Question 51: Generic Question

1. Introduction 1.1 These representations have been prepared by Turley on behalf of Downing College, Cambridge (“the College”). The representations have been prepared in response to the consultation on the Greater Cambridge Local Plan - Regulation 18 - Issues and Options 2020 and its supporting evidence base. 1.2 Downing College welcomes Cambridge City Council and South Cambridgeshire District Councils’ (“the Councils”) decision to review and update their Development Plan collectively. This decision followed the insertion of a policy into each of the adopted Local Plans (2018) by the Local Plan Inspectors, which committed the Councils to an early review of their Development Plans. 1.3 Downing College is pleased to have the opportunity to engage in the emerging Local Plan making process at this early stage. The College has reviewed its assets and is considering how the College site will change over the next 20 years through the development of an appropriate long-term plan. The College is interested in understanding how the emerging Local Plan will enable the changing needs of educational institutions to adapt to the learning and welfare needs of their students and staff, especially in locations which must consider the impact on heritage assets. As owners and occupants of listed buildings within a Conservation Area, Colleges have an important part to play in the future protection and enhancement of these heritage assets, whilst ensuring that these buildings function efficiently and effectively for College life. 1.4 These representations support the review of the Local Plan and cover the following matters: • Recognition that there is a need to consider different options to achieve zero net carbon within new and adapted buildings, especially those within a historic context; • That the Council needs to undertake research to understand the complexities of student accommodation provision before determining how much should be allowed for within the emerging Local Plan; • Understanding the change in working patterns so that public transport options are responsive to demand; and • Consideration in the emerging Local Plan of the difference between University Development and College Development. 1.5 A site plan of Downing College is included at Appendix 1.

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2. Consultation Response 2.1 This section of the report provides a detailed response to the Consultation, on behalf of Downing College, Cambridge. The comments are set out as responses to the relevant questions in the consultation document. 2.2 The comments are focused on how the emerging Local Plan should consider how buildings can achieve improved levels of energy efficiency within a heritage context; the different needs and types of student accommodation, and the need to improve transport infrastructure to ensure that those working in the City Centre are able to reach their jobs in an affordable way.

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3. Summary 3.1 These representations have been prepared by Turley on behalf of Downing College, Cambridge (“the College”). They have been prepared in response to the consultation on the Greater Cambridge Local Plan Regulation 18: Issues and Options Consultation 2020 and its supporting evidence base. 3.2 These representations are supportive of the Councils’ decision to embark on an early review of their Local Plans. It is appreciated that this initial consultation is at an early stage of the Plan-making process. However, in order to comment more constructively on the direction of this emerging Plan, the Councils need to undertake further research, as suggested in these representations, to form the underlying evidence base. 3.3 At this stage, issues of importance to the College around how it accommodates its students and provides for their social and welfare needs is given little commentary in the consultation document. The College, therefore, hopes that the Councils take up its invitation to meet and discuss the diversity of its accommodation needs over the next Local Plan period, so that this information, together with that of other educational institutions, is used to inform the first draft of the emerging Local Plan.

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5 Where to build? 5.1 Our current approach to locating development Comment - Given that the proportions of housing growth in rural areas are the highest both within the Structure Plan 1999-2016 and the Adopted Local Plans 2011-2031 it is surprising how lacking the consultation document considers the rural environment.

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1. Introduction 1.1 IWM Duxford retains the finest and best-preserved fighter base representative of the period up to 1945 in Britain with important associations with The Battle of Britain and the American Support for the Eighth Air Force. It closed as a military airfield in 1961 and became the first regional branch of the Imperial War Museums (IWM) in 1976. 1.2 In 2017/18, IWM Duxford attracted a total of almost 400,000 visits; 2/3 from people outside the Eastern Region and 12% from overseas. It directly employed 85 FTE posts whilst the 27 on-site third party organisations employed the equivalent of a further 150 FTEs. A report on the Economic and Social Impact of the Museum by Hatch Regeneris published in January 2019 calculated that the value of the site to the East of England equated to 1040 FTE jobs and £43m in GVA. 1.3 In addition, through its school programme activities, public learning and volunteering opportunities, IWM Duxford contributes to social inclusion and wellness far in excess of the monetary values above. 1.4 IWM is therefore very pleased to have the opportunity to comment on this early stage of the replacement Local Plan and in general terms supports the key themes under discussion. Turley have been asked by IWM to coordinate its responses.

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Response to Question 2 Vision 3.1 The applicant is a local landowner and a valued member of the local community. Their vision is to help strengthen the Longstowe community and bring forward a proposal in cooperation with local residents. 3.2 The site is submitted for allocation of development to include 30 dwellings, community space, green infrastructure and landscaping. This is in direct response to a decline in the village and the need to enhance Longstowe through carefully considered development. 3.3 The development is a locally led community-based scheme supported by Socio-Economic research conducted by Bidwells and meets a need for housing to sustain the village community of Longstowe. 3.4 To accompany this statement, a Development Site Report is also provided which includes a concept masterplan and background to this development proposal which helped form that masterplan including community consultation. Consultation Initial consultations in 2018 3.5 17 July 2018 – representatives of the Longstowe Hall Estate met with South Cambridgeshire’s housing officer to discuss Bourn and Longstowe proposals. 3.6 20 September 2018 - representatives of the Longstowe Hall estate met with the planning portfolio holder, leader of the council and director of planning at South Cambridgeshire District Council to discuss this community-based proposal. This meeting followed previous discussions held in July 2018 as well as announcement made in spring that year by the leader of the council and planning portfolio holder with regard to more sustainable housing to be delivered in particular villages including Longstowe. Community Consultation 3.7 Consultation with the community is a vital aspect of the proposed development and has been maintained throughout in preparation for this representation. Consultation will continue as the proposal is brought forward. 3.8 The proposed development is the product of extensive public consultation which both identified the need for a community led scheme and has helped to shape development proposals. 3.9 The landowner has conducted a series of public consultations in the area with local residents including the following: 18 April 2019 Parish Council AGM where the housing needs survey was reported on, and where parishioners expressed further interest in housing, but thought that Longstowe Hall Estate would be averse to releasing land for building. 10 October Initial presentation to the Parish Councillors. 14 October Presentation to 4 members of the oldest families living in the Parish – Murdens and Hemmins & second presentation to 3 young families in the village. 26 November 2 presentations to Core group of 9 families living in the heart of the village. 9 December Presentation to a group from the houses beyond St Johns Farmyard and more persons with properties in Rushbrook Close. 10 December Individual presentation to family immediate adjacent to the centre of village development site 14 December Presentation to 2 households looking on to the centre of village plot 2 January 2020 Presentation to owners of larger family homes in the village 3.10 The outcomes from public consultation are summarised in the following requirements from the local community: ● Development directly opposite Rushbrooke Close is favoured by a clear majority as integrating the village better; ● All community members wanted to see properties set back from the road edge, to mirror the look opposite (with front garden); ● Parking to be for a minimum of 2 cars per household to avoid any roadside parking; ● A mixture of properties with bungalows are favoured for retirement; ● To include family homes to encourage families to put down roots; ● Retirement homes would ideally be retained for rental to elderly Longstowe residents; ● Potential for existing farm buildings to be used for conversion into shared office space; ● Development to explore renewable energy infrastructure; ● Explore green solution to sewerage and therefore not adding to the overburdened existing system; ● Prevention of the landscaped areas being left under the ownership of any developer to prevent a later application seeking to build on the green spaces; ● Potential for Longstowe Estate to retain ownership and maintenance of the landscape areas; ● Replacement of the large grain store at St Johns would be an improvement rather than converting it. Village Assessment Conclusions 3.11 The population of the village has declined by 9% from 204 in 2011 to a projected 186 residents in 2018, a lower resident population than in 2001 (193)1 (Figure 2.1). The age profile shows: ● Those aged 64+ make up 17% of the population, comparable with the district. 1 Census 2001, Census 2011, ONS Small area population projections 2018 ● The village has a higher % of:  older children (15-19 years), 10% compared to 6% in the district;  elderly (75+), 10.3% compared with 9.9% in the district;  working age population (30-64), 54.7% compared to 49%; ● The village has fewer children (0-14), 15% compared to 18.5%. Figure 2.1 – Longstowe Population Change Source: NOMIS, ONS Census 2001, Census 2011 and ONS Small area population estimates 2018 (OA: E00092047) Figure 2.2 – Longstowe Age Profile Source: ONS Small area population estimates 2018 (OA: E00092047) Community buildings 3.12 Community buildings bring people together, enable them to play an active role in their community and improve the quality of life in their neighbourhoods, helping to build stronger communities.2 They are an important facilitator of social interaction and help to build social capital in the form of: ● Personal relationships; ● Social network support (the level of resources or support that a person can draw from their personal relationships); 2 A key objective of SCDC Community Services Vision ● Civic engagement (the actions and behaviours that can be seen as contributing positively to the collective life of the community or society); ● Trust and co-operative norms that shape the way people behave towards each other and as members of society. 3.13 Longstowe is a small village but supports two community buildings: a village hall and a church, as well as a part-time post office run from a residence. 3.14 The village hall is a central element of the social life of the village and is also used by neighbouring villagers. It is used for village events and is available for hire, enabling a range of local clubs to offer activities in the village for all age ranges. There is growing demand for its space, particularly since its refurbishment. 3.15 The Hall is run by a group of Trustees, residents of the village, who undertake its maintenance and manage bookings. This largely falls to the older demographic in the village and a typically small dedicated group of volunteers. This creates pressures on the system, particularly as the population is ageing and without an increase in the village population, its capacity to sustain and continue to offer a full range of community facilities and social opportunities will be diminished. 3.16 Within the village itself, there are good connections, with access from the site to community infrastructure via public footpaths and bridleways. In addition to this, there are permissive routes through Longstowe Hall Estate, which add to the variety of walks available. All routes are well used by dog walkers, creating a mobile community within the village environs. 3.17 The assessment suggests the need for the following: ● Addressing the under provision of existing allotments; ● Provision of a new community orchard ● Onsite provision of informal open space, children’s play area and youth provision; ● Funding to help with maintenance of village hall and augment play area, particularly for older/ teenage children; ● Provision of smaller houses/bungalows to facilitate downsizing and first-time buyers; ● Contributions to education provision. Benefits of the scheme 3.18 Public consultation feedback and Village Assessment Research have been accommodated in the development proposal and help shape the concept masterplan. A consultation map showing the local of community members consulted is attached at Appendix 2. 3.19 The Concept Masterplan within the Development Site Report provides an indicative layout for the site. The purpose of the Masterplan is to demonstrate one way that the site is capable of accommodating the proposed quantum of development and the needs of local residents. 3.20 In addition, the proposed development will bring forward further benefits to the area, including: ● 40% Affordable housing; ● A triple uplift in natural capital well exceeding the targets set out by the LPA; ● Retirement properties to accommodate local need; ● Dwellings to be a mixture of sizes including semi-detached properties; ● Dwellings set back from the High Street; ● Green footpaths connect the site area with wider village: ● Creation of a nature reserve with wetlands, grassland and woodland; and, ● Creation of public green space. Technical Assessments 3.21 A Highways Review, prepared by EAS, accompanies these representations. As part of the review, an access appraisal was undertaken which found that an access onto the highway, along with the necessary visibility splays, can be achieved. 3.22 A Flood Risk Analysis prepared by EAS accompanies these representations. The assessment concludes that there are no restrictions to development.

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Dear Sir or Madam Consultation response to Greater Cambridge Local Plan, Issues and Options 2020 Consultation I write on behalf of Cambridge University Hospitals NHS Foundation Trust to provide our response to the Local Plan, Issues & Options 2020 Consultation. We welcome the opportunity to contribute a response to the Greater Cambridge Local Plan in order to support the inclusive growth and development for Cambridge, in particular when considering the future of Addenbrooke’s Hospital and the Rosie, and the role of the wider Cambridge Biomedical Campus (CBC). About Cambridge University Hospitals NHS Foundation Trust Cambridge University Hospitals NHS Foundation Trust (CUH), incorporating Addenbrooke’s Hospital and the Rosie Maternity Hospital has over 1,000 beds and 11,000 members of staff. We are one of the largest and best known acute hospital trusts in the country. The ‘local’ hospital for our community, CUH is also a leading regional and national centre for specialist treatment; a government designated comprehensive biomedical research centre; a partner in one of six academic health science centres in the UK – Cambridge University Health Partners (CUHP); and a university teaching hospital with a worldwide reputation. We have worked closely with CUHP in preparing this response. CUHP have responded separately to this consultation on behalf of the wider CBC partners. Why are we interested in this consultation? Hospital projects The next phase of development requires the upgrade of the aging NHS facilities at the core of the Cambridge Biomedical Campus's vision. It is the Trust's view that this upgrade provides a further opportunity for the NHS (beyond the vision of the CBC) - a once in a generation chance to use capital investment to integrate our care models, strengthen regional ties, and improve the health care experience of patients locally and across the East of England. We summarise in this response our proposals for major investment in the hospital during the lifespan of the new Local Plan – with the Cambridge Children’s Hospital, the Cambridge Cancer Research Hospital and the rebuild of the core of Addenbrooke’s Hospital (known as Addenbrooke’s 3) all in our capital pipeline during the timeline of this Local Plan. Other projects may include other specialist facilities such as a neurosciences facility and a movement centre. Policies of the plan should ensure the future plans for CUH and the wider Biomedical campus can be accommodated and to improve the local hospital for the residents of Cambridgeshire and South Cambridgeshire, but to ensure the campus as a whole continues to drive nationally significant progress in health outcomes. Housing In addition to hospital projects, a key priority for the Trust is the issue of housing affordability. The lack of affordable housing for our staff, in the right locations, is a key barrier to CUH in recruiting and retaining key staff and skills and has implications for travel patterns, congestion and quality of life for our staff. We enclose evidence with our submission, as follows: 1) “Assessing the Housing Need of Hospital Workers” report prepared by Savills in January 2020. This is research undertaken on our behalf which highlights the real affordability challenges facing our staff, and some of the less desirable outcomes arising as a result. See our comments on questions 31 to 33. 2) We have prepared a summary report entitled “Delivering Affordable Housing for our Hospital Workers: The Case for Change”. This is a simple, accessible document, which draws out the key findings of the Savills research, and sets out CUH’s corporate priorities in terms of housing, highlighting the critical importance of delivering of genuinely affordable housing in accessible locations, to ensure the growth and prosperity of the area can be supported by the NHS. The research highlights housing as one of the key barriers to CUH in recruiting and retaining key staff and skills. Officers will be aware that we are hosting a briefing on this research on 2nd March, to which officers and Councillors have been invited. We very much consider that this research should inform the Greater Cambridge Planning Service’s evidence base on housing need and affordability, to shape policies in the new plan to help meet this need. I trust the content of our representations is clear, but should you have any questions, please do not hesitate to contact me.

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Question 2. Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible Enclosed at Annex A, is a plan showing, Addenbrooke’s Hospital, the Rosie Maternity Hospital, expansion land for the hospital and the adjacent Cambridge Biomedical Campus. The land edged yellow represents the existing Addenbrooke’s Hospital and Rosie Maternity Hospital. The land shaded yellow represents land which CUH has options to draw down form the landowner, in order to facilitate the replacement and/or expansion of hospital buildings and facilities. Land edged blue represents the wider Cambridge Biomedical Campus. (application ref 16/0176/OUT) with the deadline for submission of reserved matters of September 2026. There are three key NHS builds proposed in the next 3-10 years. 1) Cambridge Children's - a paediatric hospital that integrates acute and mental health care, improving the pathways and support to patients and staff across the East of England. This project has been successfully granted £100m of funding. 2) The Cambridge Cancer Research Hospital - a hospital that brings together world class research (University of Cambridge) on methods to improve the early detection and diagnosis of cancer with the clinical (CUH) and commercial facilities to deliver that care. This project has yet to identify a funding source, however discussions are ongoing with industry partners and government departments; and 3) The rebuild of the core of Addenbrooke's Hospital - replacing aging NHS building with a new fit for purpose facility (Addenbrooke's 3) designed to maximise local integration with primary care and community service, working closely with GPs, community nursing, therapy teams, social workers and charities to transform the workforce and co-ordinate services more effectively, ensuring patients get quick and easy access to the care they need closer to home; alongside improving pathways and support to patients and staff across the East of England • The Addenbrooke’s 3 project has successfully obtained c. £5m of seed funding from Government to begin early stage feasibility studies. At this stage, CUH is not in a position to articulate the detail of this project, but it is likely to entail significant clinical development on the CBC Phase 1 and Phase 2 land, moving the centre of gravity of the Hospital to the south and west • Complex construction sequencing will be required to ensure we maintain the highest standards of care throughout the construction and commissioning periods. • We recognise the need to consider the end use of residual land which may be freed up from the demolition of life expired buildings and facilities. We have not put a formal submission into the Call for Sites as the Council are aware of the site and our intentions, and given it is consented for clinical uses. We intend to work with policy and development management officers over the coming months and years to develop a suitable policy framework to support our plans, and to ensure planning permissions are secured in a timely fashion. The working assumption is that construction of the new hospital would commence by 2025. The shaded yellow land has long been identified for the provision of clinical accommodation to support the (re)development of Addenbrooke’s Hospital. This includes:

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Response to Question 2 - ADDITIONAL INFORMATION The Mill Lane Site in Sawston was promoted to the call for sites process in March 2019. A number of technical documents have subsequently been prepared for the site and are submitted with these representations to the Issues & Options consultation including a Vision Document; Green Belt Impact Assessment and Highways Assessment.

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Question 2. Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Q2 Response: The Cambridge Biomedical Campus (CBC) is the largest employment site in Cambridge, with over 20,000 researchers, industry scientists and clinicians and students on one site. A CBC Strategy Group with representation from all campus organisations has agreed to develop a Vision 2050 for the CBC. Subject to ratification by the CBC Strategy Group, this will be shared with the Greater Cambridge Planning Service by summer 2020 to define the extent, scale and location of development proposed throughout the timescale of the next Local Plan, and the anticipated number of jobs to be supported by the CBC by 2050.

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Question 3. Please submit any sites for green space and wildlife habitats you wish to suggest for consideration through the Local Plan. Provide as much information and supporting evidence as possible. Q3 response: No response proposed.

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Response to Question 2 2.1.1 Please see accompanying three Additional Sites and Broad Locations response forms with accompanying site locations plans (Drawing No.’s B.16,348, B.16,348a, and B.16,348b), included at Appendix 1. 2.1.2 Specific information in respect of the uses proposed is outlined on the response forms together with the associated site location plans.

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Dear Sir or Madam Consultation response to Greater Cambridge Local Plan, Issues and Options 2020 Consultation I write on behalf of the Cambridgeshire & Peterborough Sustainability and Transformation Partnership (STP) to provide our response to the Local Plan, Issues & Options 2020 Consultation. The role of the STP is to bring together the key organisations in the NHS with wider system partners in order to more effectively plan health and wider services within Cambridgeshire & Peterborough. The STP is a Partnership of the following organisations: • Cambridge University Hospitals NHS Foundation Trust • Cambridgeshire and Peterborough NHS Foundation Trust • Cambridgeshire Community Services NHS Trust • Cambridgeshire County Council • East of England Ambulance Service NHS Trust • NHS Cambridgeshire and Peterborough CCG • NHS Property Services • North West Anglia NHS Foundation Trust • Royal Papworth Hospital NHS Foundation Trust • Peterborough City Council We welcome the opportunity to contribute a response to the Greater Cambridge Local Plan and in particular wish to state our strong support for the inclusion of Health and Wellbeing as one of the Big Themes of the plan. We have chosen to respond to those questions of most relevance to the STP partners, as per the summary table appended to this response (questions 1, 16, 19 and 36 only). Our intention is that the NHS system in Greater Cambridge (and the wider STP area) is more effective at supporting and engaging with planning authorities in areas of planning policy, pre-application stages and planning application determination, with the objective of securing better health outcomes through better designed places, better integration of health considerations in masterplanning and through planning gain for health purposes (secured via S106/CIL). We are developing our thinking in these areas and we will be in contact to discuss further in due course. We look forward to working more closely with officers in both Planning Policy and Development Management. If you have any questions regarding the content of our response, please do not hesitate to contact me.

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Response to Question 2 Hopkins Homes made a submission for this site (Land at Bush Lane, Comberton) as part of the March 2019 Call for Sites. The consultation documentation makes clear that "There is no need to resubmit sites you have already provided to the Councils as part of the Call for Sites 2019". This submission does however include additional information relating to Green Belt and landscape appraisal, transport, heritage and biodiversity which should be read in conjunction with that earlier submission to demonstrate that the whole of the site is available, suitable and deliverable. This specifically addresses earlier comments set out at the time of the SHLAA (August 2013) including in particular highways and heritage matters. At that time it was concluded that the landscape impacts could be mitigated by retention of robust hedgerows and tree belt. This submission sets out why a blended spatial strategy including ‘Dispersal: Villages’ should be adopted, and why Land East of Bush Close, Comberton is a logical and sensible site to help deliver that strategy. As well as being read in conjunction with the March 2019 submission, this letter should be read in conjunction with the following accompanying documents:  Concept Masterplan  Green Belt Strategic Site Landscape Appraisal  Heritage Technical Note  Technical Note 01 – Transport and Highways Representations to the Greater Cambridge Local Plan For Hopkins Homes Spatial Strategy We consider that the strategy for locating new residential development should be a blend of the 6 identified options in the consultation. All have a role to play in helping meet the housing needs of Greater Cambridge whilst ensuring existing communities remain vibrant and preserving the most important aspects of our built and natural environment. Further development in villages such as Comberton, that has a Village College and sports facilities, Primary School, Surgery, Village Hall, Public House, two Churches, and a range of shops and employment opportunities should be a key part of a sustainable spatial strategy. Comberton has many of the attributes of a Rural Centre. Accessibility is also being improved as part of the Comberton Greenway and Cambourne to Cambridge Better Transport Projects – further details below. Outline planning permission (S/2204/15/OL) for the erection of up to 90 dwellings, car park, football pitch and changing facilities was granted in October 2016 on land at the western end of the village and this land was allocated as part of the South Cambridgeshire Local Plan 2018 (Policy H/1:h) "to provide a flexible and responsive package of sites that will best meet identified needs (paragraph 2.34 of the Local Plan 2018)". An assessment of the proposed site is set out in more detail below, and demonstrates that allocation of the proposed site at Bush Lane would help deliver a flexible and responsive package of sites that will best meet identified needs in the next Plan period to 2040 without significant harm. Importantly, as the National Planning Policy Framework makes clear, different sized sites can make an important contribution to meet the housing need of an area and, to this end, a three year build programme is expected, with construction able to commence shortly after the necessary planning consent is secured. The consultation sets out the following advantages and challenges of the 'Dispersal - villages' approach: Advantages: 1. Can help to sustain existing facilities and infrastructure in the village. 2. Can help provide for a diversity of population in the village. Challenges: 3. Can result in increased commuting by car, and travel to access to services and facilities, particularly if the village is away from main transport corridors. 4. Small sites are unlikely to significantly contribute to improvements to infrastructure so services capacity within or accessible to a particular village is important. 5. Potential impact on village character needs to be considered. 6. Some of the larger better served villages are surrounded by the Green Belt. In addition, it is considered that such an approach as part of a blended strategy: 7. Would provide for a mix of small and medium sized sites which would help diversify the number and type of housebuilders and thereby speed up delivery. Land East of Bush Close In terms of these advantages and challenges, the East of Bush Close development would: 1. Help sustain existing facilities and infrastructure in Comberton, and ensure that it remains a vibrant community; 2. Provide for a diversity of population and more housing choice in the village, and in the eastern part of the village; 3. Take advantage of planned proposals as part of the Cambourne to Cambridge Better Transport Project, including the Waterworks and Scotland Farm Park and Ride options, and the improved cycleway links to Cambridge as part of the Comberton Greenway Project, to limit commuting by car; 4. Whilst Comberton already has a Village College (and has recently consulted on plans to increase the PAN from 240 to 270) and sports facilities, Primary School, Surgery, Village Hall, Public House, two Churches, and a range of shops and employment opportunities, the development could make contributions towards health and/or education if necessary to mitigate the impacts of the development. 5. Not have a significant impact on the village’s distinctive character or setting as demonstrated by the submitted Heritage Technical Note, Green Belt Strategic Site Landscape Appraisal and indicative masterplan – see further detail below. The development would provide a more sustainable and sympathetic boundary to the site and the overall settlement edge (paragraph 5.9 of the Green Belt Strategic Site Landscape Appraisal). 6. It is acknowledged that, before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the Councils should be able to demonstrate that they have examined fully all other reasonable options for meeting the identified need for development (paragraph 137 of the NPPF). It is though considered important for a review of the Green Belt boundary to be part of the preparation of the Local Plan. When drawing up or reviewing Green Belt boundaries, paragraph 138 of the NPPF highlights the need to promote sustainable patterns of development. This needs to include maintaining the vitality of the better served villages such as Comberton through the consideration of new allocations. Furthermore and significantly, allocation and development of this site would provide more recognisable and more permanent boundaries to the Green Belt than at present (as advocated by Paragraph 139 of the NPPF). Paragraph 139 of the National Planning Policy Framework states that “When defining Green Belt boundaries, plans should: ….f) define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.” In this instance, the byway along the eastern boundary of the site and Tit Brook along the southern boundary are more recognisable and permanent physical features than the existing village boundaries (southern boundary of Swaynes Lane development and eastern boundary of Bush Close development). The Green Belt serves five purposes: a) to check the unrestricted sprawl of large 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. The submitted Green Belt Strategic Site Landscape Appraisal sets out a detailed analysis of the site and concludes in Table 1 that the site makes only a limited contribution to Green Belt purposes. The report concludes at Paragraph 3.19 that “…the Site could be released from the Green Belt and that a sensitively designed residential development can be successfully integrated into the Site without resulting in unrestricted sprawl or significant encroachment into the wider Green Belt with the enclosure provided by the existing robust mature vegetation and nature of the landform any development within the Site would have no effect on the openness of the wider Green Belt”. In terms of the functions of the Green Belt, in particular, the enclosure provided by the byway and brook would restrict the extent to which the proposal would be perceived to ‘sprawl’; the development would not lead to towns (or any settlements) merging into one another; and through the proposed landscaping that could be incorporated into the development, development could ensure that the setting and special character of Comberton and Cambridge are, as a minimum, preserved. Moreover, as part of a blended strategy that included urban regeneration to meet the identified need, the release of Green Belt land in this location would not prejudice urban regeneration. 7. In summary, a development of circa 100 dwellings as part of a blended spatial strategy provides the opportunity for diversification in the number and type of housebuilders to ensure timely delivery of the housing required. Highways At the time of the SHLAA (August 2013), SCDC were not satisfied that it was possible to provide safe highway access to the site linked to the adopted public highway. The submitted Technical Note 01 – Transport and Highways demonstrates that safe highway access to the site can be provided and that the existing Byway Open to All Traffic (BOAT) can be upgraded to provide a link to the surfaced road providing access to Thornbury. Heritage The submitted Heritage Technical Note demonstrates that there are no overarching heritage constraints that would preclude the allocation of the site, and that the whole of the site could be developed. Whilst the southern part of the site is the most sensitive part, having the fullest views of the Grade I listed Church of St Mary, sensitive development here utilising larger, detached dwellings, surrounded by a greater extent of open space and planting, and with views retained through to the Church “is likely to minimise any harm, or potentially remove it entirely” (paragraph 6.5 of the Note). Ecology A Phase 1 Ecology Report has been carried out by Aspect in January 2020, which concludes that the site itself, comprising a single grassland field is unlikely to comprise an important ecological feature and should therefore not form a constraint to development. Any habitats of elevated value are restricted to the site boundaries. The Phase 1 Ecology Report identifies potential for a small number of faunal species, and therefore further Phase 2 surveys would be undertaken in the event that a planning application is progressed. In the event that species are found, the report identifies appropriate mitigation that could be implemented. It also highlights the potential for ecological enhancements on the site, which could include: Native planting along retained hedgerows to increase species richness. Diverse native grassland could be created adjacent to these hedgerows and watercourse to increase their functional width as wildlife corridors; Incorporating wildflower grassland within SuDS basins, whilst the opportunity to incorporate permanent standing water should also be explored; Incorporating high yielding nectar and pollen species within the planting strategy; Incorporating within the landscaping strategy, plant species that absorb pollution; Incorporating planting strips along bases of buildings; Incorporating appropriate native planting within amenity areas and shared spaces; Incorporating ground-level cut-outs in garden fences for Hedgehogs; Incorporating bat roosting and bird nesting opportunities within new buildings / on retained trees; Incorporating bee bricks within new buildings, providing nesting opportunities for solitary bees; Incorporating bug hotels, brash piles and refugia within areas of open space, providing nesting and sheltering opportunities for a range of species including invertebrates and reptiles; and Incorporating bat-sensitive lighting. As such, there are not considered to be any ecological constraints that should prevent this site from being allocated for residential uses. Utilities and Flood Risk Utilities The site is within close proximity to existing statutory provider assets in order that the site may be serviced by electricity, water and telecommunications. There are existing overhead HV cables the cross the development site which would be diverted below ground as part of the development. This will provided for the point of connection of HV to serve a substation which would provide low voltage supply to the site. The exact point of connection details would be confirmed with UKPN. There are existing water mains present along the B1046 and within the existing byway. The site would take the nearest point of connection to the existing water mains and via zonal charging, any required reinforcement would be delivered by Cambridge Water as the statutory undertaker of these mains. For sites over 30 units Openreach provide connection of fibre to the property (FTTP) at no cost to the developer. There is no gas available in Comberton therefore all heating and hot water will be provided via other means, potentially air source heat pumps. Drainage Foul Water - There are existing foul water sewers present within the access road to Thornbury and on the B1046 which could provide a point of connection for the site. Anglian Water will be consulted to confirm the exact point of foul water connection and any reinforcement work required will be undertaken by Anglian Water via zonal charging. Surface Water – At present the site is a Green field and therefore the natural drainage mechanism has been reviewed. Currently the site falls generally towards the Tit Brook and the brook forms the southern boundary of the site. The Greenfield runoff rate will be assessed and proposed surface water flows will be directed to the brook at a maximum discharge rate to reflect that of the present greenfield runoff. As such, attenuation of flows will be provided in the form of an open basin SuDs feature along with additional SuDs solutions where space permits to store flows over and above the greenfield discharge up to a critical design storm event of 100yr + 40% climate change, with adequate freeboard to accommodate a further 10yr storm within 24 hours. Water quality will be controlled using SuDs features such as swales, permeable paving and filter drains, and will be determined further as the drainage strategy is developed. Flood Risk Based on the Environment Agency flood mapping for fluvial and coastal flooding the site is located within Zone 1 and is at a low risk of flooding. Surface water flooding of the site has also been considered and there are extents of low risk surface water flooding along the northern and southern boundaries of the site along with small isolated areas of high risk. In order to manage flood risk for the proposed development the development proposals will avoid the areas of surface water flooding as far as is practicable. Where necessary floor levels will be raised above existing levels to prevent flooding of properties and necessary compensation volume provided. In the most part the depth of surface water flood is below 300mm.

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PREAMBLE This is the response of the Cam Valley Forum to your invitation to comment on the issues to be considered in the plan. The forum, a voluntary organisation, works with many other organisations to protect and improve the river Cam and its riversides, including its many tributaries and its sustaining aquifers. This response focuses mainly, therefore, on our concerns for the future of the river and its environment. However, since as individuals and as a group, we are also concerned about the city and its environs, we are not confining our comments to river-related issues alone. The river Cam is an invaluable, but vulnerable, natural asset to the environment of Cambridge and South Cambridgeshire. Cambridge without its river would not be all that it is. The river and its tributary streams bring threads of wildness through an intensively farmed countryside as it flows north. Its riversides contain and connect with many important wetland habitats. Its wetlands hold still elements of the wildlife most typical of this lowland region. Importantly to the whole planning process its waters are enjoyed by rowers, punters, boaters, canoeists and swimmers, while many more people enjoy walking, picnicking or angling from its banks. Visitors from far and wide come to experience the world-famous Cambridge Backs. The river, however, is damaged and vulnerable to further damage. The Backs, in particular, suffer from being congested with too many punts. To many of our citizens the tourist pressure on the River is overly exploitative of our iconic City's environment. Throughout its catchment the river and its wildlife suffers from poor water quality. Environment Agency data indicate that only three tiny tributaries in the upper reaches have ‘good’ water quality, the rest of the river system is ‘moderate’ to ‘poor’. This reflects not just the pollutants that find their way into the river, but also the reduced level of natural flow. For a premier City in Europe aiming for truly sustainable living this is a fact that our citizenry should to be ashamed of. We must do better Flows in the river have been declining for many years, as a result of increasing abstraction from its Chalk aquifers to meet the demands of the rapid growth of employment and housing. Thus in September 2019 the River Granta ran completely dry, as did Nine Wells, our historic source of water. The river Cam is largely fed by Chalk springs. These flow as streams into its main tributaries, the Granta, the Cam and Rhee. When the springs run dry much of the flow is contributed by treated sewage effluent alone. This aquifer is now acknowledged to be over-licenced for water abstraction.. The Environment Agency currently estimates that, in 2019-20, we will need 160% of the mean winter rainfall to recharge our aquifers to normal levels. Present groundwater is thus used unsustainably. We have a groundwater crisis that we have been slow to recognise. Increasing demand for water and the real impact of hotter summers both genuinely threaten the very existence of the river Cam itself. Although the River Cam is a designated County Wildlife Site in recognition of the river's importance in linking semi-natural habitats we would urge that the whole River Cam be given the highest conservation status to safeguard all its benefits to both people and the environment.

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1. The Big Themes The forum agrees that all four key issues are vitally important, but that the threats of climate change and declining biodiversity, which are intimately related, are of overriding importance. There is a tendency to give lip service to sustainable development without recognising that we humans are part of the ecosystem. All the policies and proposals of this local plan need to be appraised rigorously, in the light of their potential to counteract or exacerbate these threats to environmental sustainability. Thus the human water supply (locally through the Cambridge Water Company) and the River’s own water supply (from the groundwater Chalk aquifer) are the same. Why do our rivers run dry before we even ask people to save more water? Where is the prudence that builds up resilient infrastructure? Many any of us deeply question the intelligence and prudence of this headlong rush to unending local growth that is overly driven by greed rather than need. With respect to climate change there is ample evidence of changes in temperature and atmospheric carbon, but there is very limited evidence to date of great changes in rainfall itself or of the rainfall changes predicted in 4.1. These are possibly national predictions but may not apply to this drier eastern region.

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2. Level of growth The forum is particularly concerned about the assumption in your explanatory document that the current fast rate of growth will continue or even accelerate. The plan should aim to guide change, not simply accept it. The pressures on the quality of life in the centre of Cambridge, and the congestion of the river, call for effective measures to restrain the growth of tourism in the city. The impending water crisis suggests the need to restrain, rather than to promote, the current rate of employment growth within the plan area as a whole. Environmental limits must be respected. More is not necessarily better.

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3. Location of growth We accept that there will be need to accommodate further housing and related service developments in a variety of locations, but the location of essential new developments should be subject to the following considerations: No development should be allowed which: • Adversely affects the river and its tributaries, its sustaining aquifers, land liable to flood, and river-side green spaces. • Adversely affects the chemical or biological condition, or the temperature of the river’s waters. • Adversely affects any nature reserve, woodland and semi-natural open space. • Erodes the areas of best landscape, from the south-east to south side of the city. In particular there should be no further development on the green space between the Biomedical Campus and Nine Wells Nature Reserve. It is vital to protect this sensitive reserve, and it is important to maintain the views of the hillsides above that give pleasure to many and, not least, help sustain the morale of patients in Addenbrooke’s Hospital. The plan also needs to identify areas for environmental gains, especially recognising the importance of the water environment. • The plan should map a ‘nature recovery network’ as a framework to guide essential development. Water and water sources are a vital part of this connectivity, as are drains, streams, rivers, lakes and ponds. A ‘nature recovery network’ must include these aquatic elements at the same time as identifying new large-scale areas for habitat creation, including new woodlands and areas of natural regeneration, and opportunities for linking them all together. • The plan should recognise that ‘flooding’, which will be increasingly likely with climate change, can be mitigated upstream by slowing river drainage. This ‘natural’ approach would require a reversion to an earlier pattern of agricultural land-use management with wet meadows and less arable land in the flood plain itself. Some river valley farmers are already making this positive change. e.g. South Cambridgeshire could develop a larger flood plain with a wet woodland basin as a buffer against Cambridge City flood events. This wet woodland would impede rapid flow, so attenuating the flood, save water, sink carbon dioxide and ease soil erosion.

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4. Quality of development • All new developments should have the highest standards of water efficiency to minimise the use of water abstracted from the chalk aquifer, including use of rainwater and greywater recycling, and permeable paving. Large new developments should incorporate sustainable urban drainage systems to help water percolate back into the soil. • Opportunities for new tree planting should be maximised within new developments and in existing developed areas, recognising that trees help to not only absorb carbon dioxide but also reduce air pollution, help to cool urban areas in summer, and improve the landscape for all to enjoy. Careful consideration needs to be given to the choice of appropriate species. • New development should maximise use of renewable energy generation, passive heating and cooling. • With respect to reducing flood risks, especially in Cambridge City itself, were a large wet woodland basin to be encouraged upstream of the City, such an area could additionally provide needed recreation space for people and would undoubtedly help to increase the biodiversity of Cambridgeshire’s wet woodland habitats. • Well-being, health and recreation are central to the planning process for our future population. The scenery - beauty, tranquility and atmosphere - of being by a stream or river is worth everything to people whose lives are oppressed. The worth of our environment for this alone merits the highest conservation status.

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5. Transport Radical changes are needed to reduce the reliance on the use of cars, especially within Cambridge to improve local air quality and contribute to reducing the use of carbon-based fuels. The plan should identify: • potential routes for a strategic joined-up network of cycle paths. • potential traffic free areas. Where any footpaths, cycle ways or roads are planned to cross or go beside rivers, steams or conservation wetlands consideration needs to be given to:- • The reality that on narrow tow-paths or footpaths by the river cyclists may be a real hazard to pedestrians and dog-walkers. • The importance of safer cycle ways, which if allowed to be used by pedestrians need to be made much wider for safety reasons. • The fact that rivers are a natural corridor for wildlife and should be neither overly disturbed nor polluted in any way. • The scenic merit of the river and its heritage importance, which should always be most carefully considered.

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Response to Question 2 2.1 Our client, Martin Grant Homes Ltd, are promoting ‘Land at Ambrose Way, Impington’ for residential development and allocation in the emerging Greater Cambridge Local Plan. As demonstrated by the submitted Framework Plan it is currently estimated that the Ambrose Way site has a capacity of up to 190 dwellings. 2.2 The site was promoted by Martin Grant Homes Ltd through the 2019 ‘Call for Sites’ exercise. Since this initial promotion our client has undertaken significant technical work to address site constraints and further development the indicative proposals. The additional technical work is summarised in an updated Site Promotion Document which is submitted alongside these representations. The following technical reports are also provided at this time to demonstrate the sustainability and suitability of the site for release from the Green Belt and subsequent allocation for residential development. - Overview Transport Strategy - prepared by iTransport - Drainage Position Statement - prepared by PFA - Green Belt Appraisal - prepared by EDP - Landscape and Visual Appraisal - prepared by EDP - Archaeology and Heritage Assessment - prepared by EDP - Ecology Briefing Paper – prepared by EDP 2.3 The above listed reports and the Framework Plan provide robust site-specific evidence to inform the Councils’ review of the Ambrose Way site when the Strategic Housing Land Availability Assessment is completed. 2.4 The suitability and sustainability of the Ambrose Way site is also set out in these representations; along with details of how the site can be released from the Green Belt and then allocated for development to complement the sustainable spatial distribution of growth in the GCLP area.

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See call for sites form submitted previously as part of the 2019 call for sites - Land off Comberton Road, Toft Summary of Comments: See call for sites form submitted previously as part of the 2019 call for sites - Land Off Comberton Road, Toft

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Paragraph 5.2.1: Summary: Wyton Airfield in Huntingdonshire is already contracted for mixed use development and is not available for the relocation of Cambrige Airport. Full Text: We (ENGIE Services Limited) are contracted developers of the first phase of the development of the former RAF Wyton airfield. Paragraph 5.2.1 and Question 44 of the Issues and Options document relates specifically to the redevelopment of the Cambridge Airport site. The owners of Cambridge Airport, Marshall Group (MG), confirmed an intention in early 2019 to move the company’s operations to a new location by 2030 and that, following further updates, the airfields at Wyton and Cranfield were under consideration as preferred options. MG further undertook publicly to work with these locations to assess each site’s feasibility and signalled its intent to the local authorities and other key stakeholders to put its current Cambridge Airport site forward for development as part of the next Local Plan from 2030. The opportunity for co-location with our development and MG is unfeasible for both organisations. A lack of commercial viability for relocation to RAF Wyton has already been confirmed by MG previously when relocation to RAF Wyton was proposed in 2010. MG's relocation proposals to RAF Wyton are not deliverable and are incompatible with the proposed mixed-use residential development of the site for which it is contracted. We therefore consider that significant adverse weight should be attached to the credibility and robustness of any development proposals reliant upon relocation of Cambridge Airport to RAF Wyton.

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Question 2. Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Land to the west of Malton Rd, Orwell was submitted to the Greater Cambridge ‘Call for Sites and Broad Locations’ in March 2019 as a Site which could deliver up to 155 residential units. We continue to support its promotion as the Site is deliverable in accordance with the National Planning Policy Framework (‘NPPF’).

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Summary: Savills (UK) Ltd are instructed by Mr John Jarman, Mr Geoff Jarman and Ms Coral Henshaw to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the north of Chestnut Road, Bassingbourn-cum-Kneesworth Full Text: Land to the north of Chestnut Road, Bassingbourn-cum-Kneesworth, was submitted to the Councils’ Call for Sites in March 2019 for residential development. A copy of this submission is enclosed at Appendix 1. In summary: • Extending to 5.32 hectares the site can accommodate in the region of 86-110 homes subject to further design analysis and assessment. • The site is in walking and cycling distance of key facilities in Bassingbourn-cum-Kneesworth which include a primary school, secondary school, convenience store and post office, a doctors surgery and small local shops including a bakery, coffee shop and pharmacy. • The village is located just 2.5km north of Royston to which it is connected by a footway/cycleway. • There are no heritage assets on the site and the site is not in an area of valued landscape nor is it located in the Cambridge Green Belt. • Potential for extensive landscape buffering around the boundaries of the development in order to achieve a ‘soft’ transition and screen the development from views from the north and east. • Provision of a circular walkway, linking to the public right of way to the west of the site. • Access to the site can be taken from Chestnut Road (A1198) which provides access to Cambourne and the A428 to the north, and Royston and the A10 and A4505 to the south.

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Response to Question 2 - ADDITIONAL INFORMATION Land r/o no. 7 St Georges Court, Impington was promoted through call for sites process in March 2019 on behalf HRB Properties Ltd. A site plan is attached. The proposed development would provide additional housing and affordable housing for Impington. Impington is surrounded by the Green Belt, and there are limited opportunities for infill development within the settlement boundary, and as such a very limited amount of housing and affordable housing will have been provided in the village in recent years. The proposed development would include open space and landscaping, which would also provide ecological benefits. The woodland to the rear of the site would be retained as part of the proposed development. The proposed development would support the existing services and facilities in Histon including convenience stores, public houses and bus services, and provide much needed affordable housing. The Site is well related to the existing built form of Impington and closely located to a number of existing local services and facilities. The site has access to local employment opportunities and has excellent public transport links, with a bus stop located closeby. The existing level of services and facilities in the village make the village a sustainable location for a larger population, where job opportunities and facilities are close by. The site could accommodate approximately 9 dwellings which reflects the edge of settlement, the neighbouring woodland and other uses, and the current Green Belt location. This could include singe and one and a half storey dweliings to minmise the impact on the greenbelt. The development would also bring demonstrable social benefits in that it would be accompanied by a policy-compliant level of affordable housing. Social Benefits • Deliver much needed market and affordable housing, making a material contribution to the supply of housing within South Cambridgeshire District and within Great Abington. • Provide affordable dwellings, which equates to 40% of the total housing. • Provide a choice of high quality homes to meet local needs in a manner that can achieve sustainable growth and quality design. Environmental • Provide additional strategic landscaping, woodland planting, green infrastructure and open space to enhance the surrounding landscape. • Provide enhanced habitats that will improve the ecological value of the land. • Promote sustainable forms of transport by including walking, cycling and public transport infrastructure and facilities, which connect to the existing networks in the surrounding area. Economic • Provide employment opportunities, including local construction jobs. • Provide housing for employees. • Reduce commuting distances. A density of 15 dph would result in the capacity for 25 dwellings.

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JDi No - 40703 I write in response to the Issues and Options consultation in respect of the draft Greater Cambridge Local Plan. Orchestra Land is working with the owner of land south of Chestnut Lane, Bassingbourn cum Kneesworth to promote residential development as part of the emerging Local Plan. The Issues and Options consultation on the Greater Cambridge Local Plan is focused around a number of key themes and I have included below some commentary for the Chestnut Lane site in respect of each of the relevant themes. Climate Change Climate change is rightly a priority for the forthcoming Local Plan and new development will need to play its part in mitigating and adapting to climate change. In respect of this site, Orchestra Land would support a high level of energy efficiency in the new development and we would seek a developer with experience using air-source heat pumps, photo-voltaic panels, triple glazed windows and energy efficient products which limit the long-term impact of development. The emphasis on maximising the use of low-carbon transport is recognised, although should not necessarily prevent development in villages. With the growth in electric vehicles, development in smaller settlements can still play a role in mitigating climate change. There is an existing bus service through Bassingbourn cum Kneesworth to Royston and developer contributions from the Chestnut Lane site could be used to enhance this service, to the benefit of all local residents. Chestnut Lane has a good deal of tree coverage around the boundaries of the site and Orchestra’s development proposal will look to retain and enhance this boundary planting. Biodiversity and Green Spaces The Chestnut Lane site is made up of an open field and part scrub land with a small area at the south boundary designated as non-coniferous wood. It is not subject to any specific wildlife designations and apart from the nonconiferous wood there appears to be no features of notable ecological interest within the site. Further survey work will be undertaken in due course to explore this issue in more detail. As mentioned above, tree planting around boundaries of the site would be retained and enhanced. Open space would be provided on the site with the location to be determined. Additionally, new habitat creation will ensure an overall net gain in biodiversity. Wellbeing and Social Inclusion The emphasis within the consultation material on community involvement in development proposals is welcome. Orchestra Land welcome the prospect of early consultation with the local community as part of the preapplication process. In terms of social inclusion, the development would promote a range of sizes and tenures of new homes. We would welcome a discussion with you about the particular housing mix that the Council would want to see on this site. Additionally, we would seek to establish a new foot path along Chestnut Lane up to Hill View Farm shop and thereby provide easier access to the existing and new residents. Great Places The commitment to design quality in the consultation material is welcomed. Orchestra Land will select a developer with a proven record of high design quality. Infrastructure The provision of appropriate infrastructure is an important consideration to Orchestra Land as it is a key issue for potential purchasers. Appropriate developer contributions will be made through the normal channels but we will also be exploring if there are particular infrastructure issues in the village that development could help address. As mentioned earlier, Orchestra Land will propose the provision of a new footpath along Chestnut lane which would link existing and new residents with Hill View Farm shop situated immediately east of the site. Development Options You will be aware that Kneesworth is designated as Infill Village in adopted South Cambridgeshire Local Plan. As such, while unlikely to be a focus for strategic scale growth, modest growth is appropriate and would help support and sustain important local services. The Chestnut Lane site measures just over 1 hectare. The developable part of the site measures just under one hectare and as such would be suitable for a development of around 28 dwellings (indicative). Orchestra Land would be open to hearing views on this number of dwellings from the council.

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We act for, Anderson O&U Limited, an operating subsidiary of the Anderson Group, and the owners of Land South of Coldham’s Lane, Cambridge (“the Site”). Their ownership includes the majority of the undeveloped land identified at Policy 16 of the adopted Cambridge Local Plan 2018, as South of Coldham’s Lane Area of Major Change (see attached Land Ownership Plan). Policy 16 sets out that the Council is seeking the wider regeneration of this Area of Major Change, with appropriate redevelopment (commercial uses) and the creation of an urban country park to serve the east of the city. This Policy advocates the development of the Site, which is currently underutilised land in the existing urban area. On behalf of our client, we submit representations to the Regulation 18: Issues and Options consultation version of the Greater Cambridge Local Plan. We understand that the purpose of the consultation is to explore the big themes that will influence how homes, jobs and infrastructure are planned. It also looks at how engagement with communities, neighbouring local authorities and other important groups will be coordinated. Our client’s Site has the potential to contribute significantly to the key objectives of the emerging development plan. The ‘big themes’ The consultation document (Section 1) explains the four big themes which are considered central to future development across the Greater Cambridge Local Plan area. The four themes are:  Climate change  Biodiversity and green spaces  Wellbeing and social inclusion  Great places Our client is supportive of the general principles of the four ‘big themes’ and the growth in the number of homes and jobs which should be accommodated over the Plan period. The identified options for growth consider the potential to utilise underused land in existing urban areas, develop the edge of Cambridge (within or outside of the Green Belt), creation of new settlements, or directing new development to existing villages and along public transport corridors. Whilst the Local Plan sets out these concepts in high level spatial terms only at this stage, it is important that the proposed options for positive place making and continued economic growth align with wider strategic opportunities, especially in respect of key infrastructure such as highways and public transport. Employment Land At Section 4.5.3 of the Issues and Options document, it identifies that protecting existing employment land is an important matter for local residents. The Site is subject to an existing designation in the Adopted Development Plan, with Area A identified for commercial uses. A planning application for development has not yet been submitted. It should be noted that Land South of Coldhams Lane Area of Major Change (Policy 16) – Area A - is not identified as an existing employment site on Figure 24 (Existing planned growth in the adopted 2018 Local Plans) in the Issues and Options draft. We presume that this is an administrative error. It is requested that this allocation is included within any future diagrams and policy documents, to accurately reflect the adopted planning policy position for the Site. The Issues and Options document considers the unique employment opportunities in Cambridge, including traditional office, industrial and warehouse space, alongside education, technology, innovation and small ‘start-up’ businesses (Section 4.5.3). The Plan identifies that a wide range of employment opportunities should be provided for, with spaces which are adaptable and respond to fast-changing working practices. We support the principle of a flexible approach, and believe that the Council should carefully consider the type of employment space and where it is located. Whilst we support the continued identification of existing allocations, we consider that these should be re-evaluated in the context of the potential to create longer term mixed use developments across the Greater Cambridge area where people can live and work thereby maximising the limited opportunities available. Housing The Issues and Options document utilises the Governments ‘standard method’ in order to calculate the anticipated housing need over the Plan period. The Council have calculated a need for 40,900 homes for the suggested plan period of 20172040 (1,800 per annum). The Cambridgeshire and Peterborough Independent Economic Review (CPIER) showed that recent job growth had been faster than expected, and that growth is likely to continue. As a result, demand for new housing has been exceptionally high. The Council’s indicative calculation based on CPIER suggest that if the forecast jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,700 homes over the Plan period. This is significantly higher than the allocations already identified in the 2018 adopted Local Plans, and the calculated need using the Government’s standard methodology. This target housing figure is therefore likely to be subject to change as the Plan preparation progresses. Question 32 of the Issues and Options consultations asks if the Council should plan for the additional number of homes, to support the growing economy. We believe that the Councils should utilise its evidence base to determine the number of homes required. Should this evidence that significantly more dwellings are required over and above the Government’s standard methodology, the Councils need to carefully identify additional sites at an early stage, which are available, deliverable and do not result in the inappropriate release of the Green Belt. The Council’s should avoid the need for an early review of the Plan. The Issues and Options document (Section 4.6.3) notes that the Council’s current pipeline forecasts do not include the Cambridge Airport site, which could provide a significant number of new homes. This site is located directly to the north of Coldhams Lane, opposite the land owned by Anderson O&U Limited. Should the Council proceed with an allocation for the Cambridge Airport site, we would suggest that it would present an opportunity for a holistic approach to the strategic planning of this area on the edge of Cambridge including our clients land as part of a wider mixed use, residential led development. The Land south of Coldhams Lane is surrounded by a mix of residential and employment uses, hence it is suitably located to compliment the wider Cambridge Airport allocation, as these proposals develop. Adopting a holistic approach could also give rise to a range of alternative Infrastructure, place making and sustainability options. Approach to Locating Development The Council’s historic approach has been to focus development on previously developed land, and sustainable locations on the edge of Cambridge. As part of the Issues and Options consultation, Section 5.3 looks at options for growth. In particular, option 5.3.2 Edge of Cambridge – outside the Green Belt is of relevance to the Land South of Coldhams Lane. We support the opportunity this option brings to create a holistic extension to the edge of Cambridge, with new homes and jobs. We would welcome the opportunity to propose how mixed use development and transport infrastructure improvements could be brought forward in a comprehensive manner, to the north and south of Coldhams Lane. Closings These representations made on behalf of Anderson O&U Limited seek to ensure that the Greater Cambridge Local Plan appropriately represents existing relevant policy allocations, and delivers a robust and effective strategy for delivering new development over the Plan period. Our primary points are:  We support in principle the four key themes and the Council’s approach to place-making;  We would highlight that Land South of Coldham’s Lane is not shown as an existing employment allocation (figure 24) and respectfully recommend that it is included in future iterations of the Local Plan;  We support the Councils intent to encourage a range of employment opportunities and the need to respond to fast-changing working practices;  In respect of housing numbers, we encourage the Council to complete further evidence based assessments on housing numbers, which plan appropriately for the future, taking into account the Government’s standard methodology and planning beyond this where supported by the evidence base; and  Supports the identification of the Cambridge Airfield site (subject to it being available and deliverable) and would highlight the potential for a complimentary design approach to mixed use residential and employment development with appropriate infrastructure improvement, to the north and South of Coldhams Lane. We trust that the above comments are of use in the formulation of the Local Plan preparation. Please ensure that we are on the Council’s consultation register.

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Our client, who is the landowner of several sites in Graveley, has instructed us to make the following comments on their behalf in respect of the Greater Cambridge Local Plan Issues and Options Consultation. One of the big themes outlined in the Local Plan Issues and Options 2020 is climate change. Achieving net zero carbon is an important consideration in the preparation of the Local Plan. The sites in Graveley were put forward as part of the Greater Cambridge Local Plan Call for Sites undertaken in Spring 2019. The sites provide an infill opportunity in Graveley and the homes would be efficiently designed. The sites can accommodate tree planting which will also create biodiversity net gain, another important big theme. The Issues and Options Consultation also identifies wellbeing and social inclusion as another big theme, especially in rural areas where people have limited access to services and transport. Enhancing the vitality of villages is supported by Paragraph 78 of the National Planning Policy Framework and the development of the sites in Graveley will enable homes and enhance the setting and spirit of the village through much needed housing providing environmental and social benefits. As set out in the Local Plan Issues and Options, the cost of renting or buying a home in Greater Cambridge is much higher than the national average. If the Local Plan does not make provision for a larger quantity of housing this will be exacerbated. To achieve this, the Council must set itself an ambitious housing target for the plan period. The Government’s Standard Methodology fails to consider changing economic circumstances in its calculations. Considering Greater Cambridge is at the heart of the Oxford-Cambridge Arc, the UK Innovation Corridor and the Cambridge-Norwich Tech Corridor, all of which will transform the regional economy, it is imperative the Councils plan for a higher number of homes than the minimum required by government. The type of housing provided should be informed by the Strategic Housing Market Assessment. It is also important to note that Paragraph 68 of the National Planning Policy Framework requires councils to identify 10% of their housing need on sites of 1 hectare or less. Land within and adjacent to villages such as Graveley is perfectly suited to meeting this requirement.

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