Plan to be sound, the evidence base must include a robust SA at a level of detail which allows proper determination of the likely effects of the Plan.
3.10 It is therefore of some concern that the land on the edge of Cambridge high in the sequence of sustainable development locations, is not compared directly to other less sustainable locations for growth.
3.11 It should be noted that the ISA can only describe the current baseline known by SCDC. Accordingly, additional site and issue specific information will emerge from the formal consultation stages which may have a bearing on the content and outputs of the final SA Report. This will ensure that any conclusions are based on the most up to date and accurate data. This report seeks to enlighten the process with emerging work currently being undertaken on Broad Location 7 which is not represented in the ISA of the Issues and Options against the SA Framework.
3.12 It is noted under ISA paragraph 5.16 information available at the time of the appraisal is used. Following consultation on the Issues and Options Report, the Council may be made aware of further information that necessitates consideration. CEG argues that the emerging plans for Broad Location No 7 need to be understood and the details fed into the SA framework so that a true and sound picture of how this option supports the Sustainability Objectives the Council has identified, especially when compared to other development options.
3.13 Therefore, a sustainability appraisal will be undertaken of Broad Location 7 in this document which is based on the emerging plans and information against the identified Sustainability Objectives. This shows the current known position of how this option supports, or not, the Sustainability Objectives of the Plan.
8 SA Scoping Report
3.14 SCDC has identified key sustainability issues through the Scoping process and from this identifies Sustainability Objectives to guide the assessment of the environmental, social and economic impacts of a policy or site option, in order to identify and respond to significant effects.
3.15 SCDC states in paragraph 9.4 'significance can vary depending on the context, but judgements will be made in light of the baseline information, and the extent and duration of the effect'.
3.16 The Sustainability Objectives provide a framework for testing policies in a consistent and comparable manner. The Objectives reflect desired environmental, social or economic outcomes as follows.
THEME SUSTAINABILITY OBJECTIVE
LAND Minimise the irreversible loss of undeveloped land, economic mineral reserves and productive agricultural holdings.
Minimise waste production and support the reuse and recycling of waste products.
POLLUTION Improve air quality and minimise or mitigate against sources of environmental pollution.
BIODIVERSITY Avoid damage to designated sites and protected species.
Maintain and enhance the range and viability of characteristic habitats and species.
Improve opportunities for people to access and appreciate wildlife and green spaces.
LANDSCAPE AND Maintain and enhance the diversity and local distinctiveness of landscape TOWNSCAPE and townscape character.
Avoid damage to areas and sites designated for their historic interest and protect their settings.
Create places, spaces and buildings that work well, wear well and look good.
9 CLIMATE Minimise impacts on climate change (including greenhouse gas emissions). CHANGE
Reduce vulnerability to future climate change effects.
HEALTH Maintain and enhance human health.
Reduce and prevent crime and reduce fear of crime.
Improve the quantity and quality of publicly accessible open space.
HOUSING Ensure everyone has access to decent, appropriate and affordable housing.
INCLUSIVE Redress inequalities related to age, disability, gender, race, faith, location COMMUNITIES and income.
Improve the quality, range and accessibility of services and facilities (e.g. health, transport, education, training, leisure opportunities).
Encourage and enable the active involvement of local people in community activities.
ECONOMIC Improve the efficiency, competitiveness, vitality and adaptability of the local ACTIVITY economy.
Help people gain access to satisfying work appropriate to their skills, potential and place of residence.
Support appropriate investment in people, places, communications and other infrastructure.
TRANSPORT Reduce the need to travel and promote more sustainable transport choices.
Secure appropriate investment and development in transport infrastructure, and ensure the safety of the transport network.
3.17 The Council also identifies Decision Making Criteria and Indicators which should allow for a more robust and transparent appraisal.
3.18 We are concerned that the Decision Making Criteria are not always conducive to identifying the most sustainable locations for development. The Council has an Objective to minimise impacts on
10 climate change (including greenhouse gas emissions). The Council states that as sustainable transport is addressed elsewhere in the ISA its appraisal of the Objective primarily focuses on impacts of development on energy use. However, the impact of transport emissions on the Climate Change Objective is not properly addressed in the ISA, either under the Climate Change section or the Transport section. Increasing the need to travel by providing development further away from employment, services and facilities means that an increased level of fossil fuels will be used over and above that which would be needed if development was on the edge of Cambridge. Fossil fuels result in the production of carbon dioxide which intensifies the greenhouse effect causing global warming. Road transport accounts for 22% of total UK emissions of carbon dioxide (http://www.environmental-protection.org.uk/transport/car-pollution/). This important aspect of climate change is not addressed properly in the Sustainability Appraisal.
3.19 Also, we conclude the effect of minimising car journeys is not fully reflected in the Sustainability Objective which requires minimising or mitigating against sources of pollution. Emissions saved by providing housing close to employment and service facilities will help mitigate the effects of air pollution.
3.20 This is a major deficiency in the Sustainability Appraisal, as the effect of global warming is considered to be a major consideration for our future and the Government is committed to meeting the challenge of a low carbon future (NPPF paragraph 18).
3.21 Development on the edge of Cambridge can also deliver significant positive outcomes on the following Objectives:
Improve the quality, range and accessibility of services and facilities – The Council states that 'focusing developm ent on b etter ser ved locat ions could h ave t he greatest positive impact on achiev ement of this objective'. We show that development on the edge of Cambridge has the most potential to deliver access to the widest range of services and facilities and is the best served location.
Help people gain access to satisfying work appropriate to their skills, potential and place of residence – The Council states that delivering new employment provision near Cambridge could deliver a significant positive impact on this Objective. We conclude that not only the provision of jobs on the edge of Cambridge but also the provision of housing on the edge of Cambridge benefits this objective as this would give people easy, affordable access to the pool of jobs.
Reduce the need to travel and promote more sustainable transport choices - The Council states in the ISA page 28 that 'Delivery of housing could support putting homes near to
11 jobs and have positive impacts on commuting patterns. Development Strategy options which propose development close to Cambridge or in new settlements have the greatest potential to deliver access to the widest range of services and facilities' and continue that 'Options…could potentially have a significant negative impact on achievement of the overall objective by increasing the need to travel and reducing opportunities for sustainable modes of travel'. The most sustainable travel is by foot, cycle or short journeys on public transport. Edge of Cambridge development is the most supportive growth option for this objective. Development on the edge of Cambridge clearly has the greatest potential to deliver access to the widest range of services and facilities over and above new settlements.
3.22 We have, therefore, a number of reasonable concerns that the full sustainability credentials of sites on the edge of Cambridge are not recognised.
Appraisal of Site Options
3.23 The Council states 'the Sustainability Objectives will be used to establish the effect of site options. To ass ist in mak ing impac ts quant ifiable, measurable and transparent, and f or t he direc t comparison between sites to be made, the S ite Assessment Matrix at Table 10 indicates how the impact of individual sit es w ill be est ablished o n t he o bjective ( or dec ision making cr iteria) at the Issues and Options stage of plan making'.
3.24 We are concerned that Table 10 is not relevant in part for large urban extensions which are high in the sequence of sustainable locations for development. For example, one of the sub criterion used for 'Economic Activity, Helping people gain access to satisfying work appropriate to their skills and potential' is based on access by public transport to the nearest area of employment with 2,000 plus employees in a certain time scale. This particular sub criterion does nothing to reflect the very best sustainable location of development on the edge of Cambridge. In particular CSE would be within easy cycling distance of three major employers, and if the proposed employment allocation comes forward, within easy walking distance of an additional employment area. This major positive benefit of edge of CSE is not reflected in the Site Options Assessment Matrix and is therefore an impediment to positively identifying the most sustainable locations for development.
3.25 In addition, under 'Transport, Reducing the need to travel and promote more sustainable transport choices' the Decision Making Criteria are stated to be based on enabling shorter journeys, improving modal choice and integration of transport modes. However, three of the four are based on public transport including distance to the nearest bus stop/railway station and the frequency and length of journey. There is no acknowledgement that an urban extension would bring forward an integrated public transport system with bus stops throughout the development. In addition, CSE
12 could utilise the nearby Park and Ride and Addenbrooke's to create an efficient and effective transport interchange hub. No allowance is made for this sort of potential which could be brought forward on the back of developing CSE and which would make it one of the most sustainable options for development. This would go un-noticed with the current scoring proposed. One sub- indicator is based on cycling, with weighting given to distance. However, the weighting appears skewed. Whilst cycle journeys of up to 5km, especially on roads with cycle lanes clearly marked, are achievable by many, it is much more unlikely for individuals to undertake increasingly long journeys. The fact that the 10-15km journey scores 50% (three points) of journeys less than 5km (six points) is unrealistic and skews the sustainability credentials of sites which are less positive. There should also be an allowance for journeys of less than 2km where cycling would be an increasingly likely choice of transport mode. There is no allowance for walking distances in the Decision Making Criteria. We consider this an oversight. If CSE goes ahead, many houses on the development would be within walking distance of the 9.7ha of employment which will be provided. The Transport Assessment which accompanies this submission shows that Cherry Hinton High Street, Addenbrooke's and Capital Park are within 2km walking distance and are therefore very accessible by foot from CSE. Walking distances are not mentioned. We propose that distances of 2km or less should be in the sub-indicators to the Decision Making Criteria scoring the highest number of points.
3.26 The sub-indicator does not allow for service facilities other than in the City/town centre. Whilst it is true that most services and community facilities are likely to be found in the centre of a market town, within the City there are local nodes of facilities in the suburban areas which could be used for day to day needs with longer journeys into the City centre not needed as often. This should be reflected in the Decision Making Criteria and the sub-indicator should not be just distance for cycling to City centre or market town, but include walking options to local shopping/service facilities. For example, Cherry Hinton High Street would provide CSE with a local services and facilities node, catering for day to day needs. There would be less need to journey to the City centre.
3.27 We have, therefore, a number of justifiable concerns with the Decision Making Criteria for the Assessment Matrix for Appraisal of Site Options in that:
it is not refined enough to differentiate the very most sustainable development locations where there is close proximity to major employers and facilities from other proposed development at a greater distance from employers and facilities;
the sub-indicators are skewed away from the most sustainable locations on the edge of Cambridge because they do not allow for shorter distances of 2km or less to facilities; and
13 the sub-indicators are skewed in favour of longer journeys over 10-15km which are scored at 50% of the likelihood of journeys of up to 5km and therefore to less sustainable developments.
ISA of South Cambridgeshire Local Plan
3.28 The consultation on the Issues and Options along with the Initial Sustainability Report is currently taking place.
3.29 The ISA makes it clear that it was carried out to support the Issues and Options consultation to help identify reasonable alternative options that the plan could implement, and test them to identify the potential impacts and their relative sustainability. We have already shown our concern about the testing framework in that sustainability issues are not fully explored and the Decision Making Criteria for the Appraisal of Sites – Table 10 of the Scoping Report - in that it does not allow for the highly sustainable sites such as CSE to be differentiated from lesser sites on several counts. This is considered a major failing in the process.
3.30 The ISA sets out the objectives of the plan and what the plan is seeking to achieve with the overall aim to help ensure that the South Cambridgeshire Local Plan makes an effective contribution to the pursuit of 'sustainable development'. The purpose of the ISA is to help identify reasonable alternative options that the plan could implement, and test them to identify the potential impacts and their relative sustainability. We are concerned that the very most sustainable locations for development will not be identified, which must lead to the conclusion that the plan is unsound unless the analysis is corrected.
3.31 The ISA appraises the individual issues and sites and presents the findings. We consider the base line information on which the appraisal is based is no longer up to date. We have, therefore, undertaken our own appraisal on the impact on the Sustainability Objectives of Broad Location 7 and compared this against the Council's own appraisal.
14 4 SUSTAINABILITY MATRIX UNDERTAKEN FOR CAMBRIDGE SOUTH EAST
4.1 Please note this matrix is based on the Sustainability Appraisal for Sites using the Decision Making Criteria. The greyed out parts of the table indicate that the Council considers the criterion to not depend on location but rather to the emerging design.
Sustainability Objective Decision Criteria Comments Likely Effect
1. Minimise the Will it use land that has been previously The site has not been previously developed. 0 irreversible loss of developed? undeveloped land, economic mineral reserves, productive Will it use land efficiently? SCDC states that this is dependent on the design of agricultural holdings, development and not the location. However, it should be noted and the degradation / that it is the intent of CEG to use the land efficiently. loss of soils
Will it protect and enhance the best and The land is in Grade II and Grade III. However, it should be ? most versatile agricultural land? noted that any site on the edge of Cambridge or a new
Land settlement is likely to impact this criterion.
Will it avoid the sterilisation of economic The site is not within a designated area identified in the Minerals 0 mineral reserves? and Waster LDF. Development would not have a negative impact. Will it minimise the degradation/loss of soils due to new development?
2. Minimise waste Will it encourage reduction in household SCDC considers that this is dependent on the design of
15 production and support waste, and increase waste recovery and development and not the location. It is worth noting that CEG the reuse and recycling recycling? supports the reduction of household waste and increase in of waste products waste recovery and recycling.
3. Improve air quality Will it maintain or improve air quality? The site does not lie within an AQMA. CSE is one of the edge +++ and minimise or of Cambridge broad growth areas furthest removed from the mitigate against A14 and therefore likely to have least impact. CSE would sources of however assist in promoting sustainable means of commuting environmental pollution by providing for the housing needs of Cambridge's workforce close to the City, resulting in a reduction in private vehicular trips and their associated emissions.
Will it minimise and where possible The development would help remove the existing in-commuting +++ improve on, unacceptable levels of to Cambridge. It would provide housing in a location accessible noise, light pollution, odour and to services, facilities and employment on foot, cycle and by vibration? public transport.
Pollution
Will it minimise, and where possible Development would not be on land likely to be contaminated. 0 address, land contamination?
Will it protect and where possible CSE would improve the quality of local water courses via +++ enhance the quality of the water the provision of a Sustainable Drainage Measures environment? (SuDS) strategy which will adopt a treatment train approach to the improvement of water quality. The
16 change of use of the land from agriculture to primarily residential development will reduce the volume of nitrates and phosphates released to the watercourse network and therefore provide further valuable water quality benefits.
CSE is readily able to improve the existing sewerage infrastructure, where necessary to convey flows to the Milton Sewage Treatment Works, which will have adequate capacity for the development. It is anticipated that the proposed infrastructure improvements will deliver certain localised relief to existing capacity constraints.
4. Avoid damage to Will it conserve protected species and CSE is adjacent to the Cherry Hinton Chalk Pit SSSI, Gog + designated sites and protect sites designated for nature Magog SSSI, the Roman Road SSSI and incorporates areas protected species conservation, interest and geodiversity? which are currently designated as County Wildlife Sites and Protected Roadside Verges. These areas would be protected and enhanced to form a network of sites which reflect the natural character of the area and deliver significant biodiversity enhancements, as well as securing improved public accessibility to local wildlife sites.
5. Maintain and Will it reduce habitat fragmentation, CSE would provide a unique opportunity to convert arable +++ enhance the range and enhance native species, and help farmland into an ecological bridge between nationally viability of characteristic deliver habitat restoration (helping to important areas designated for their chalk grassland habitats and species achieve Biodiversity Action Plan communities. This will secure a green wedge which Targets)? extends northwards from Cherry Hinton through CSE to the wider countryside. This would be a significant connection between Gog Magog and the City's green
17 Biodivers space network. ity 6. Improve Will it improve access to wildlife and The emerging plans for CSE are to provide an area of chalk +++ opportunities for people green spaces, through delivery and grassland on part of the site. This would link through the site to access and access to green infrastructure or access bridging the Cherry Hinton Chalk Pits with Wandlebury. It would appreciate wildlife and to the countryside through Public Rights deliver significantly improved access to wildlife and green green spaces. of Way? spaces through the delivery of access to green infrastructure which accesses the countryside through Public Rights of Way.
7. Maintain and Will it maintain and enhance the Whilst the criterion states that built development cannot get a 0 enhance the diversity diversity and distinctiveness of positive impact on the Green Belt, CEG recognises that not all and local landscape character? the site should be developed. CEG has undertaken extensive distinctiveness of surveys and propose to safeguard the land of higher importance landscape and and create green infrastructure. This would maintain the townscape character. distinctiveness of the landscape character and allow access to it for the first time.
Will it maintain and enhance the CEG is undertaking extensive surveys on townscape character 0 diversity and distinctiveness of in the local area to ensure that the new development will relate townscape character? to the local townscape character. The overall effect is that this development would be compatible with the local townscape
18 character.
8. Avoid damage to Will it protect or enhance sites, features There are no areas of historic, archaeological or cultural interest 0 areas and sites or areas of historical, archaeological, or known on the site. designated for their cultural interest (including conservation historic interest, and areas, listed buildings, registered parks Landscap protect their settings and gardens and scheduled e, monuments)? Townsca pe and Cultural Heritage 9. Create places, Will it lead to developments built to a SCDC considers that this is dependent on design and not spaces and buildings high standard of design and good place location. It should be noted that CEG intends that a very high that work well, wear making that reflect local character? standard of design will be built into the proposals creating a well and look good. good place to live and which reflects local character.
10. Minimise impacts Will it support the use of renewable Standard requirements for renewables would apply. It should 0 on climate change energy resources? be noted that appropriate implementation of a renewable energy (including greenhouse option such as biomass fired heating would aid in adaptation to gas emissions). climate change and such measures can more readily be implemented on sizeable development such as CSE.
Will it promote energy efficiency? SCDC considers that this is dependent on design and not location. It should be noted that CEG intends that energy efficient measures will be promoted.
Will it minimise contributions to climate SCDC considers that this is dependent on design and not change through sustainable construction location. It should be noted that CEG intends that sustainable
19 practices? construction practices will be used.
11. Reduce Will it use water in a sustainable SCDC considers that this is dependent on design and not vulnerability to future manner, and enable and encourage location. It should be noted that CEG intends to use high levels climate change effects. high levels of water efficiency? of water efficiency.
Climate Change Will it minimise risk to people and The site is in Flood Zone 1 and it is intended to incorporate a + property from flooding, and incorporate sustainable drainage strategy into the emerging plans for the sustainable drainage measures? site. In addition, there are opportunities for reducing flood risk in Cherry Hinton. Cherry Hinton Village , and Cherry Hinton North and South are identified as 'wetspots' and are therefore considered susceptible to flooding. The provision of a carefully designed SuDS surface water management strategy at CSE will control and reduce water discharged to the Cherry Hinton Brook to a rate below the present day conditions. This will deliver valuable and unique flood risk and drainage betterment to the area.
Will it minimise the likely impacts on Whilst SCDC considers that this is dependent on the type and future development of climate change design of development and not the location, it is considered that through appropriate adaptation? there are fundamental aspects to the location of development which are bound to have repercussions on climate change. CSE is a truly sustainable development, appropriately located close to major employers and with local shops and services close by – these elements will contribute to climate change in a
20 most effective way as no additional energy expenditure is required for long distance commutes for example (most experts agree that the burning of mineral/fossil fuel releases carbon dioxide into the atmosphere thereby directly contributing to global warming and its consequences). In addition, on site interventions such as food and farming would be a focus for the development by providing space for intensive food production areas. The site lies in Flood Zone 1 where climate change on river flood will not have an effect and drainage and infrastructure systems will make allowances for climate change. In addition, appropriate water management strategy at CSE will control and reduce water discharged to the Cherry Hinton Brook to a rate below the present day conditions which will deliver valuable and unique flood risk and drainage betterment to the area. It is our conclusion that this aspect is dependent on location and should therefore be considered in the Sustainability Appraisal for Sites.
Will it use water in a sustainable SCDC considers that this is dependent on design and not manner, and enable and encourage location. high levels of water efficiency?
Health 12. Maintain and Will it promote good health, encourage SCDC notes that this is dependent upon design of development enhance human health. healthy lifestyles, and reduce health not location, however, the points about the creation of green inequalities? space and opportunities for access to the countryside, human health and environmental issues (air quality and other forms of pollution) relate to this criterion and it should be noted these are positive for CSE.
21 13. Reduce and Will it reduce actual levels of crime, and SCDC considers that this is dependent on design and not prevent crime and will it reduce fear of crime? location. It should be noted that Secure by Design guidance will reduce fear of crime. be used for the emerging masterplan.
14. Improve the Will it increase the quantity and quality This development offers significant open space over and above +++ quantity or quality of of publicly accessible open space? that which would be established in the Plan. The emerging publicly accessible masterplan for CSE envisages the creation of large areas of open space. publicly accessible open space as well as significant biodiversity improvements. It will allow the reversion of land in arable cultivation to chalk grassland which is a characteristic habitat type within the area. This area will also act as a 'viewing platform' towards the Cambridge skyline. The availability of this space linking Wandlebury to the Limekiln Close Site of Special Scientific Interest and the Local Nature Reserve within close proximity to existing and future residents would encourage active life styles and access into the countryside and other 'natural' areas beyond the site.
15. Ensure everyone Will it support the provision of a range of SCDC states that it is likely that all sites would be required to has access to decent, quality housing of appropriate types and make provision for affordable housing, in line with the Council's appropriate and sizes, including affordable housing, to adopted policies. It should be noted that CSE will deliver a affordable housing. meet the identified needs of all sectors large number of social rented and intermediate dwellings in of the community? compliance with local authority requirements which would significantly contribute to the supply in South Cambridgeshire.
Will it result in quality homes for people This is dependent on design and not location. within the district to live in?
22 Will it provide for housing for the ageing SCDC considers that this is dependent on design and not population? location. CSE will provide housing in line with the Council's adopted policies.
Will it provide for the accommodation The site would have no effect on pitch or plot provision. 0 Housing needs of Gypsies and Travellers and Travelling Showpeople?
17. Improve the quality, Will it improve accessibility to key local This is an edge of Cambridge location. SCDC uses the +++ range and accessibility services and facilities, including health, settlement hierarchy to consider the accessibility to services of services and facilities education and leisure (shops, post and facilities in that it provides an appropriate proxy for (e.g. health, transport, offices, pubs etc) assessing this objective. education, training, leisure opportunities).
Will it improve quality and range of key Small scale retail facilities are likely to be provided on site in +++ local service and facilities including order to supplement the existing provision in the area, so as to health, education and leisure (shops, meet the day to day need of existing and future residents. CSE post offices, pubs etc) would result in an increase in the local population which would support local shopping provision and either accommodate on- site educational provision or fund sufficient and meaningful improvements elsewhere in the local area.
Inclusive Will it improve relations between people SCDC considers that this is dependent on design and not Communi from different backgrounds or social location. ties groups?
23 Redress inequalities Will it redress inequalities? SCDC considers that this is dependent on design and not related to age, location. disability, gender assignment, race, faith Will it increase the ability of people to SCDC considers that this is dependent on design and not location and income. influence decisions, including 'hard to location. reach' groups?
18. Encourage and Will it encourage engagement in CSE will bring forward a considerable quantum of development. +++ enable the active community activities? There is more likelihood of larger development bringing forward involvement of local community facilities. The exact nature of these is still to be people in community determined. services.
19. Improve the Will it support business development CSE would deliver approximately 9.7ha of commercial +++ efficiency, and enhance competitiveness, enabling development adjoining the Peterhouse Technology Park. This competitiveness, vitality provision of high-quality employment will be focussed on research and development operations and and adaptability of the land in appropriate locations to meet the could include a range of office accommodation to suit the needs local economy. needs of businesses, and the of both large firms and small and start-up high tech businesses. workforce? The site lies in close proximity to ARM Holdings plc, headquarters which leads the market in mobile phone chips. To maintain its status ARM needs to continue to develop at the forefront of this fast changing industry. Addenbrooke's vision is to excel in biomedical science and translational research. There is an opportunity through the development of CSE for these to expand and for synergy between complementary disciplines to cluster and form the basis of a high tech/bioscience hub. For these two, and other organisations to be at the top of the international league tables they need an infrastructure in place which works for them – local facilities and
24 local homes for all types of workers.
Will it promote the industries that thrive SCDC considers that this is dependent on design and not in the district – the key sectors such as location. However, CSE is a mixed use development and it will research and development/high tech/ promote high tech related industries within the commercial Cambridge University related development proposed which will also expand the cluster particularly through the development centred on Peterhouse Technology Park. ARM Holdings, and expansion of clusters? Addenbrooke's and Marshall's are all easily accessible. Local homes for all types of workers and local facilities help these industries thrive. This should be taken into account in the Sustainability Appraisal.
Will it protect the shopping hierarchy, CSE would strongly support local centres. CSE does not seek +++ supporting the vitality and viability of to provide town centre use in any significant proportion, Cambridge, town, district and local although small scale retail facilities are likely to be provided on- centres? site in order to supplement existing provision in the area so as to meet the day to day need of existing and future residents. These would not detract from the vitality and viability of the City Economic centre. The provision of new homes within close proximity to Activity the P&R providing direct access into the City centre will increase visitors to Cambridge improving its vitality and viability.
20. Help people gain Will it contribute to providing a range of The site lies in close proximity to ARM Holdings plc, +++ access to satisfying employment opportunities, in accessible headquarters which leads the market in mobile phone chips. It work appropriate to locations? is also close to other major employers including Addenbrooke's their skills, potential and Marshall's. These and other employment opportunities will and place of residence. be very accessible from the site.
25 21. Support appropriate Will it improve the level of investment in The site has access to all the major service providers, so that +++ investment in people, key community services and there would be no major infrastructure requirements before places, infrastructure, including communications work could begin. There are no impediments to the delivery of communications and infrastructure and broadband? the site. The site is also an ideal home working location other infrastructure. because there is infrastructure in the area so the site can have a superfast network. It should be noted that around 500 houses are required before this option becomes viable and so developments of fewer than 500 houses are less likely to provide this service.
Will it improve access to education and CSE would provide a sufficiently large development to +++ training, and support provision of skilled either accommodate on-site educational provision or fund employees to the economy? sufficient and meaningful improvements elsewhere in the local area.
22. Reduce the need to Will it enable shorter journeys, improve Whilst SCDC has developed a scoring mechanism to consider +++ travel and promote modal choice and integration of access to and quality of public transport and cycling, there must more sustainable transport modes to encourage or be an allowance for development which is large enough to bring transport choices. facilitate the use of modes such as forward its own enhanced public transport provision. CSE is walking, cycling and public transport? considered to be in a very sustainable location. The nearest services and facilities are located at Cherry Hinton and Addenbrooke's. It is intended to create a very 'walkable' Transport development with the majority of development within 400m of a high frequency bus service. The town centre is about 5km distant on roads which allow for convenient cycling. It should also be noted that more local centres for day to day needs are much closer – at about 1.5 to 2 km for most of the site.
26 23. Secure appropriate Will it provide safe access to the CSE will provide adequate capacity at the points of access; ++ investment and highway network, where there is there are no constraints and minor improvements. development in available capacity? transport infrastructure, and ensure the safety of the transport Will it make the transport network safer There will be a significant improvement to the transport network. +++ network. for all users, both motorised and non- There is a possibility of a link to the Park and Ride, which would motorised? be an effective transport hub to help ensure that movements by public transport are preferable to the use of the car. In this way pressure is taken off the transport infrastructure.
27 5 COMPARISON WITH SUSTAINABILITY MATRIX UNDERTAKEN HERE FOR CSE AND SCDC MATRIX ON BROAD LOCATION 7 Land Waste Air Quality Designated Sites Habitats and species Access to wildlife and spaces Landscape Historic Environment Good Spaces Climate change Mitigation Climate change Adaptation Human Health Crime Public Open Space Housing Inequalities Services andFacilities Involvement Economy Work to Access Infrastructure Sustainable Travel Transport Infastructure ? +++ + +++ +++ 0 0 0 + +++ 0 +++ +++ +++ +++ +++ ++ 1
- / ??? --- / ? ?? +++ ? +++ ? + / ? 2 --- - +++
1 is Sustainability Matrix undertaken with up to date base line information and presented here under item 4
2 is SCDC Sustainability Matrix for Broad Location 7 ISA page 232
28 6 APPRAISAL DISCUSSION OF BROAD LOCATION 7
6.1 The site is deliverable and infrastructure is in place which means that the development of the site could start immediately.
6.2 This option is the only proposal that can bring forward a number of deliverables which are potentially extremely beneficial to local residents.
6.3 The site has the potential capacity for approximately 4,000 dwellings, 1,000 of which would be in South Cambridgeshire. SCDC acknowledges that development strategy options which propose development close to Cambridge have the greatest potential to deliver access to the widest range of facilities and services. Specifically it will increase the delivery of affordable housing by a quantum which is unavailable in any single other option which is in such a sustainable location on the edge of Cambridge.
6.4 In terms of sustainability, the site is the best option in relation to proximity to three major employers – Addenbrooke's, ARM and Marshall's. No other site coming forward is as sustainable in terms of proximity to these major employers. Delivery of housing in this location has the potential to reduce the inward commute from South Cambridgeshire.
6.5 The quantum coming forward on a single site means the development is sufficiently large to support community and service facilities on the site.
6.6 Not only will the site provide affordable houses, but the proposed employment area will bring forward job opportunities.
6.7 The site will provide opportunities for sustainable transport. The proximity of the Park and Ride site will be instrumental in ensuring that there are opportunities for alternative modes of travelling than the car. This, along with the creation of direct cycle routes, not only to the Park and Ride, but also linking through to Addenbrooke's, Marshall's and Capital Park will help ensure that daily vehicle trips and vehicular impacts on local roads will be reduced as much as possible.
6.8 The site has access to all the major service providers, so that there would be no major infrastructure requirements before work could begin. There are no impediments to the delivery of this site. The site is also an ideal home working location because there is infrastructure in the area so the site can have a superfast network. It should be noted that around 500 houses are required before this option becomes viable and so developments of fewer than 500 houses are less likely to provide this service.
6.9 Very careful account has to be taken of the wider landscape and setting of Cambridge. We have undertaken our own assessments of how the land supports the Green Belt function as well as the
29 capacity of the land to accept development without undue detriment. This has closely informed the emerging development proposals so that land which is high value is not developed.
6.10 This is the only site which allows the creation of an area of chalk grassland. It will be created from the reversion of existing arable land. Chalk grassland is on the Biological Action Plan priority list as it is a nationally rare habitat. It is also a local protected habitat. The creation of an area of chalk grassland would be of significant benefit to the local area, complementing and linking the chalk habitat of the SSSI and Local Nature Reserve to the north west and the area of Beech Woods, Wandlebury and the Roman Road beyond to the south east. If the development proposals proceed this site could deliver one of the largest open areas of chalk grassland in the County
6.11 CEG welcomes the involvement of the local authority and the local Wildlife Trust to ensure that this major benefit will be created by the best possible methods.
6.12 In addition, the open space created also allows public access for the first time to enjoy the views towards the City. The development of this site would be the linking access between Wandlebury Country Park and the Beech Wood with Limekiln Close and the Chalk Pits with Cherry Hinton Hall, Cherry Hinton Brook, Coldham's Common including Barnwell East and Barnwell West Local Nature Reserves and through to Coldham's Common to Ditton Meadows. The Fen River Way and Harcamlow Way then link through to Midsummer Common and the City centre.
6.13 The development of the site will create new sensitive edges which take account of the setting of the City.
6.14 Archaeological searches will be undertaken so that proper account will be taken of these as the proposals proceed.
6.15 Not only does the proposed development bring significant biodiversity and accessible green infrastructure gains as shown, it provides unique opportunities to provide high standards of water efficiency measures. CSE would improve the quality of water courses via the provision of Sustainable Drainage Measures (SuDS) strategy which will adopt a treatment train approach to the improvement of water quality. The change of use of the land from agriculture to primarily residential development will reduce the volume of nitrates and phosphates released to the watercourse network and therefore provide further valuable water quality benefits. The provision of a carefully design SuDS surface water management strategy at CSE will control and reduce water discharged to the Cherry Hinton Brook to a rate below the present day conditions. This will deliver valuable and unique flood risk and drainage betterment to the area. In addition the quality of water leaving the site will be improved.
30 6.16 Altogether CSE is an extremely sustainable location for an urban extension as shown in the detailed matrix undertaken here.
31 7 COMPARISON OF SUSTAINABILITY MATRIX UNDERTAKEN HERE AND SCDC MATRIX ON THE EFFECTS OF NO GREEN BELT RELEASE
7.1 In effect, no Green Belt release would mean that new housing would have to be delivered away from Cambridge, where the need is greatest, to new settlements. This would not address the problem of journeys to work caused by the imbalance of jobs and homes.
7.2 A comparison is made between CSE and the option of no Green Belt release, which is effectively new settlement development.
7.3 It should be noted that the effect on Land will be similar for all edge of Cambridge and green field sites. Therefore the effect is considered neutral. Land Waste Air Quality Designated Sites Habitats and species Access to wildlife and spaces Landscape Historic Environment Good Spaces Climate change Mitigation Climate change Adaptation Human Health Crime Public Open Space Housing Inequalities Services andFacilities Involvement Economy Work to Access Infrastructure Sustainable Travel Transport Infrastructure +++ + +++ +++ 0 0 0 + +++ 0 +++ +++ +++ +++ +++ ++ 1
2 ??? -/? --- / --- / - /? ?
1 is Sustainability Matrix undertaken with up to date base line. 2 is SCDC Sustainability Matrix for No Green Belt release
32 8 DISCUSSION ON EFFECTS OF NO GREEN BELT RELEASE
8.1 It is clear that development on the edge of Cambridge is the most sustainable option.
8.2 The matrix at Item 6 compares the sustainability appraisal undertaken with an up to date base line informed by the emerging masterplan proposals for CSE with the Council's own assessment of the Issue which allows no Green Belt release.
8.3 Not allowing Green Belt release and development on the edge of Cambridge will force development to the proposed new settlements. The latter is not a sustainable option as the Council themselves state that the edge of Cambridge is the most sustainable location in South Cambridgeshire and has the best access to services, facilities and shops.
Appraisal of Site Options
8.4 The Council uses the Sustainability Objectives to assist in making impacts quantifiable, measurable and transparent and for direct comparison of sites to be made. Table 10, of which we have already expressed our concern that the Decision Making Criteria are skewed, is used to indicate how the impact of individual sites will be established on the objective.
8.5 Whilst an appraisal is given in the main body of the ISA of the Broad locations, a sustainability appraisal of almost 300 sites is included in Annex 1 of the Sustainability Appraisal.
8.6 The Strategic Housing Land Availability Assessment and Sustainability Appraisal (SHLAA) and Sustainability Appraisal of potential sites identify key constraints and considerations relating to potential development sites including suitability, availability and achievability. The Council states that 'in order to draw information together in an accessible form, and reach an overall conclus ion on the merits of t he sites assessed, key elements from bot h assessments have been com bined in a ser ies of settlement summaries which enable t he mos t and least sustainable sit es in eac h settlement to be identified. This has been collated in Annex 2' of the ISA.
8.7 The Council notes that the 'least sustainable sites, identified as hav ing no signif icant development potential due t o constraints or adverse impacts, have been r ejected at this stage, as they are not considered reasonable options'.
8.8 Annex 2 indicates that Site 242 Land NW of B1050, Station Road, Longstanton (Northstowe Reserve) and Site 273 Southwell Farm, Station Road, Longstanton (part of Northstowe Reserve) are the most 'sustainable' tested with a 'green light'.
8.9 Site 057 Bourn Airfield and Site 238 Bourn Airfield both have an 'amber light'. Site 231 Land north of A428 Cambourne also has an 'amber light'.
33 8.10 All the other sites are shown to be unsustainable.
8.11 While the reference to the SA criteria in the Annex II table is not clear, the commentary in the left hand column refers to the specific criteria in which Northstowe scores highly. These are: Accessibility to key local services and facilities, Accessibility to the range of employment opportunities, and Accessibility by sustainable transport modes such as walking, cycling and public transport.
8.12 It is clear that all these criteria that have scored well are, in comparison to the locations on the edge of Cambridge, not as sustainable. All the services and facilities that a new settlement will rely upon are unlikely to be available from the outset. There is a cost burden of setting up new facilities and a substantial investment is required not available until later phases of development.
8.13 Northstowe was appraised as the most sustainable of all the new settlements.
8.14 It is important to be able to compare directly how options support the Sustainability Objectives. Unfortunately it is not directly compared in the ISA. Therefore, a comparison is made of the sustainability appraisal undertaken on CSE with the Northstowe site 242 appraisal.
34 Comparison of CSE with Northstowe Land Waste Air Quality Designated Sites Habitats and species Access to wildlife and spaces Landscape Historic Environment Good Spaces Climate change Mitigation Climate change Adaptation Human Health Crime Public Open Space Housing Inequalities Services andFacilities Involvement Economy Work to Access Infrastructure Sustainable Travel Transport Infrastructure +++ + +++ +++ 0 0 0 + +++ 0 +++ +++ +++ +++ +++ ++ 1
2 0 0 0 0 + -/--- 0 0 0 0 + 0 + + + +/- +/+++ +++/- --
1 is Sustainability Matrix undertaken with up to date base line. 2 is SCDC Sustainability Matrix for site 242 Northstowe
Please note that the symbols and 0 have been used interchangeably throughout the Sustainability Appraisal documents and mean the same thing – Policy has no impact or effect.
35 8.15 Even with the concerns about the Decision Making Criteria we have described, using the Council's Decision Making Criteria, it is clear that CSE is much more sustainable location for development than the most sustainable new settlement.
36 9 CONCLUSION
9.1 South Cambridgeshire District Council sets out the current 'sustainability' baseline which covers the relevant aspects of the current state of the environment and the environmental characteristics of areas likely to be significantly affected by the Plan in the Sustainability Appraisal Scoping Report published in June 2012. It also sets out the Sustainability Objectives and the Decision Making Criteria.
9.2 We consider the Appraisal to be transparent. However we consider some of the Decision Making Criteria do not allow full consideration of the issues. For example, the Climate Change Sustainability Objective Decision Making Criterion does not take the energy saved through not burning fossil fuels by providing development in a sustainable location close to services and employment into consideration. Nor does the Decision Making Criterion for air pollution allow for the effect of minimising potential car journeys.
9.3 The approach is flawed in so much that the most sustainable development options are not being differentiated from less sustainable options.
9.4 The Assessment Matrix for the Appraisal of Site Options is flawed, as this does not allow full consideration of all the issues. For example, we consider the weighting proposed to assess the Sustainability Objective of reducing the need to travel through the Decision Making Criterion does not reflect how sustainable an edge of Cambridge site is because it does not allow for walking, for short cycle journeys and the sustainability comparison with longer cycle journeys is skewed in favour of longer journeys making them look more sustainable than they really are. Nor do these criteria allow for a development of considerable size bringing forward its own internal public transport system.
9.5 In order for the Plan to be sound, the evidence base must be sufficient, in enough detail, consistent and fairly weighted to allow a robust SA which properly determines the likely effects of the Plan.
9.6 CEG recognises that the ISA is initial and iterative but finds that the sustainability appraisal undertaken in the ISA does not fully explore the actual sustainability of an edge of Cambridge site and the additional benefits which CSE brings. CEG has fed into this process by providing a more detailed level of evidence to properly assess CSE in terms of sustainability and how the site will support the Objectives of the Local Plan, guiding development in South Cambridgeshire in a sustainable way, balancing social, economic and environmental issues.
9.7 We have also looked at the Sustainability Objectives relevant to the new settlements in Annex 2. The most sustainable new settlement is considered to be Northstowe. We have compared the sustainability of CSE and Northstowe. Even with our concerns about some of the details of the
37 Appraisal it is obvious that CSE delivers a sustainable location development which can not be overlooked.
9.8 In the round, Cambridge South East can deliver unique benefits. The site is deliverable and there is no detriment to prompt development. CEG hopes to work closely with the local authority and other stakeholders to ensure that this site delivers on its significant sustainability credentials which will allow South Cambridgeshire to grow in a most sustainable way.
38 Response to South Cambridgeshire Local Plan Issues and Options on the exceptional need to release land on the edge of Cambridge which is currently Green Belt Appendix C
Commercial Estates Group Cambridge South East September 2012 Commercial Estates Group Cambridge South East September 2012
Table of Contents
Executive Summary ...... 1
The case to release Green Belt land on the edge of Cambridge ...... 1
1 INTRODUCTION...... 2 Background to the Proposals...... 2 Structure of the Report...... 3
2 POLICY BACKGROUND...... 4
3 BACKGROUND TO THE ESTABLISHMENT OF THE GREEN BELT...... 8 Challenges to the Green Belt...... 8
4 PREVIOUS GREEN BELT REVIEWS ...... 10 Cambridge City Council Green Belt Review 2002 ...... 11
5 SUSTAINABILITY AND GREEN BELT RELEASE...... 13
6 THE REQUIREMENT FOR A DETAILED GREEN BELT REVIEW ...... 15
7 BENEFITS OF DEVELOPMENT ON CSE...... 16
8 CONCLUSION...... 19
Figure 1 Cambridge South East Constraints Plan
Figure 2 Green Belt Changes 1965 – 1996
Figure 3 Land released from Green Belt 2006
Figure 4 Spatial Strategy Executive Summary
The case to release Green Belt land on the edge of Cambridge
We support South Cambridgeshire District Council in that there is an exceptional need for a review of the Green Belt given the scale of the on-going housing needs of the district and the need to provide houses close to jobs. Development needs to be directed to the edge of the City so that housing can be delivered where there is need in the most sustainable location.
Urban extensions are widely recognised as a particularly sustainable form of development which allow for the delivery of houses close to employment opportunities and services. Cambridge South East on the edge of Cambridge is the most sustainable location for growth.
Whilst previous Green Belt reviews have been undertaken and were relevant at the time, a contemporary and detailed review must be undertaken now to properly assess the Green Belt and identify land which should be released and developed to address the significant economic and social issues which outweigh the need to preserve Green Belt.
Cambridge South East is being promoted by the Commercial Estates Group. We have shown how this site will bring about many positive impacts on the Council's Sustainability Objectives and benefits associated with key Issues in South Cambridgeshire, not least in bringing forward a significant area of open space which would help create a new green corridor linking the heart of Cambridge to Wandlebury and beyond.
1 1 INTRODUCTION
1.1 This report has been produced by Bidwells on behalf of Commercial Estates Group Ltd (CEG) to support its submissions in response to the South Cambridgeshire Local Plan Issues and Options consultation.
1.2 CEG is currently promoting proposals for a residential led, mixed-use, urban extension to the south of Fulbourn Road and north east of Babraham Road, referred to as Cambridge South East in this document. This equates to Issue 12: broad location 7.
Background to the Proposals
1.3 The Cambridge South East (CSE) site comprises approximately 214 hectares of land on the south eastern fringe of Cambridge, south of Fulbourn Road and north east of Babraham Road.
1.4 To the north lies Cherry Hinton. To the west lies the built up area of Queen Edith's Way and Beaumont Road. To the south west the site is partly bounded by Babraham Road and further east, Wort's Causeway.
1.5 To the south and south east of the site lie the Gog Magog Hills, an area which is centred on Wandlebury at 74m AOD, Little Trees Hill 74m AOD and Wormwood Hill. Gog Magog forms part of the East Anglian Heights, a gently rolling area with a series of hills running away to the east and south east and which themselves are an extension of the chalklands running north from the Chiltern Hills.
1.6 Missleton Hill, rising to 65m AOD, lies in the extreme south east corner of the site encompassing an area further east and south of Wort's Causeway in an area called 'The Loaves'. This area is on the northern edge of the Gog Magog Hills.
1.7 In bringing CSE forward, we recognise the constraints to development. We have undertaken extensive survey and analysis and identified the opportunities and constraints to development as shown in the Constraints Plan Figure 1. We appreciate that not all land released from the Green Belt should be developed. The emerging proposals incorporate very substantial areas of open space designed to protect the setting of Cambridge. It is proposed that the area shown in dark and mid green colour wash in Figure 1 centred on Missleton Hill should be retained as an essentially open area free from development with the creation of an area of chalk grassland which would complement, extend and link the chalk habitats of Wandlebury and Beechwood to the south with Limekiln Close and East Pit to the north west. Newly created open space could, for example, have a secondary designation for its continued future protection.
2 1.8 The draft conceptual proposals for the site currently envisage the development of a new residential led, mixed-use neighbourhood for the city, comprising:
up to 4,000 market, affordable and key worker dwellings;
9.7 hectares of R/D/B1a Employment Development;
a neighbourhood centre;
substantial public Open Space designed to protect the setting of Cambridge;
strategic landscaping; and
Highways and other supporting infrastructure.
1.9 The site straddles South Cambridgeshire District Council (SCDC) and Cambridge City (CCC) boundary with approximately 1,000 houses proposed in SCDC. The majority of the proposed development is to take place within Cambridge City, including approximately 3,000 dwellings and the employment development.
Structure of the Report
The report is structured as follows:
Section 2: Policy background
Section 3: Background to the establishment of the Green Belt
Section 4: Previous Green Belt Reviews
Section 5: Sustainability and Green Belt Release
Section 6: The Requirement for a Green Belt Review
Section 7: Benefits of Development of CSE
Section 8: Conclusion
3 2 POLICY BACKGROUND
2.1 The National Planning Policy Framework (NPPF) sets out the Government's planning policies for England and how these are applied. At the heart of the NPPF is a presumption in favour of sustainable development.
2.2 The NPPF defines sustainable development as five principles as set out in the UK Sustainable Development Strategy: living within the planet's environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.
2.3 NPPF paragraph 150 states that 'Local Pla ns ar e t he key to deliver ing sus tainable d evelopment that reflects the vision and aspiration of local communities'.
2.4 Section 39(2) of the Planning and Compulsory Purchase Act 2004 requires that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development.
2.5 NPPF paragraph 152 states that in plan making 'local planning authorities shou ld seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development and net gains across all three'.
2.6 The NPPF shows how sustainable development should be interpreted. To deliver sustainable development the NPPF outlines thirteen factors of which 'Protecting the Green Belt land' is one. The principles for protecting the Green Belt are outlined in paragraphs 79-92 of the NPPF.
2.7 The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.
The Green Belt serves five purposes:
to check the unrestricted sprawl of large built-up areas;
to prevent neighbouring towns merging into one another;
to assist in safeguarding the countryside from encroachment;
to preserve the setting and special character of historic towns; and
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4 2.8 With the Cambridge Green Belt, the relevant purposes are usually taken to be to preserve the setting and special character of historic towns and to prevent neighbouring villages from merging into the built up area of Cambridge.
2.9 Whilst the NPPF is silent, PPG 2 paragraph 1.7 states that 'although G reen B elts o ften cont ain areas of attractive landscape, the quality of the landscape is not relevant to the inclusion of land within a G reen Belt or t o its cont inued prot ection'. This must still be the case as the Green Belt contains a variety of quality of landscape.
2.10 NPPF paragraph 83 states that for local planning authorities with Green Belts in their area, that, once established, Green Belt boundaries should only be altered in exceptional circumstances through the preparation or review of the Local Plan.
2.11 NPPF paragraph 84 states that when drawing up or reviewing Green Belt boundaries the local planning authorities should take account of the need to promote sustainable patterns of growth.
2.12 The spatial strategy adopted over previous decades up to the turn of the century, outlined in more detail in following sections, resulted in imbalances and unsustainable travel patterns. A review of the Green Belt was regarded as necessary and directed through the Regional Planning Guidance 6 2000. This approach was acknowledged in the 2003 Cambridgeshire and Peterborough Structure Plan directing new development in the following sequence:
i within the built up area of Cambridge;
ii on the edge of Cambridge subject to a review of the Green Belt boundary;
iii a new settlement at Longstanton/Oakington (Northstowe); and
iv market towns, previously established new settlements and rural centres.
2.13 Urban extensions are widely recognised as a particularly sustainable form of development which allow for strategic development needs to be met through the delivery of significant levels of new housing and other complementary uses, whilst maximising the benefits associated with proximity and accessibility to existing employment opportunities, services and facilities. Such extensions go to the heart of the NPPF.
2.14 Significantly there is a major out-migration of workers from South Cambridgeshire to Cambridge because of the imbalance between jobs and housing. The combination of large flows of employees to the City and the reliance on the car for such journeys results in considerable traffic congestion problems, noise, pollution and accidents, particularly at peak times. These problems are not only short term. In the longer term, such an imbalance with a continued need to make such journeys, will result in burning more fossil fuel which adds to the long term problems of climate
5 change and other social, environmental and economic issues. As a consequence this pattern is not sustainable.
2.15 This is the exceptional circumstance for the alteration of the Green Belt - development should be provided in the most sustainable location which is the edge of Cambridge. This will reduce the need to travel now and in the future, and not only provide economic and social benefits but environmental benefits also.
2.16 Given the scale of the on-going housing needs of South Cambridgeshire District Council., identified in Appendix A Housing which supports this representation, we consider that there is a need for a further in-depth review of the Cambridge Green Belt in order to identify and release further sites on the edge of the City so that housing can be delivered in South Cambridgeshire in the most sustainable way.
2.17 Fundamental reviews of the Cambridge Green Belt were undertaken by both SCDC and CCC in 2002 to help identify sites which could be released from the Green Belt without undermining the core principles as set out in planning policy.
2.18 The areas of land released from the Green Belt to come forward to provide sustainable urban extensions with housing delivery on the edge of the City were identified in the CCC Proposals Plan 2006 as well as Area Action Plans including the Cambridge East Area Action Plan 2008.
2.19 Currently SCDC is consulting upon its Issues and Options Report and considers that Cambridge and South Cambridgeshire have strong links and that their aim has been 'to pr ovide m any new homes c lose t o the jo bs in and around Cambridge as poss ible'. SCDC states that 'the new development strategy f or S outh Cambr idgeshire needs t o rec ognize t he l inks with Cambr idge, particularly in terms of providing employment to support the successful economy of Cambridge and South Cambridges hire, and housing to provi de op portunities f or t he w orkforce, bot h exist ing a nd new, to live close to where they work'.
2.20 Issue 11 in the Issues and Options Report allows for a Green Belt Review. The exceptional circumstance for such a review is justified by the need to provide housing close to jobs so that development can be achieved in the most sustainable way.
2.21 In policy terms, land can not only be released from the Green Belt, but added to it. Redefinition of the Green Belt should only be approved under exceptional circumstances through the preparation or review of the Local Plan (NPPF paragraph 83). The Government is signalling its desire to get the economy back on track helped by sustainable development, with George Osborne over the weekend of 2 September 2012, championing a series of changes to the planning system and
6 raising the prospect that developers could build on Green Belt land, provided other areas of land were designated for protection.
2.22 We respectfully suggest that this option should be considered by the Council. Cambridge East, previously released from the Green Belt, will not now come forward for development. This will significantly reduce the supply of housing on the edge of Cambridge by 8,000 to 10,000. Cambridge East lies close to CSE and the re-establishment of the Green Belt on Cambridge East would balance the release of land from the Green Belt on CSE.
7 3 BACKGROUND TO THE ESTABLISHMENT OF THE GREEN BELT
3.1 The Cambridge Green Belt had its roots in the 1930s, began to be firmed up in the 1950s and was formally defined on the Town Map in 1965. The intervening sixty years have seen huge change which now warrants a substantial and thorough review.
3.2 The history of the Green Belt shows a number of modifications over time although one area of uniformity was that when compared with the five purposes of Green Belt policy set out in PPG2 and now in the NPPF, the purpose which is consistently mentioned in all the historic Plans is its role in preserving the setting and special character of historic towns. Safeguarding the countryside from encroachment is emphasised less and assisting in urban regeneration is not considered relevant.
Challenges to the Green Belt
3.3 The future of the Cambridge Green Belt has been challenged throughout this period. The controls over new industry and commerce were relaxed in the 1970s. New businesses were attracted to Cambridge, especially 'high-tech' firms which benefit from a close relationship with the University. The buoyancy of the local economy led to a rapid increase in the population. Attempts were made to release additional areas through representations on the Green Belt Local Plan and through the Cambridge Local Plan. There were a number of changes to the Green Belt boundary between 1965 and 1996 illustrated in Figure 2, including the addition of an area to the south east of Cambridge which included part of Netherhall School, Limekiln Close and East Pit and some 'green fingers' and some land released from Green Belt, particularly on the northern fringe of the City. So, it is clear that the boundary has not been 'absolute' and has been modified at different times to accommodate need.
3.4 However, with Cambridge unable to expand to accommodate increasing business and housing need, newcomers have largely settled in the outlying villages, now effectively detached suburbs. This has generated a large increase in local road traffic. The pressures on Cambridge and its sub- region caused by these trends called for a review of planning policies.
3.5 The concept of restraint surrounding Cambridge was questioned as early as 1966 when the 'Future Shape of Cambridge' was published by the then City Architect and Planning Officer, Gordon Logie. It looked at how the City should develop over the next forty to fifty years, suggesting future tongues of development which would allow the City to grow, while maintaining the essential qualities of the City.
3.6 In the early 1970s Professor J Parry Lewis was commissioned by national and local government to undertake a Study of the Cambridge Sub-Region 1974. This study was concerned with taking the
8 pressures off the historic centre of Cambridge. Parry Lewis concluded that Cambridge 'must grow in order to retain as m uch of its character as it can' and that the only way to conserve the historic centre was to have a major expansion.
3.7 In the late 1990s CCC presented a document entitled 'Cambridge Green Belt. Towards 2016' to support its view that there should be a radical reassessment of the Green Belt. The report set a case for the need for the continued growth of Cambridge as the economy and mobility amongst other factors had changed considerably and that the pressing need was to reduce journey to work flows for the benefit of both employers and employees and to address the issues of affordability of houses and housing need.
3.8 Whilst the economic and social argument for Green Belt release was strong, the Council stated that environmental and landscape factors were important in any future consideration of shaping the Green Belt. CCC recognised that 'Green Belt designation is not in itself any guide t o the quality and value of the landscape' finding that 'not all of the Green Belt is of equivalent value with parts of it playing no important role' of supporting the purpose of the Green Belt 'other than by being part of a blanket presumption aga inst development'. The balance has now turned. The economic and social arguments must now significantly outweigh the need to preserve Green Belt.
9 4 PREVIOUS GREEN BELT REVIEWS
4.1 Widely accepted sustainability principles of allowing development close to the places people work was accepted through the RSS with the review of the Green Belt set out in policy terms by RPG 6 2000, and then through the Cambridgeshire Structure Plan 2003 accepting the need for Green Belt release.
4.2 The process of identifying land to be released from the Green Belt was through local plans. Both SCDC and CCC undertook Green Belt reviews.
Landscape Design Associates 2002 Cambridge Green Belt Study. A Vision of the Future for Cambridge in its Green Belt Setting. South Cambridgeshire District Council
4.3 This study focuses on the fourth purpose of including land in Green Belts set out in NPPF which is 'To pres erve t he set ting and special char acter of historic towns'. A baseline study including topography and geology, environmental designations, cultural and access designations, townscape character, landscape character and visual assessment was undertaken.
4.4 The western part of the CSE site is described as being in the 'Granta Valley' character area, described as having low-lying, gentle topography.
4.5 The eastern part is described as being in the Gog Magog Chalk Hills. This is described as a chalk ridge which forms an area of high ground to the south east of Cambridge. They are a series of rounded hills. We agree that Missleton Hill, lying mostly to the east and south of the site along with the extreme south east of the site, could be described as a rounded hill; the rest of the site could not be described in this way. The study also notes that there are several elevated views to Cambridge and indicate one in the approximate location of the higher land in the south east corner of the site. We concur with this and wish to retain this area as a freely accessible open space which will allow the public access to this viewpoint.
4.6 All character areas have a 'typical' character and an area where one character type merges into another. This applies to the major area of CSE where the character areas are merging. The only area of the site which could be described as 'Gog Magog Hills' is the very south east corner of the site which has been identified to be retained as undeveloped land.
4.7 In the section, 'special qualities to be safeguarded', this study states that 'No development to take place on elevated land. The open elevated setting to the city must be retained. Potential for new access routes linking the City with Wandlebury Country Park and Magog Down.' As has been shown, the entire extent of CSE is not on elevated land. The landscape capacity assessment undertaken by CEG identifies the elevated land and determines to protect it. In addition, the
10 potential benefits of the site should be considered. The development of this site could provide the missing link in the potential access route mentioned in the LCA 2002 report, linking the City with Wandlebury Country Park and Magog Down.
Cambridge City Council Green Belt Review 2002
4.8 CCC undertook a review of the Green Belt in 2002 which guided the release of areas of the Green Belt ratified in CCC Local Plan 2006.
4.9 The site lies in the character area described by the Cambridge Landscape Character Assessment 2003 as Rural Lowland Mosaic: Chalklands. The Character Assessment also notes that parts of this character area are 'Defining Character'. This is ascribed to factors of 'Setting, Views, Environmental Features, High Ground and Important Views'. The emerging masterplan for CSE acknowledges and confirms this position. A landscape capacity assessment was undertaken by CEG and land of high value was identified and recognised as a constraint to development. This coincides with the description of parts of this character area being sacrosanct. No development is proposed on high ground from which there are important views.
4.10 The Inner Green Belt Boundary Study 2002 undertook the assessment on a site-by-site basis assessing the importance to the Green Belt purposes of setting, character and also of separation and described land as 'Very High, High, Medium, Minor and Negligible' according to the way it supported the Green Belt function.
4.11 Point 4.1.6 of that report states 'the worth to the Green Belt function was attributed to the highest value'. In other words, that for every parcel of land, the assessment of importance to the Green Belt function was based on the highest value of any part of that area.
4.12 This is an important distinction because of the rising land on CSE. Each parcel of land was ascribed to the highest value found on that site; so if the corner of the site or any small part of the site was elevated for example, the whole area would be given the highest value irrespective of whether the whole area was worthy of the designation.
4.13 These reviews were undertaken according to the circumstances at that time and have in common the protection of elevated land and views to the City centre. The reviews were undertaken at a broad brush, generic level, and the finer details of site setting and topography were not taken into consideration so that generalisations were made over sweeps of countryside.
4.14 These reviews were relevant at the time and helped inform Green Belt release as shown in Figure 3.
11 4.15 Since these assessments were carried out the base line has changed as land identified then as least supportive of the purpose of the Green Belt has been released but there is continued pressure to identify land for development on the edge of Cambridge.
4.16 A contemporary and detailed review must be undertaken now to properly assess the Green Belt and identify land which should be released and developed to address the significant economic and social issues which outweigh the need to preserve Green Belt.
12 5 SUSTAINABILITY AND GREEN BELT RELEASE
5.1 We have shown how development on the edge of Cambridge is the most sustainable form of growth, located close to services and facilities and helping address the imbalance between jobs, and the number of people who commute every day to those jobs.
5.2 SCDC states in paragraph 1.9 of the Issues and Options Report that the overarching objective in national policy to secure sustainable development has strongly influenced the development of the Issues and Options Report.
5.3 Of the Council's Sustainability Objectives outlined in the Sustainability Appraisal Scoping Report (SR) and the Initial Sustainability Appraisal Report (ISA), development on the edge of Cambridge has the effect of delivering significant positive impacts on the following objectives in particular:
Minimise impacts on climate change (including greenhouse gas emissions) – The Council states that as sustainable transport is addressed elsewhere in the ISA their appraisal of the Objective primarily focuses on impacts of development on energy use. However, we feel that the impact on this Objective is not properly addressed in the ISA. Increasing the need to travel by providing development further away from employment, services and facilities means that an increased level of fossil fuels will be used over and above that which would be needed if development was on the edge of Cambridge. Fossil fuels result in the production of carbon dioxide which intensifies the greenhouse effect causing global warming. We do not feel that this important aspect of climate change is addressed properly in either this Objective or in the sustainable transport section.
Improve the quality, range and accessibility of services and facilities – The Council states that 'focusing developm ent on b etter ser ved locat ions could h ave t he greatest positive impact on achiev ement of this objective'. We show that development on the edge of Cambridge has the most potential to deliver access to the widest range of services and facilities and is the best served location.
Help people gain access to satisfying work appropriate to their skills, potential and place of residence – The Council states that delivering new employment provision near Cambridge could deliver a significant positive impact on this Objective. We conclude that not only the provision of jobs on the edge of Cambridge but also the provision of housing on the edge of Cambridge benefits this objective as this would give people easy, affordable access to the pool of jobs.
Reduce the need to travel and promote more sustainable transport choices - The Council states in the ISA page 28 that 'Delivery of housing could support putting homes near t o
13 jobs and hav e positive im pacts on c ommuting pat terns. Development Strategy opt ions which propose development close to Cambridge or in new settlements have the great est potential to deliver access to the widest range of services and f acilities' and continue that 'Options…could pot entially hav e a si gnificant negative im pact on ach ievement of the overall objective by increasing the need to travel and reducing opportunities for sustainable modes of travel'. We have shown in the Sustainability Report Appendix B which accompanies this submission that the most sustainable travel is by foot, cycle or short journeys on public transport. Edge of Cambridge development is the most supportive growth option for this Objective. Development on the edge of Cambridge clearly has the greatest potential to deliver access to the widest range of services and facilities over and above new settlements.
5.4 The Council considers that (ISA page 72) the focus of development on the edge of Cambridge 'is the most sustainable location in Sout h Cambridgeshire and t he best access to services, facilities and jobs. The loss of Cambridge East has significantly reduced the supply of housing land on the edge of Cambridge for the new Local Plan'.
5.5 The ISA and the Sustainability Report Appendix B, produced as part of this submission, clearly show that development on the edge of Cambridge, and consequently a Green Belt Review, is more sustainable than anywhere else. Page 225 of the ISA compares Issue 11 Green Belt review with Issue 11 No Green Belt review against the Sustainability Objectives. It is clear that not reviewing the Green Belt and not providing development on the edge of Cambridge would be an unsustainable option. The Sustainability Report Appendix B of this submission shows that Cambridge South East is a particularly sustainable option on the edge of Cambridge which delivers many benefits.
5.6 We propose that development should be on the most sustainable location on the edge of Cambridge. The planned quantum of houses that is coming forward is much reduced because of Cambridge East. Cambridge has capacity to accept additional development on its edge.
14 6 THE REQUIREMENT FOR A DETAILED GREEN BELT REVIEW
6.1 Issue 9 of the Issues and Options allows for a Cambridge focus for development. We endorse this approach and believe the 'special circumstances' exist in terms of locating homes close to jobs so that growth of the area is sustainable, improving social and economic circumstances without undue detriment to the setting and special character of Cambridge.
6.2 The 2002 reviews are no longer appropriate for today's circumstances. Judgements need to be made about land which should come forward on the edge of Cambridge. A Green Belt review needs to be undertaken in enough detail to identify a quantum of development on the edge of Cambridge which will meet housing need and improve future economic and social circumstances.
6.3 A full and detailed Green Belt review according to the requirements of the NPPF needs to be undertaken to look at the way Cambridge should be shaped. As part of this review, consideration could be given to the addition of Cambridge East to Green Belt so that there is an overall balance between land to be added to Green Belt and land which could be released to facilitate development.
15 7 BENEFITS OF DEVELOPMENT ON CSE
7.1 Issue 9: Development Strategy and Issue 11: Considering Exceptional Circumstances for a Green Belt Review, allow for an option of providing more development on the edge of Cambridge through a further review of the Green Belt.
7.2 The exceptional circumstances requiring Green Belt release have been set out in this report. In addition, the benefits that development of CSE would bring forward and which would support many of the emerging issues which are seen to be important for South Cambridgeshire are set out here for the consideration of SCDC.
7.3 SCDC points out that there is a strong link between jobs and homes. Seeking an appropriate balance will support the economy, whilst delivering homes where people can access work in a sustainable way.
7.4 The Council says in paragraph 3.4 of the Issues and Options Report that 'to only pr ovide for new jobs would be likely to be found to contribute to be (sic) unsustainable development, perpetuating the imbalanc e bet ween homes and jobs in and close t o Cambr idge and t he congestion and emissions that arise from traffic travelling to t hose jobs. Not supporting jobs could hold back the economy, or lead to higher levels of unemployment.'
7.5 There is already an imbalance between jobs and houses so that there is a significant journey to work flow to Cambridge, not only from South Cambridgeshire but also other neighbouring districts. The 2001 census shows 20,710 trips from South Cambridgeshire to Cambridge of which 14,177 were by car i.e. a mode share of 68.5%. This inflow to Cambridge results in congestion at peak travel periods.
7.6 Not supporting jobs is not a viable option. The most sustainable place to locate new homes is close to where there are jobs.
7.7 CSE is centrally located for three of the largest employers in Cambridge, namely ARM Holdings plc, Addenbrooke's and Marshall's.
7.8 CSE would deliver approximately 9.7 ha of commercial development adjoining the Peterhouse Technology Park and provide the homes for these workers as well as other employers close-by.
7.9 CSE is one of the proposed edge of Cambridge growth areas furthest removed from the A14 and is not, as such, likely to exacerbate the existing situation in this area. In addition, and most importantly, the location of CSE allows opportunities for a connecting transport hub with the P&R and Addenbrooke's and potentially allowing public transport access to major employment hubs to the south of the City.
16 7.10 CEG intends to work closely with the local authorities to bring forward sustainable development of high quality homes with high quality design on its site. However, it is worth noting the following where the development of CSE can bring forward particular benefits on the following issues:
7.11 Issue 12: Green Belt Locations. The allocation and development of CSE would bring forward an additional green corridor into the heart of Cambridge. This is illustrated in Figure 4. Creating an area of open space in the Missleton Hill area links the Gog Magog Hills, including Wandlebury Country Park and the Beech Wood, with Limekiln Close and the Chalk Pits with Cherry Hinton Hall, Cherry Hinton Brook, Coldham's Common including Barnwell East and Barnwell West Local Nature Reserves and through to Coldhams Common to Ditton Meadows. The Fen River Way and Harcamlow Way then link through to Midsummer Common and the City centre. In this way a strategic new green space would be added to Cambridge's Current Spatial Strategy as shown.
7.12 Issue 17: Mitigation and Adaptation to Climate Change. The allocation and development of CSE would support Issue 17 by providing homes near jobs and thereby saving on the energy required for travelling to work. In addition, development proposals can evolve to demonstrate energy efficiency, the promotion of sustainable forms of transport and reduction of car use, recycling and waste reduction and inclusion of broadband.
7.13 Issue 26: Sustainable Drainage Systems/Managing Flooding and Issue 27: Flood Risk. The provision of carefully designed SuDS surface water management strategy at CSE will control and reduce water discharged to the Cherry Hinton Brook to a rate below the present day conditions. Cherry Hinton is identified as a 'wetspot' and therefore considered to be susceptible to flooding. The control of water discharged to Cherry Hinton Brook to a rate below the present day conditions will deliver valuable and unique flood risk and drainage betterment to the area.
7.14 Issue 30: Landscape Character. The emerging plans for CSE ensure the proposals reflect and enhance the character and distinctiveness of the area, through the retention of a large tract of elevated, open land for public use and the creation of an area of chalk grassland.
7.15 Issue 32: The emerging proposals include the creation of a large area of chalk grassland habitat. This could be one of the largest open areas of chalk grassland in the County.
7.16 Issue 33: Green Infrastructure. The development of CSE would provide specific opportunities to link in and augment the Gog Magog Countryside Project. This is a project identified by the Green Infrastructure Strategy for the creation of species-rich, chalk grassland south of Cambridge through working with local authorities and voluntary bodies. The addition of East Pit LNR added to the Cherry Hinton Chalk Pits nature reserve in 2009 is noted and the proposed green space coming forward in the CSE proposal would be contiguous with East Pit.
17 7.17 Issue 59: New Employment Provision near Cambridge. CSE has the potential to deliver 9.7 ha of employment.
7.18 Issue 97: Planning for Sustainable Development. This development can provide opportunities to encourage sustainable development especially if there are opportunities for linking transport with a transport hub based on the Park and Ride scheme and Addenbrooke's.
7.19 In this way, development of broad location 7 particularly supports many of the issues emerging in the Local Plan.
18 8 CONCLUSION
8.1 Planning development which is not sustainable or is less sustainable than other options is not viable.
8.2 We agree with SCDC that a Green Belt review is needed. We strongly contend that a transparent, robust, comprehensive and in-depth review of the Green Belt needs to be undertaken at a level detailed enough to properly identify land which could be released from the Green Belt, balancing the need for a sustainable future for Cambridge with the protection of the setting and special character of the historic core in compliance with the requirements of the NPPF. We urge the Council to consider balancing Green Belt in the south east of Cambridge by redefining Cambridge East as Green Belt and releasing CSE, the most sustainable growth location.
8.3 We have identified land which is important to the purpose of the setting of the City and propose to conserve this, open it up to public access and recreate chalk habitat within it. This could be the largest area of open chalk grassland in Cambridgeshire. We see the benefits of bringing forward the site due to the massive environmental benefits associated with it.
8.4 We have shown that the future development of CSE helps with many of the Council's long term Sustainability Objectives and Issues identified in the Issues and Options Report.
19
Cambridge Inner Green Belt - Land released from Green Belt 2006 ® Figure 3
Legend Green Belt Land released from Green Belt 2006
O.S. Licence No: ES 100017734 This plan is based on Ordnance Survey data with sanction of the controller of HM Stationery Office. Crown Copyright Reserved.
Note: This plan is published for convenience only and although believed to be correct its accuracy is not guaranteed and it shall not be deemed to form part of the contract.
Trumpington Road, Cambridge CB2 9LD t: 01223 841841 f: 01223 845150 bidwells.co.uk
Scale: 1:18,000 O.S. Ref: TL 45 Drawing No: D.2239 Date: 23/7/2012
CAMBRIDGE SOUTH EAST
South Cambridgeshire District Council
LOCAL PLAN REPRESENTATIONS
TRANSPORT
V4
Report prepared by
G Corrance Report checked by
A Redhead
Bryan G Hall Consulting Civil & Transportation Planning Engineers Suite 11 Lighterman House 26-36 Wharfdale Road London N1 9RY
0203 077 2162 www.bryanghall.co.uk
September 2012 Ref: 12-167-003.04
CONTENTS
Executive Summary
1.0 INTRODUCTION ...... 1
2.0 ‘PROMOTING SUSTAINABLE TRANSPORT’ – TRANSPORT POLICY ...... 5
3.0 CAMBRIDGE SOUTH EAST ...... 12
4.0 DEVELOPING A SUSTAINABLE TRAVEL STRATEGY ...... 18
5.0 LOCAL AND STRATEGIC HIGHWAYS ...... 31
6.0 OPTIONS FOR NEW SETTLEMENTS ...... 36
7.0 CONCLUSIONS ...... 41
Figures
Figure 1 Location Plan Figure 2 Local Highway Network Figure 3 Strategic Road Network Figure 4 Key Travel Destinations Figure 5 2.0 Kilometre Walking Distance from Cambridge South East Figure 6 2.0 Kilometre Walking Distance from Local Employment Areas Figure 7 5.0 Kilometre Cycle Distance from Cambridge South East Figure 8 Existing Cycling Facilities Figure 9 Existing Bus Services Figure 10 Proposed Bus Service – Initial Development Phases Figure 11 Proposed Bus Services – Complete Development Figure 12 Location Plan: options for new settlements
Appendices
Appendix 1 Existing Travel Behaviour: Cherry Hinton and Queen Edith’s wards Appendix 2 Notes of a meeting with Cambridgeshire County Council’s public transport officer
Executive Summary
1 South Cambridgeshire residents rely on their cars to travel to work significantly more than the national average. Cambridge is the principal employment destination for South Cambridgeshire residents; nearly 40% of travel to work trips by car from South Cambridgeshire are to Cambridge (including the Science Park).
2 The imbalance between housing and employment is the primary cause of this high level of commuting. This has led to congestion on the radial routes into Cambridge, particularly during peak travel periods. This commuting also contributes to congestion on the A14.
3 South Cambridgeshire District Council’s (SCDC) spatial policy is to locate development first of all in Cambridge, then the Cambridge urban extensions, followed in turn by Northstowe, the market towns and villages. There are strong sustainable transport related reasons for continuing to pursue this spatial policy, rather than locate development outside of the city. These reasons include;
Urban extensions present more opportunity to encourage travel by walking, cycling and public transport; Locating development within an urban extension would reduce travel distances, particularly by car; and Reduced car traffic will cause less congestion.
4 Cambridge South East would incorporate a mix of land uses which would minimise the need to travel. It would comprise approximately 4,000 dwellings, 9.7 hectares of employment and a range of local facilities.
5 Cambridge South East would be conveniently located in relation to a number of local employment, leisure, education and transport destinations. The majority of these locations would be sited within walking distance from the development area.
6 A large part of the city of Cambridge, including the majority of its employment areas, would be located within cycling distance from the development area.
7 Cambridge South East would be sited close to two existing transport hubs: these are the Babraham Road Park and Ride and the Addenbrooke’s Hospital bus station. These hubs are served by a number of frequent bus services which, when taken together, would provide a high level of public transport accessibility for Cambridge South East.
8 Cambridge South East is predicted to have a baseline travel to work mode share of 45% by car. This figure compares very favourably with the countywide average of 65%. The baseline figure would be improved by the implementation of the sustainable travel strategy outlined below.
9 A sustainable travel strategy has been developed for Cambridge South East. This strategy comprises;
i) Providing a mix of development land-uses which would reduce the need to travel outside of the development area, ii) Providing walking and cycling facilities that would connect to existing facilities and which would provide access to local destinations, iii) Providing new bus services which would be implemented from the first stages of development: these would complement the high level of service already provided by current bus services, iv) Managing travel demand through the implementation of Travel Plans, v) Banking trips through area wide travel planning, vi) Providing cycle parking throughout the development area (including cycle storage arrangements for dwellings), vii) Implementing a car parking strategy within the development area, viii) Providing charging facilities for electric vehicles, ix) Providing a car club to encourage reduced levels of car ownership, and x) Providing teleworking facilities to encourage working from home.
10 The options for new settlements at Northstowe, Waterbeach and Bourn Airfield have been considered. All three locations are considered to be more car reliant and less sustainable than the Cambridge South East urban extension. Both Waterbeach and Northstowe depend on the improvement of the A14 before significant levels of development can be provided at these sites.
11 The location of Cambridge South East means that it is unlikely to have a significant impact on the A14. It does not rely on the improvement of the A14 in order to be able to come forward for development.
12 Cambridge South East is an excellent location for a new urban extension. It enjoys a location that is genuinely accessible, particularly as it located within a convenient travel distance of Addenbrooke’s Hospital, Peterhouse Technology Park and Capital Park employment areas. Its location enables it to benefit from existing transport facilities: these facilities would be enhanced by the travel measures (outlined above) that would be introduced as part of the sustainable travel strategy for Cambridge South East.
Cambridge South East Local Plan Representations – Transport
1.0 INTRODUCTION
Local Development Framework
1.1 South Cambridgeshire District Council’s (SCDC) current Local Development Framework (2007) sets out the policies to be applied to development in South Cambridgeshire up to 2016 and beyond.
1.2 SCDC’s development strategy for the Cambridge area aims to encourage the provision of new jobs, principally in high-technology and research sectors. A significant proportion of such employment would be situated in business parks including Cambridge Science Park, Genome Campus (Hinxton Hall) and Granta Park.
1.3 The Council’s development strategy also includes the provision of 20,000 dwellings to be provided during the period 1999 to 2016.
1.4 SCDC’s aim has been to provide as many new homes as possible close to jobs in and around Cambridge, in order to provide a better balance between jobs and homes. This is intended to reduce commuting and congestion and provide a more sustainable pattern of development.
1.5 In order to achieve the aims outlined above, the LDF proposes a development sequence that focuses first of all on Cambridge, then the Cambridge urban extensions, followed by; Northstowe, the market towns and finally villages.
1.6 From a transport point of view, the rationale behind this approach is to:
i) redress the imbalance between housing and employment in Cambridge,
ii) reduce the level of commuting undertaken by employees who work in Cambridge but live in towns and villages outside of the city, thereby
iii) keeping to a minimum the increase in the number of cars entering Cambridge and adding to congestion, particularly on radial routes into the city.
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Development Plan Review
1.7 The LDF is to be replaced by a new Local Plan. SCDC intend to adopt the new Local Plan in October 2015 and it will run until 2031.
1.8 As part of its Local Plan preparation process, SCDC will be considering future levels of housing provision and the locations of development sites within its district. SCDC’s “Issues and Options Report” includes ten broad locations for possible future residential development on the edge of Cambridge.
1.9 Bryan G Hall Limited (BGH) have been commissioned by CEG to report on the transport issues associated with Broad Location 7, as identified in the Issues and Options Report. This location is hereafter referred to as Cambridge South East.
Transport Report
1.10 This transport report reviews existing travel behaviour between South Cambridgeshire and Cambridge. It also develops a travel strategy for Cambridge South East which would encourage journeys to and from the site (and within the site itself) to be undertaken on foot, by bicycle and by public transport.
Transport Strategy
1.11 The transport strategy for Cambridge South East comprises of four key components;
i) minimising the need to travel by providing a good mix of land uses,
ii) maximising opportunities for non-car travel, particularly through the delivery of public transport services which would provide strong connectivity with the rest of Cambridge,
iii) ‘managing down’ the number of trips made by private car, and
iv) improving the highway network, both in terms of providing improved facilities for pedestrians, cyclists and bus passengers but also providing increased highway capacity where it is appropriate to do so.
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1.12 The approach outlined above is consistent with the requirements of current transport policy (transport policy is described in Section 2). It is also an approach that has been accepted by the local authorities for urban extension sites proposed elsewhere in Cambridge.
Transport Strategy for Cambridge and South Cambridgeshire
1.13 Cambridgeshire County Council is presently consulting on its proposed Transport Strategy for Cambridge and South Cambridgeshire. The County’s consultation process is proceeding in tandem with the SCDC’s Local Plan consultation process.
1.14 Bryan G Hall will liaise with the County Council to provide input to the County’s emerging transport strategy and ensure that the strategies for Cambridge South East and the strategy for Cambridge and South Cambridgeshire are compatible with one another.
Issues and Options
1.15 Chapter 12 in SCDC’s “Issues and Options Report” outlines a number of issues relating to the delivery of sustainable transport and infrastructure for Cambridge. The issues which relate to Cambridge South East are;
Issue 97: Planning for Sustainable Travel
Issue 98: Transport Assessments and Travel Plans
Issue 99: How car parking is provided within Residential Developments
Issue 100: Allocation of car parking within Residential Developments
Issue 101: Residential garage sizes
Issue 102: Car parking standards for other types of developments
Issue 103: Cycle parking standards
These issues are referenced in Section 4 of this report.
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Structure
1.16 This report is structured as follows. The requirements of current national, regional and local transport policy are reviewed in Section 2. The merits of Cambridge South East are described in Section 3. Proposals for a sustainable travel strategy for Cambridge South East are described in Section 4. Highways matters are discussed at Section 5. SCDC’s options for new settlements are discussed at Section 6. Conclusions are drawn at Section 7.
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Cambridge South East Local Plan Representations – Transport
2.0 ‘PROMOTING SUSTAINABLE TRANSPORT’ – TRANSPORT POLICY
National Planning Policy Framework (2012)
2.1 The National Planning Policy Framework (NPPF), introduced in March 2012, provides high level national policy guidance, including transport. The principal transport related requirements of NPPF are briefly described below.
2.2 NPPF states (paragraph 29) that:
“The transport system needs to be balanced in favour of sustainable tra nsport modes, giving people a real choice about how they travel.”
2.3 It continues (at paragraph 30):
“In preparing local plan s, local plan ning authorities should t herefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport.”
2.4 A sustainable travel strategy has been developed for Cambridge South East and this is described in the following sections of this report. The strategy is intended to ensure that the development area would be genuinely accessible by sustainable forms of travel. In particular, the strategy would provide residents living at Cambridge South East, and employees working at Cambridge South East, with a variety of choices regarding which travel mode they choose to make their journeys.
2.5 NPPF encourages that (paragraph 31):
“Local auth orities shou ld work wit h neighbouring authorities and transport providers t o develop strategies f or the provision of viable infrast ructure necessary to support sustainable development…”
2.6 It is noted that SCDC, in conjunction with the City Council, is presently preparing its Infrastructure Delivery Study, which will identify the significant items of infrastructure required to support the implementation of the Local Plan. It is also noted that the County Council is at an early stage of developing its own Transport Strategy for Cambridge and South Cambridgeshire.
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2.7 Our discussions with transport officers at the County Council indicate that the County Council will be working with the local authorities to identify the infrastructure required to facilitate future development in Cambridge and South Cambridgeshire.
2.8 It is noted that NPPF stipulates at paragraph 32 that:
“Development should o nly be prevented or refused on tr ansport gro unds where the residual cumulative impacts of development are severe.”
2.9 At paragraph 34, NPPF recommends that:
“Plans and decision s should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised”.
2.10 With respect to Cambridge South East, the development mix proposed is intended to maximise the number of internal trips within the development area and keep to a minimum the number of trips released onto the external transport network. Locating development on the edge of Cambridge, rather than at a location outside of the city, not only reduces trip distances, but it also enables people to choose non-car modes of travel as a realistic alternative to the motor car.
2.11 At paragraph 35, NPPF states that:
“Plans shou ld protect a nd exploit opportunities for the u se of susta inable transport modes for the movement of goods or people. Th erefore, developments should be located and designed where practical to;
accommodate the efficient delivery of goods and supplies, give priority to pedestrian and cycle movements and have access to hig h quality public transport facilities, create safe and secure layouts which m inimise conflicts between traffic and cyclist s and pedestrians, a void street clutter and whe re appropria te establishing home zones, incorporate facilitie s for charging plug-in and other ultra-low e mission vehicles, and consider the needs of people with disabilities by all modes of transport”.
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2.12 All of the items listed above have been incorporated into the sustainable travel strategy and masterplan layout for Cambridge South East.
2.13 NPPF requires that:
“All developments which generate significant a mounts of movement should be required to provide a Travel Plan” (Paragraph 36).”
2.14 Travel planning is a key component of the sustainable travel strategy for Cambridge South East. It is intended that a Framework Travel Plan would be produced for the development area. This would form the guidelines for detailed, site specific Travel Plans (which would be produced at later stages of the development process). Furthermore, it is intended that an Area Wide Travel Plan (AWTP) would be developed for Cambridge South East. The AWTP would incorporate measures to persuade residents and employees of existing residential and employment areas to change their mode of travel away from the use of the car. These trips would be “banked” by Cambridge South East and used to off-set the traffic impact of the development area.
2.15 NPPF Paragraph 38 states that:
“For larger scale residential developm ents i n particular , planning policie s should promote a mix of uses in order to pro vide opportunities to undertake day-to-day activities, in cluding wor k, on site. Where practical, part icularly within large-scale devel opments, key facilit ies such as pri mary schools and local shops should be located within walking distance of most properties”.
2.16 As mentioned above, the development mix for Cambridge South East has been designed to retain day-to-day activities on site, thereby reducing the number of trips released onto the external transport system. The masterplan layout for the development area would ensure that facilities would be situated within reasonable walking distance of most dwellings.
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East of England Plan (2008)
2.17 Although the Regional Spatial Strategy for the East of England (East of England Plan) will be withdrawn, it nevertheless remains extant at the time of preparing this report. The East of England Plan includes a regional transport strategy (outlined in Section 7 of the Plan) which provides a regional framework for the delivery of transport investment and policy priorities to support the aims of the spatial strategy.
2.18 Policy T1 “Regional Transport Strategy Objectives and Outcomes” highlights that the successful achievement of the regional transport strategy will achieve a number of outcomes, including;
Increased proportion of the region’s movements by public transport, walking and cycling, Sustainable access to areas of new development and regeneration, Safe, efficient and sustainable movement between homes and workplaces, education, town centres, health provision and other key destinations, and Economic growth without a concomitant growth in travel.
2.19 All of the objectives outlined above are satisfied by the sustainable transport strategy devised for Cambridge South East.
2.20 Policy T2 “Changing Travel Behaviour” encourages local authorities and transport providers to introduce a number of measures, including;
Encourage the wider implementation of workplace, school and personal travel plans, Introduce educational programmes for sustainable travel, and Raise awareness of the health benefits of travel by non-motorised modes.
2.21 It is intended that these points would be incorporated into a travel planning programme as part of the sustainable travel strategy for Cambridge South East.
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2.22 Policy T4 “Urban Transport” states that,
“Within urba n areas, including key centres for d evelopment and change and appropriate market t owns, Local Transport Plans, Local Developm ent Documents and other plans or strat egies should identify ways to bring about a shift away from car use to public transport, walking and cycling. This should be achieved t hrough the following types of measures, in com bination as appropriate to local circumstances;
Ensuring ur ban extensions and oth er major developm ents are linked from the ou tset into th e existing u rban structu re through safe, well designed pedestrian and cycling routes and a high standard of public transport; Capitalising on opportunities provide d by new d evelopment to achieve area wide improve ments in public transport se rvices, fo otpaths and cycle networks; Promoting public tra nsport throu gh qualit y partnerships or other agreements to deliver enhanced services, improved i nterchange, increased access, hig her level s of publi c visibilit y, better trave l information, and appropriate traffic management measures; and Improvements to local networks fo r walking and cycling, includ ing increasing the attractiveness and safety of the public realm”.
2.23 The proposals for Cambridge South East would fully satisfy the requirements of Policy T4.
2.24 Paragraph 7.9 of the Plan recognises that urban areas have the greatest scope for efficient public transport and more use of walking and cycling. It also states that new peripheral development should be focused on sustainable links with the rest of the urban area and not simply connections to the local road network.
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2.25 Policy T4 is complemented by both Policy T9 “Walking, Cycling and other Non- Motorised Transport” and T13 “Public Transport Accessibility”. T9 states that pedestrian, cycle and non-motorised transport networks should be managed and improved to enhance access to work, schools and town centres and provide access to the countryside, urban green-space and recreational opportunities. T13 states that public transport use should be encouraged by increasing public transport accessibility to appropriate levels of service for as high a proportion of households as possible, enabling them to access core services including education, employment, health and retail. Again, it is considered that the pedestrian, cycling and public transport facilities that would be provided for Cambridge South East fully satisfy the aims of policies T9 and T13.
SCDC’s Development Control Policies DPD (2007)
2.26 SCDC’s current transport policy is described within its Development Control Policies DPD. Although the DPD is clearly being subject to review, its travel objectives nevertheless continue to be relevant.
2.27 SCDC’s development related travel objectives are set out in Section 9 of the DPD. These objectives include;
TR/b: To reduce the need to travel, and where travel is unavoid able, to increase the use of sustainable modes.
TR/c: To promote the use of more sustainable modes of travel such a s public transport, co mmunity transport, walking and cycling by m aking such modes more integrated, highly accessible safer and more attractive to use.
TR/d: To promote sustainable travel by ensuring new development takes place in location s with, or with potential for, good accessibility by non-m otorised modes to facilities and services and ensuring provision for all transport modes.
TR/g: To improve the safety of tra vel for all pe ople and a ll modes, including measures to reduce the number and severity of road accidents.
TR/h: To improve personal safet y and acce ssibility for all m odes and all people, including those with disabilities.
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TR/i: To reduce the en vironmental im pact of t ravel, to co nserve ener gy and reduce air pollution by limiting the growth in road traffic.
TR/j: To pr ovide tran sport proposals that pro tect or enh ance the b uilt and natural environment.
2.28 All of the objectives outlined above would be satisfied by the Cambridge South East scheme proposals.
Overview of Section 2
2.29 National, regional and local transport policy seeks to encourage walking, cycling and public transport as the preferred modes of transport, rather than use of the motor car. This sustainable transport policy has been implemented in Cambridge to date by locating new residential development within urban extensions on the fringe of Cambridge, rather than locate development further afield. Locating development on the Cambridge fringe not only reduces trip distances, but it also enables people to choose non-car modes of travel as a realistic alternative to the motor car.
2.30 Should new development be located away from Cambridge, particularly in new settlements, then it is inevitable that trip distances would increase - particularly for people commuting into the city - and that a higher proportion of those trips would be by car.
2.31 Cambridge South East would be situated on the fringe of Cambridge. It would be provided with pedestrian and cycling facilities which would connect with those already in existence in the surrounding area. Public transport services would be provided from an early stage of development and these will augment the large number of frequent services which are already operating in the south east part of the city. Residents at Cambridge South East would have the opportunity to travel by sustainable modes of transport. Trip distances to and from Cambridge South East would invariably be shorter than trips generated by development located outside of the city. Given the points described above, it is considered that Cambridge South East fully satisfies the transport objectives contain in national, regional and local planning policy.
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Cambridge South East Local Plan Representations – Transport
3.0 CAMBRIDGE SOUTH EAST
Development Mix
3.1 Cambridge South East would incorporate a complementary mix of land uses which would minimise the need to travel. It would deliver approximately 4,000 dwellings and 9.7 hectares of high-tech employment land-use. In addition, the development would deliver its own education facilities and a range of local services.
3.2 New employment would be provided at the northern end of the development area, abutting the Peterhouse Technology Park. New residential areas would be situated at both the northern and southern ends of the development area: these residential areas would be divided by a large area of public open space.
3.3 With regards to phasing, it is anticipated that development would begin in both the northern and south western parts of the development area and that development would proceed in both directions towards the middle of the development area. A spine road would be provided in stages (matching the development phases) and this would connect to form a through-route during the later phases of development. From a transport viewpoint, this phasing arrangement would allow development to take advantage of existing travel facilities, particularly excellent local public transport services.
Location
3.4 The Cambridge South East development area is located to the south of Cambridge’s Cherry Hinton ward and immediately to the east of the Queen Edith’s ward (see Figure 1).
3.5 The highway network in the vicinity of the development area is illustrated by Figure 2. This shows that Cambridge South East is flanked to the north by Fulbourn Road (which runs approximately east-west along the area’s northern boundary). Babraham Road (including the Babraham Road Park and Ride site) is situated to the south of the development area. Cambridge South East itself is bisected north-south by Limekiln Road, and east-west by Wort’s Causeway.
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