Question 39. Should we look to remove land from the Green Belt if evidence shows it provides a more sustainable development option by reducing travel distances, helping us reduce our climate impacts?
A. Whilst there are different advantages and challenges for each growth option as recognised by the consultation material, significant weight must be given to the NPPF in considering which growth options are appropriate to progress. The NPPF (paragraphs 133 and 136) is clear that great importance is attached to Green Belt and boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. B. Paragraph 137 explicitly requires the strategic policy-making authority to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries. Compliance with this process will be assessed through the examination of its strategic policies. C. Therefore, the onus is on the GC authority to demonstrate that all other reasonable options for growth have been exhausted before releasing Green Belt regardless of the potential sustainability benefits of Green Belt locations. D. Therefore, it is clear that edge of sustainable village locations outside of the Green Belt, such as Gamlingay, which present a suitable, available and sustainable location for development must be given significant weight and consideration for allocation before any land can be released from Green Belt. E. If further sites are required to meet growth needs once all edge of village and edge of Cambridge sites outside the Green Belt have been assessed and, where appropriate, allocated, then the Green Belt boundaries can then be changed and justified as necessary.
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As set out above in paragraph 137 of the NPPF, national planning guidance states that all alternatives should be considered before sites are released from the Green Belt. The Council should therefore first fully assess the option of delivering sites on the edge of non-Green Belt settlements, and should prioritise the allocation of these ahead of Green Belt release. A balance will need to be struck in some cases between release of Green Belt sites in proximity to Cambridge and allocation of sites which may incur shorter journeys. These decisions should be supported by identification of improvements to train and bus services Settlements outside the Green Belt in Greater Cambridge such as Meldreth and Melbourn which offer opportunities for walking and cycling to local shops and services, and to access excellent train and bus public transport provision, should be prioritised before Green Belt settlements for allocating new sites.
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It is known that the Government attaches great importance to Green Belts, the fundamental aim of which is to prevent urban sprawl and keep land permanently open. The anticipated forthcoming Planning White Paper may make some changes to this situation with potentially some relaxation. However, until it is published, current national planning policy remains that the Green Belt serves five purposes: a. To check the unrestricted sprawl of built up areas; b. To prevent neighbouring towns merging into one another; c. To assist in safeguarding the countryside from encroachment; d. To preserve the setting and special character of historic towns; and e. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Green Belt boundaries are established through Local Plans and should only be altered where exceptional circumstances are fully evidenced and justified. As part of the preparation of the currently adopted Local Plans, minimal changes to the Green Belt were proposed. These were limited to a number of small scale changes to allow the expansion of some existing urban extension allocations and a small number of new allocations. The new Local Plan should undertake a fundamental review of the entire Cambridge Green Belt to understand whether it still serves a relevant function in planning terms for the City, or is stifling sustainable development. Potentially, it is promoting unsustainable patterns of development which simply leapfrog the Green Belt and result in development in less sustainable locations, increasing the need to travel between Cambridge and outlying areas that as such, are less connected to public transport routes. It is clear that given the geography of Greater Cambridge in which many of the most sustainable parts of the spatial planning area are located within the Green Belt, that some Green Belt release should form part of the overall spatial strategy. In this way, the area can help to reduce travel distances and help faciliate sustainability through the provision of sustainable transport infrastructure. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time Green Belts were introduced, the need to promote sustainable development which meets today’s needs including housing, employment and environmental considerations were very different. Today’s issues of climate change, congestion, pollution, water security, food production and fuel poverty suggest that a more radical approach to planning policy is required. At the time the Green Belts were established, the tools available to planners were more limited and the ability to analyse opportunities and constraints and develop robust evidence and justification, were at best very basic. A blanket protection of large swathes of land was therefore considered appropriate. At the time the pressures for growth and essential need for development were considerably less than they are today. Greater Cambridge is an exceptional area, both in its contribution to the national economy and its international reputation. In order to sustain its natural growth in a sustainable way, a wholesale review of the Cambridge Green Belt should be undertaken. This should be a balanced review, not simply an assessment of the performance of various parcels of land against the purposes of Green Belt. It should be a challenging assessment balancing the scale of development required to support the growth necessary to deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over the next 25 years. To support this level of job growth around 2,900 homes will need to be built each year to deliver a total of 66,700 homes between 2017 – 2040. It is imperative both locally and at the national level that Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. Cambridge as a city is also exceptional and as such a radical review of Green Belt policy is clearly justified to facilitate its growth. The tools available today to analyse and inform plan making decisions are highly sophisticated and should be used to undertake a challenging and balanced review of the existing Green Belt. Summary of Comments: A radical review of the Cambridge green belt is required to facilitate growth within the Greater Cambridge area and sites need to be released.
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Q39. Should we look to remove land from the Green Belt if evidence shows it provides a more sustainable development option by reducing travel distances, helping us reduce our climate impacts? It is known that the Government attaches great importance to the Green Belt, the fundamental aim of which is to prevent urban sprawl and keep land permanently open. The anticipated forthcoming Planning White Paper may make some changes to this situation with potentially some relaxation. However, until it is published, current national planning policy remains that the Green Belt serves five purposes: a. To check the unrestricted sprawl of built up areas; b. To prevent neighbouring towns merging into one another; c. To assist in safeguarding the countryside from encroachment; d. To preserve the setting and special character of historic towns; and e. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Green Belt boundaries are established through Local Plans and should only be altered where exceptional circumstances are fully evidenced and justified. As part of the preparation of the currently adopted Local Plans, minimal changes to the Green Belt were proposed. These were limited to a number of small scale changes to allow the expansion of some existing urban extension allocations and a small number of new allocations. The new Joint Local Plan should undertake a fundamental review of the entire Cambridge Green Belt to understand whether it still serves a relevant function in planning terms, or is stifling sustainable development. Potentially, it is promoting unsustainable patterns of development which simply leapfrog the Green Belt and result in development in less sustainable locations, increasing the need to travel between Cambridge and outlying areas that as such, are less connected to public transport routes. It is clear that given the geography of Greater Cambridge in which many of the most sustainable parts of the spatial planning area are located within the Green Belt, that some Green Belt release should form part of the overall spatial strategy. In this way, the area can help to reduce travel distances and help faciliate sustainability through the provision of sustainable transport infrastructure. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time the Green Belt was introduced, the need to promote sustainable development which meets today’s needs including housing, employment and environmental considerations were very different. Today’s issues of climate change, congestion, pollution, water security, food production and fuel poverty suggest that a more radical approach to planning policy is required. At the time the Green Belt was established, the tools available to planners were more limited and the ability to analyse opportunities and constraints and develop robust evidence and justification, were at best very basic. A blanket protection of large swathes of land was therefore considered appropriate. At the time the pressures for growth and essential need for development were considerably less than they are today. Greater Cambridge is an exceptional area, both in its contribution to the national economy and its international reputation. In order to sustain its natural growth in a sustainable way, a wholesale review of the Cambridge Green Belt should be undertaken. This should be a balanced review, not simply an assessment of the performance of various parcels of land against the purposes of Green Belt. It should be a challenging assessment balancing the scale of development required to support the growth necessary to deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over the next 25 years. To support this level of job growth around 2,900 homes will need to be built each year to deliver a total of 66,700 homes between 2017 – 2040. It is imperative both locally and at the national level that Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. Cambridge as a city is also exceptional and as such a radical review of Green Belt policy is clearly justified to facilitate its growth. The tools available today to analyse and inform plan making decisions are highly sophisticated and should be used to undertake a challenging and balanced review of the existing Green Belt. This should include taking a finer grain approach, to assess whether there are smaller parcels of land that could be released from the Green Belt without harm. This is particularly important within the areas that benefit from sustainable transport options, such as Fen Ditton, which benefits from Newmarket Road Park and Ride, as well as numerous pedestrian and footpath links. The land to the east of Ditton Lane, Fen Ditton, is located within the Green Belt, although is well contained by existing vegetation, providing effective screening for development. Although the site extends to 4.33 Ha in total, the identified development areas (as shown in the attached Context and Planning Policy Plan) extend to c.1.61 Ha providing significant opportunities for appropriate landscaping to enhance the landscape and maintain a gap between Fen Ditton and Cambridge. This represents 37% of the total site area, with 63% available for landscaping and ecological enhancement. Whilst the important role that the Green Belt plays is acknowledged, a flexible approach needs to be taken where sites such as land east of Ditton Lane, Fen Ditton benefit from their proximity to existing frequent public transport, and given the proposed use, is the most sequentially preferable Site in terms of distance from the doctor's surgery. The Site also presents opportunities for small-scale Green Belt release that would help to enable an existing sustainable village such as Fen Ditton to grow in a sustainable manner. The Site is being promoted for c.30 single storey properties designed specifically for those aged 55 and over as well as those with or supporting someone with a disability. This represents a modest increase in size of 10% for Fen Ditton, based on the existing number of properties within the Parish. In addition, it is also located close to numerous services and facilities, within Fen Ditton itself, Cambridge and the consented scheme north of Newmarket Road, which includes a foodstore, community facilities and open space. Sequentially, the Site is the closest development site within Fen Ditton, a highly sustainable location, which is within c.0.5km of the doctor's surgery, that can be brought forward for the type of small-scale development proposed, with the opportunities for increased biodiversity gain and considerable landscaping to create an attractive, biodiverse environment. Summary of Comments: The Local Plan should consider Green Belt release in sustainable locations close to existing transport.
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Please see section 8.0 of the accompanying representations document.
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Whilst there are different advantages and challenges for each growth option as recognised by the consultation material, significant weight must be given to the NPPF in considering which growth options are appropriate to progress. The NPPF (paragraphs 133 and 136) is clear that great importance is attached to Green Belt and boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Paragraph 137 explicitly requires the strategic policy-making authority to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries. Compliance with this process will be assessed through the examination of its strategic policies. Therefore, the onus is on the GC authority to demonstrate that all other reasonable options for growth have been exhausted before releasing Green Belt, regardless of the potential sustainability benefits of Green Belt locations. Therefore, it is clear that edge of village locations outside of the Green Belt, such as Linton, which present a suitable, available and sustainable location for development must be given significant weight and consideration for allocation before any land can be released from Green Belt. If further sites are required to meet growth needs once all edge of village and edge of Cambridge sites outside the Green Belt have been assessed and, where appropriate, allocated, then the Green Belt boundaries can then be changed and justified as necessary.
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37. Paragraphs 133 and 136 of the NPPF are clear that great importance is attached to Green Belt and boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. 38. Paragraph 137 explicitly requires the strategic policy-making authority to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries. Compliance with this process will be assessed through the examination of its strategic policies. 39. Therefore, the onus is on the Greater Cambridge Authority to demonstrate that all other reasonable options for growth have been exhausted before releasing Green Belt regardless of the potential sustainability benefits of Green Belt locations. 40. Cambourne in general present a suitable and sustainable location for development and therefore must be given significant weight and consideration for allocation of additional development before any land can be released from Green Belt. 41. If further sites are required to meet growth needs once all land outside the Green Belt has been assessed and, where appropriate, allocated, then the Green Belt boundaries can then be changed and justified as necessary. 42. Additionally, the previous Sustainability Appraisal for the SCLP assessed the approach to new settlements/Green Belt. This concluded that the removal of additional large-scale sites from the Cambridge Green Belt could result in irreversible adverse impacts on the special character of Cambridge as a compact historic city and risk the economic success of the Cambridge area. This further highlights the importance of considering sustainable locations outside the Green Belt as a priority for future growth.
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7.1.1 The Local Plan should be focussed on providing sustainable development in the most appropriate locations. To prioritise the four big themes will result in some development impacts. 7.1.2 Notwithstanding the underlying purposes of the Green Belt (Para. 134 of the NPPF), where it can be demonstrated that appropriate development can be brought forward in the Green Belt, sites should be considered within the context of their individual circumstances. Applications should be considered in the context of Para. 136 of the NPPF including an assessment as to whether it can be demonstrated that a proposed development would bring substantial benefits, outweighing the loss of Green Belt land and thereby demonstrate exceptional circumstances needed to justify Green Belt release. In accordance with Para. 138, Green Belt boundaries should be reviewed to reflect the need to promote sustainable patterns of development. If the release of Green Belt can facilitate more sustainable patterns of development, particularly if the land has been previously developed or is well-served by public transport, there should be policy provision to allow for a consideration of this in order to determine Green Belt planning applications within the emerging Local Plan. 7.1.3 By way of example, the Greater Cambridge Partnership, in progressing the A428/A1303 Cambourne to Cambridge Better Public Transport Project, have recommended a Scotland Farm Park and Ride location, acknowledging that it is a priority project for development in the first five years of the Greater Cambridge Partnership’s (GCP’s) transport programme. Made up of three key elements: a public transport link between Cambourne and Cambridge, a new Park and Ride facility off the A428/A1303 to supplement the existing Madingley Park and Ride, and new cycling and walking facilities. Subject to statutory consent, construction of these elements is anticipated to commence in 2022, with an opening date in late 2024.
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The NPPF underlines the Government’s commitment to maintaining the integrity of Green Belts, stating that once established, these should only be amended in ‘exceptional circumstances’ and only through the preparation or updating of plans. The NPPF indicates that when drawing up Green Belt boundaries, the Council should consider the need to promote sustainable patterns of development, channelling development towards the urban area. Where Green Belt land is required for release, consideration should first be given to land which is previously developed and/or well served by public transport. When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that all appropriate options are fully explored, including amendments to Green Belt boundaries. Grosvenor and USS consider that there are exceptional circumstances for the release of Green Belt land to meet the growing housing need in Cambridge, especially where travel distances can be reduced and sustainable patterns of development encouraged. This will provide an opportunity to identify sites which can provide a significant amount of homes to contribute to meeting identified housing needs, especially where those sites are well served by public transport (as advised in para 138 of the NPPF) and also well connected to key destinations, such as major employment hubs, education and community facilities. Grosvenor and USS agree that climate impacts could be reduced if the Councils take this approach to remove Green Belt land if evidence shows it provides a more sustainable development option by reducing travel distances. Grosvenor and USS maintain that any Green Belt Review undertaken by the Councils should be a robust assessment, undertaken in accordance with the national Planning Practice Guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development. There are a number of Green Belt locations where housing sites can be identified that reduce travel distances, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain. Trumpington South is such a site, situated on the southern edge of Cambridge, located next to the existing Trumpington Park and Ride, and the future Cambridge South West Travel Hub, with proposals to extend the guided busway around the edge of the site. Trumpington South is well connected via active and shared travel modes to the Cambridge Biomedical Campus, the city centre and nearby community facilities, reducing commuting and travel distances to key locations. Furthermore, the Green Belt and Landscape Appraisal prepared by Terence O’Rourke, which has been prepared in support of these representations, assesses the local purpose of the Green Belt in this location which is to preserve its setting and special character and to prevent the merging of communities with each other and to the city. The Appraisal considers the contribution of the site to the prevention of communities merging into one another to be limited. The Appraisal’s focus has, therefore, been on the changing nature of the site and surrounding environs and how this has, and will, affect the setting of Cambridge city. The Green Belt and Landscape Appraisal conclusions advise that the alterations to the landscape, specifically the urbanising nature of development, such as the proposed Park and Ride, and associated reduction in visual openness, will alter the contribution of the site to Green Belt purposes. It goes on to say that this is particularly the case in relation to the setting of and approach to the settlement edge and that these changes have also, therefore, altered the qualities and function of the Green Belt. The Appraisal notes that the future development of this site would provide an opportunity to create a new settlement edge which responds to the changing and increasingly enclosed nature of the landscape as a result of development. It advises that the extent of the settlement edge should allow for a sufficient countryside edge to be preserved, ensuring that the landscape predominates. It concludes that alterations to the landscape would provide the opportunity to enhance the countryside edge and, therefore, the setting and special character of Cambridge. Lastly, the NPPF also refers to “ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining green belt land”. The Green Belt and Landscape Appraisal advises that Trumpington South offers the opportunity to significantly enhance the quality of the remaining Green Belt within the site through biodiversity enhancements and access for multi-recreational purposes, as has been demonstrated in the Country Park to date. Grosvenor and USS consider these compensatory measures would offset any loss of Green Belt arising from the development
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