Representations to Cambridge Issues and Options 2, Part 1
Question 1:
Where do you think the appropriate balance lies between protecting
land on the edge of Cambridge that is of high significance for Green
Belt purposes and delivering development away from Cambridge in new
settlements and in better served villages? Please provide any
comments.
1.0
Savills (UK) Limited is instructed to make necessary representations to the Issues and
Options 2 Consultation on behalf of St John’s College, Cambridge in respect of its
landholdings on the edge of Cambridge. Representations were made to Issues and Options 1
during 2012 objecting firstly, to the approach that the Councils were taking in terms of growth
assumptions and the implications for the Green Belt and secondly, making the case for the
release of land within the Green Belt for residential development.
1.1
This new consultation document (Issues and Options 2) provides the opportunity to make
further representations. In this context, we are disappointed to see that the Councils have
failed to reconsider their strategy nor have they appropriately (in our view) assessed the
merits of the College’s landholdings in terms of releasing Green Belt for development.
Consequently, our response focuses on these two issues.
1.2
Regarding the broad planning strategy for accommodating growth in the Cambridge area, any
approach must recognise the relationship between the respective administrative areas of
Cambridge City and South Cambridgeshire District. Whilst there are administrative
boundaries, it is the case that there is a symbiotic relationship between the two. This is
perhaps best expressed in the level of commuting between the two areas in terms of the
home and workplace as well as those movements generated by the presence of high order
services and facilities within the City relating to leisure, shopping and entertainment. There is
thus a strong relationship between the City and South Cambridgeshire and consequently a
strategy employed by one authority has a definite impact upon the other.
1.3
Whatever strategy comes forward, we will need to accept that Cambridge will continue to be
the main hub for employment and the focus for people to live. Our submissions have always
acknowledged the important role that Cambridge must play in terms of accommodating
development alongside the role that the villages around the City perform and which will also
accommodate new development – it is the balance between the two that is central to the
question posed.
1.4
In responding to this issue, it is not that long ago in planning terms that policies of dispersal
were being pursued in the Cambridge area in the 1990’s - a strategy of deliberately resisting
development on the edge of Cambridge essentially forced growth outwards to more
peripheral areas. This sought in part to protect the City from new development whilst
spreading the economic benefits over a wider geographical area. Those dispersal policies
were challenged and reversed by the Cambridgeshire and Peterborough Structure Plan 2003
which placed greater emphasis on urban extensions to Cambridge including land released
from the Green Belt.
1.5
In essence, the dispersal strategy sought to protect and preserve Cambridge as a University
town in a rural setting and which clearly severely restricted the City’s ability to expand. It is
really only since 2003 that there has been a change of policy allowing for the City to develop
into urban extensions. This change to concentrating development on the edge of Cambridge
acknowledged the deficiencies in the policies adopted over past years and the implication this
has had for economic growth and sustainable travel patterns.
1.6
The change resulted in a fundamental review of the Green Belt and in the identification of a
number of sites for future development on the edge of the City. This was accompanied by a
new settlement option at Northstowe and some development for the larger settlements within
South Cambridgeshire. Such a shift and emphasis was clearly intended to address issues of
housing difficulty but it remains the case that delivery of housing in and around the City is
highly constrained and unable to meet supply. Housing prices continue to increase faster than
earnings leaving many with no possibility of house purchase – demand for housing continues
unabated and it is critical the Council acknowledges this position and reacts positively. It is no
good reverting to a policy concentrated on dispersal
– Cambridge must accommode
development and the pursuance of the policy of Green Belt releases must continue. Such a
policy approach has really only been in existence for a short period and there is no cogent or
rational reason from departing from a strategy which supports sustainable patterns of
development on the edge of Cambridge.
1.7
It is clear that the strategy of continuing development in Cambridge is a sustainable one –
there have been no changes in circumstances when such a strategy was adopted within the
Cambridgeshire and Peterborough Structure Plan, the Cambridge Local Plan and the South
Cambridgeshire Core Strategy. Paragraph 6.9 of the Part 1 Issues and Options 2 document
states:
“The current Sustainable Development Strategy was extensively scrutinised and challenged
during its evolution through the Regional Plan and Structure Plan into the Cambridge Local
Plan and South Cambridgeshire Local Development Framework (LDF).
Independent
planning inspectors confirmed it at the most sustainable development strategy for the two
districts to 2016 and beyond.”
1.8
Paragraph 6.10 goes on to state:
“Overall, the Cambridgeshire and South Cambridgeshire Sustainable Development Strategy
Review document concludes that the Development Strategy in the Cambridge Local Plan and
the South Cambridgeshire LDF remains the most sustainable for the two areas, subject to
striking the right balance between meeting the needs and demands for new homes and jobs,
with environmental, infrastructure and quality of life factors. The most sustainable locations
for development are within and on the edge of Cambridge and then on more new settlements
close to Cambridge, which are connected to the City by high quality public transport and other
non-car modes.”
1.9
With a substantial need for development in Cambridge and South Cambridgeshire, it is
inevitable that land within a tightly drawn Green Belt boundary around the edge of the City will
be identified as a potential option for accommodating new development pressure.
We
consider that a comprehensive review of the Green Belt boundary should be undertaken as a
response to a full understanding of development needs.
Government Guidance
1.10
The strategy of accommodating development should of course be Pre-empted by a proper
critical analysis of the quantum of development required on the basis of objectively assessed
needs and requirements and not a capacity based approach which is what the Council has
pursued.
1.11
The National Planning Policy Framework (NPPF) was published in March 2012 and sets out a
presumption in favour of sustainable development and which must be seen as the golden
thread running through both plan making and decision making. Paragraph 14 states that
Local Plans should:
“...meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless:

any further impacts of doing so would significantly and demonstrably outweigh the
benefits, when assessed against the policies in this framework taken as a whole; or

1.12
specific policies in this framework indicate development should be restricted.”
Paragraph 17 of the NPPF sets out the 12 core land use planning principles which should
underpin both plan making and decision making and in particular we would draw the Council’s
attention to the third bullet point at paragraph 17 which states that local authorities should:
“Proactively drive and support sustainable economic development to deliver the homes,
business and industrial units, infrastructure and thriving local places that the country needs.
Every effort should be made objectively to identify and meet housing, business and other
development needs of an area, and respond positively to wider opportunities for growth and
plans should take account of market signals, such as land prices and housing affordability
and set out a clear strategy for allocating sufficient land which is suitable for development in
that area, taking account of the needs of the residential and business communities.”
1.13
Paragraph 18 of the NPPF reinforces the Government’s commitment to securing economic
growth in order to create jobs and prosperity and in paragraph 20 the guidance states that:
“Local Planning Authorities should plan proactively to meet the development needs of
business and support an economy fit for the 21st Century.”
1.14
Paragraph 47 of the National Planning Policy Framework (March 2012) states Local Planning
Authorities should:
“...use their evidence base to ensure that their Local Plan meets the full, objectively assessed
needs for market and affordable housing in the housing market area, as far as is consistent
with the policies set out in this Framework, including identifying key sites which are critical to
the delivery of the housing strategy over the Plan period...”
1.15
Such work must be seen in the context of the success of Cambridge and its immediate area
as a hub and focus for a rapidly expanding high technology sector and a location with high
levels of employment. Indeed, it is locations such as Cambridge that are considered to be in
prime position to drive economic recovery and it is such a policy thrust that is evident within
such national guidance. It is therefore critical that the policies within a new Local Plan seek to
positively deliver growth as far as possible given the strategic role that Cambridge has within
the UK economy.
Objectively assessed need for housing
1.16
The Council will be aware of strong concerns expressed by landowners and agents around
the edge of Cambridge about the timing of decisions in the process of preparing the Local
Plan. It is clear that the Council has not determined development needs and consequently
the preferred development strategy has not been agreed and yet the Council has rejected our
client’s potential development options within the Green Belt in advance of the results of that
work.
1.17
Indeed paragraph 5.6 of the consultation document acknowledges this and states:
“Cambridgeshire County Council Research and Performance Team is looking in detail at the
population, housing and employment forecasts for the Strategic Planning Unit on behalf of the
Cambridgeshire Councils. It will look at the available evidence from official statistics, local
data and sub-regional forecasting models and take account of the 2011 Census population
figures. It will analyse all of the available data and inform and update the Strategic Housing
Market Assessment (SHMA) which the Government now requires Councils to look at when
setting their housing targets and help the Councils identify appropriate levels of provision to
be planned for in their Local Plans to 2031.”
1.18
The concerns expressed about the timing of this work from both St John’s College, as clients
of Savills, as well as other landowners on the west side of Cambridge has generated the need
for specialist assessment of development needs. Accordingly, G L Hearn were instructed by
a number of parties including St John’s College to prepare a demographic assessment to
determine population and migration trends and provide advice on realistic housing and
employment targets. A copy of the document is enclosed at Appendix 1.
1.19
The enclosed report provides the evidence to provide an objective assessment for housing
requirements for Cambridge and South Cambridgeshire. The report has highlighted a number
of key issues with demographic data relating particularly to Cambridge. In this instance, a
comparison of the 2001 and 2011 Census data suggests that Cambridge’s population
increased by 15,000 over the 2001 – 2011 decade (a growth of 13.8%). ONS were estimating
a notable out-migration of the people from the City, with a large net in-migration into South
Cambridgeshire. There is clearly a major issue in terms of this figure compared to the Sub
National Population Projections (SNPP) which project population growth of just 1.5% (726
persons) between 2011 – 2031. The 2011 Census thus indicates that the input data for
Cambridge which underpins the 2010 and 2011–based SNPP is unreliable. Such projections
can therefore be rejected as a providing robust base for strategic planning for the two
authorities.
1.20
The report by G L Hearn has considered an alternative demographic projection which has
been modelled based on ten year migration trends. Such trends used data on fertility and
mortality and a 2001 and 2011 Census data on population growth over the inter-censal
period. This remodelling indicates an average net migration of 1,190 persons per annum over
the 2001 – 2011 decade to Cambridge and net migration of 1,280 persons per annum for
South Cambridgeshire. This level of net migration is projected forward on a linear basis and
Figure 12 within Appendix 1 results in a housing requirement for 37,600 dwellings over the
2011 – 2031 period (1,180 per annum) across the two authorities. The report concludes that
planning on this basis would only however perpetuate trends over the 2001 – 2011 period
which was marked by a strong imbalance between supply and demand linked to underprovision of housing and associated substantial reductions in housing affordability.
1.21
Consequently, a range of economic-driven scenarios have been developed with a baseline
growth scenario forecasting 3.1% annual growth in GVA across the two authorities which
would support growth in employment of between 30 – 33% over the twenty year Plan period.
Between 41,800 and 44,000 homes would be required over the plan period to 2031 to support
this level of growth.
1.22
The NPPF also requires the provision for meeting current and nethousing need and which
needs to be added to the housing requirement derived from the projections. The Councils
latest housing needs evidence from 2008 indicated that there is a need for 1,935 dwellings to
accommodate the households that are homeless, overcrowded or concealed. G L Hearn
assumed that across the authorities 95 additional homes per annum would be required to
meet this need.
1.23
On this basis, it is considered that an objective assessment of housing requirements for
Cambridge and South Cambridgeshire would require provision of between 43,700 and 45,900
homes over the 2011 – 2031 Plan period. This equates to between 2,185 and 2,205 homes
per annum across the two authorities.
1.24
This rate of development would represent a modest uplift on planned development rates of
between 3% to 8% on levels in the adopted (and now revoked) East of England Plan. Such
figures are considered necessary to support the growth potential of the local economy and to
address the clear housing affordability issues which are present. Indeed, it is entirely
consistent with NPPF requirement to significantly boost housing supply.
1.25
It is clear from the analysis undertaken by G L Hearn that the projected number of homes
needed from the Plan period fall within the ‘high’ options for homes contained within the
Councils’ Consultation undertaken in 2012.
1.26
It is imperative that the Councils’ address the issue of objectively assessed needs in a
coherent manner. The work undertaken by G L Hearn provides a professional and important
assessment and we consequently consider that the evidence to justify the housing target
provided by consultants is credible and robust.