Issue details

Purpose

The purpose of this report is to agree the Council’s response to East Cambridgeshire District Council’s public consultation on ‘East Cambridgeshire Local Plan: Further Draft – January 2017’. The consultation runs for 6 weeks from 12 January to 22 February 2017.

Background

East Cambridgeshire District Council (ECDC) is reviewing its adopted Local Plan. Public consultation on a preliminary draft of a new Local Plan was undertaken in February-March 2016, and having considered the comments received ECDC is now consulting on a further draft of the Local Plan. The ‘Local Plan – Further Draft’ includes draft policies and proposed allocations that will determine how East Cambridgeshire develops between 2014 and 2036.

South Cambridgeshire District Council (SCDC) and Cambridge City Council (CCC) provided a joint response to the consultation on the preliminary draft Local Plan that was subject to consultation last year. The response supported ECDC’s review of its Local Plan, but made it clear that SCDC and CCC did not agree with the conclusion that nothing in the emerging plan amounts to a “strategic matter”. It highlighted the need for ECDC to:

(i)     work closely with other local planning authorities to ensure that their development strategy and any cumulative impacts of development on transport infrastructure, particularly the A10, can be acceptably mitigated, and

(ii)    continue to recognise and support the work undertaken to inform the objectively assessed need for the Cambridge Housing Market Area that is still being used by SCDC and CCC as our Local Plans are being examined. 

The current public consultation on the ‘Local Plan – Further Draft’ is open to anyone to respond, however ECDC has written to the Councils inviting comments on the ‘Local Plan – Further Draft’ but also specifically seeking our views under the Duty to Co-operate. ECDC are still of the opinion that there is nothing in the emerging plan that amounts to a “strategic matter” as defined under the Duty to Co-operate and therefore they believe there is no requirement for any joint plan preparation or associated activities.

Considerations

a.    Objectively Assessed Need for Homes     

The ‘Local Plan – Further Draft’ proposes a housing requirement of 11,400 dwellings for East Cambridgeshire between 2014 and 2036. This requirement is based on an overall need for East Cambridgeshire of 12,900 dwellings, with 1,500 dwellings of this need redistributed to Peterborough, as agreed in 2013 through the Memorandum of Co-operation. The objectively assessed need for East Cambridgeshire has been calculated based on the existing evidence prepared for the Cambridge Housing Market Area in 2013, which is being used to inform the housing requirements included in the Cambridge and South Cambridgeshire Local Plans, and additional more recent updates prepared by the Research Group at Cambridgeshire County Council specifically related to East Cambridgeshire to consider any adjustments.

This collaborative approach was agreed by the Planning Inspector that examined the adopted East Cambridgeshire Local Plan, and ECDC intend to maintain this approach in the new Local Plan. The emerging Local Plan for Peterborough continues to include an intention to accommodate this need from East Cambridgeshire.

b.    Duty to Co-operate and Strategic Issues

The Duty to Co-operate requirements define a “strategic matter” as:

(a)       sustainable development or use of land that has or would have a significant impact on at least two planning areas, including (in particular) sustainable development or use of land for or in connection with infrastructure that is strategic and has or would have a significant impact on at least two planning areas, and

(b)       sustainable development or use of land in a two-tier area if the development or use is a county matter, or has or would have a significant impact on a county matter.

The development strategy proposed for East Cambridgeshire and its potential impacts on infrastructure may comprise a strategic matter, especially in combination with the development strategy for Greater Cambridge, as there are likely to be impacts on transport infrastructure across more than one planning authority area.

Four options for the development strategy in East Cambridgeshire were subject to consultation last year in the preliminary draft Local Plan. No single option was endorsed by the majority of respondents; however the option to distribute development on a broadly proportionate basis, based on the size of the existing settlement, was most favoured by respondents. ECDC’s assessment of the four options concluded that the main settlement focussed option was the most sustainable and deliverable. However, the ability to deliver development quickly to boost housing supply and meet the five year land supply requirements, and to take account of the view expressed by the public, has led ECDC to propose a development strategy that is broadly main settlement led but also has a broadly proportionate distribution of development.

The ‘Local Plan – Further Draft’ therefore takes forward this development strategy option and includes proposed allocations with a capacity of around 10,290 dwellings to deliver this strategy. ECDC have proposed eleven allocations with a capacity of at least 5,626 dwellings at Ely and Littleport, which are two out of three of the main settlements, and are located on the A10. For the third main settlement of Soham, located on the A142, ECDC have proposed seventeen allocations with a capacity of 2,169 dwellings. The two main settlements on the A10 of Ely and Littleport will be providing over half of the growth proposed in the district.

The development strategy for Greater Cambridge (which covers Cambridge and South Cambridgeshire) proposes a new settlement on land north of Waterbeach, on the A10, and the redevelopment of Cambridge Northern Fringe East, on the edge of Cambridge at the end of the A10. Therefore, cumulatively these development strategies are likely to result in significant impacts on the A10.

In the ‘Further Draft – January 2017’ and its supporting documents, it is not clear how ECDC has considered and responded to the concerns that the Councils outlined last year highlighting this matter. Our records do not show that ECDC has initiated any officer level discussions with the Councils under the Duty to Co-operate relating to this potential strategic matter since the consultation on the ‘Preliminary Draft – February 2016’.

SCDC and CCC approached relevant officers at ECDC in 2015 and 2016 to be part of the A10 Corridor Transport Study that is currently being prepared. This study is being funded by developers, CCC, SCDC and Cambridgeshire County Council and being undertaken by Mott MacDonald to develop transport options for the A10 corridor and provide clarity on any mitigation measures that will be needed.

The ‘Site Assessment Evidence Report – January 2017’ outlines the methodology used to assess each site suggested for allocation and includes a site assessment for each of the sites. Cambridgeshire County Council’s Transport Team was asked to assess each site to identify local road impacts, and their response is set out as a score with accompanying comments. For each of the sites considered in Ely and Littleport, the site assessments record that Cambridgeshire County Council highlighted concerns that the impact of all the identified sites in these settlements could have a significant cumulative impact on transport infrastructure. The County Council’s comments also state that should significant development across a number of sites be proposed then a cumulative impact assessment will need to be undertaken to demonstrate that any significant cumulative impacts can be satisfactorily mitigated.

The ‘East Cambridgeshire Growth Study – January 2017’ identifies the draft Transport Strategy for East Cambridgeshire (February 2016) as a relevant consideration in developing the alternative growth strategy options. The draft Transport Strategy for East Cambridgeshire (February 2016) was developed based on the growth strategy included in the adopted East Cambridgeshire Local Plan (2015) rather than the proposed growth strategy in the ‘Further Draft – January 2017’. In relation to the A10, the proposed growth strategy in the ‘Further Draft – January 2017’, compared with the growth strategy in the adopted East Cambridgeshire Local Plan (2015), includes significant additional proposed allocations at Littleport, and amendments are proposed to the adopted allocations at Ely.

c.    Other Comments

The Cambridge Green Belt surrounds the city of Cambridge and extends out into South Cambridgeshire and East Cambridgeshire. In East Cambridgeshire it extends around the villages of Bottisham, Lode and Swaffham Bulbeck. The longstanding purposes of the Cambridge Green Belt are consistent between Cambridge and South Cambridgeshire, and should also be consistently laid out in East Cambridgeshire. Consequently the Councils propose an amendment to the Green Belt purposes as set out in the East Cambridgeshire ‘Local Plan – Further Draft’.

Proposed Response

A joint response from SCDC and CCC is proposed on the ‘East Cambridgeshire Local Plan: Further Draft – January 2017’ and whether the Duty to co-operate requirements have been fulfilled. The joint response is included in Appendix 1.