Notwithstanding my comments above about the need to absolutely minimise any development in the rest of the rural area, I do not object to any of the specific allocations proposed within the First Proposals.

What I (and many many others I know that do not have the time to respond to such a hugely detailed consultation) do object to is:

• In general, allocations that would impact the Green Belt in any way
• A set of specific site proposals that have been rejected by SCDC, but would cause untold harm if they were ever to be incorporated as part of this or any future local plan.


In relation to the first point, the First Proposals state that: “The Councils consider that the carbon benefits of locating homes close to existing opportunities for very high quality sustainable travel, could provide the exceptional circumstances required to justify removing land from the Green Belt in this location but only if considered alongside the environmental impacts.” I fundamentally disagree with this point for the reasons set out in my general comments on the rest of the rural area. “Exceptional circumstances” should be just that, not “these locations happen to have nearly as good transport links as other site locations that do not form part of the Green Belt”.

In relation to the second point above, the specific site proposals I refer to are those with site references / JDI numbers as follows:

• 40041 – Kings Gate site, Villa Road, Impington
• 40232 – Land west of South Road, Impington
• 40236 – Land north-east of Villa Road, Impington
• 40239 – Kingsgate Land off Villa Road, Impington

Each of these self-serving site proposals would cause significant damage to the local community and environment and none offer anything that cannot be far better achieved at other site locations (as the First Proposals appear to correctly recognise). Main concerns common to these sites include:

• All lie wholly (or at least 98% or more) on Green Belt land
• All would result in material damage to the Landscape and Townscape, resulting in a Red flag for this criterion in the HELAA report in all 4 cases. As noted by the HELAA report, this area of Green Belt land is “typical” of the “Fen Edge” character, and there is no getting away from the fact that a development of any of these sites would cause this to be lost.
• All would result in a huge relative increase in traffic volumes on currently quiet residential roads (potentially through the South Road play area (destroying green open space) or Villa Road – both areas where small children play). The HELAA report recognises this through assigning Red or Amber flags for Site Access in all 4 cases.
• All would add further pressure on water and drainage in an area already prone to flooding (as the HELAA report notes, with Red or Amber flags)
• All would contribute to increased traffic load on the A14 North bypass (a strategic highway that is already over capacity), as the HELAA report recognises in assigning a Red flag to all 4 proposals in relation to the Strategic Highways Impact constraint. No matter what self-serving arguments land-owners put forward, it is a simple fact that large new developments of the type proposed in these areas cannot possibly lead to a net zero increase on traffic on the Strategic Highways, therefore these sites would appear to be worthy of automatic disqualification (all other issues, of which there are a lot, put aside)
• All would place more pressure on existing facilities such as the local GP and schools
• Two of the four site proposals are for 450 and 700 new houses (40232 and 40239 respectively). These large scale developments would be totally out of keeping with the rest of the village.

Taking each of these sites in turn, I provide a high-level summary of objections. I am happy to provide further details as required.

40041 receives a red flag from HELAA for flood risk. This is entirely correct, particularly given the Darwin Green development in Cambridge, that will already lead to increased flood risk in this specific area of Impington. This floor risk not only relates to new houses built on this land, but would also increase the risk for other nearby housing. Proposals from the land owners to mitigate this are inadequate, not least since there would be no obligation whatsoever for any mitigation measures to be maintained after the development was completed. Hence the problem is added to on an ongoing basis, but no ongoing solution (to the extent that there would be one) is offered.

For some reason the flag assigned for Site Access is only Amber (rather than Red). There seems to be an assumption that access via Villa Road is possible, but with the construction of two new self-build houses (perhaps only started since the publication of the HELAA report), this assessment now appears out of date. Moreover, the concern raised above about turning Villa Road, where children play and which has a blind corner, into a mainstream access road to a new housing estate (of any size) is important. Site Access simply cannot be achieved safely here and a Red flag is certainly required.

40232 suggests an outrageous 450 new homes on Green Belt land, totally disregarding the Histon & Impington Neighbourhood plan, which clearly states a maximum development size of 50 houses. Such an estate would be total out of character with the village and serve only to further line the pockets of NIAB, its estate agents and any developer it sells its land (at astronomical profit) to.

This notwithstanding, even a smaller development on this site would still be totally unacceptable for the reasons provided through 3 Red and 6 Amber flags in the HELAA report, amongst others. The flood risk is in this case assessed as Amber despite 29% being sited in a 1 in 100-year event flood area – given the increasing frequency of such events due to climate change, it is in fact likely to be much more than 29% and more frequently than once in the next 100 years: this should be a Red flag.

Transport and Roads is flagged Amber, though (akin to Strategic Highways Impact, which is flagged Red) it is unclear why this assessment is not also Red. There would be a huge impact on local residential streets, the B1049 as well as the strategic A10 and A14, which has “No capacity for growth”. Site Access though is rightly rated as a Red flag. The idea of creating a major transport route through the northern end of a children’s play area (one of what is already too few open spaces in Histon & Impington) is appalling, without even considering how narrow this road would be. The suggestion would be laughable were NIAB and its agents not actually serious in their outrageous proposition.

40236 again rightly receives the same Red flags for Landscape and Townscape and Flood Risk, as well as Site Access (i.e. there is none). For the same reasons as above, this proposal would also create an unacceptable traffic burden on local residential streets and nearby strategic roads.

40239 is however the most egregious of the 4 site proposals. It combines 40041 and 40232 to create a larger site, yet somehow the proposed number of houses increase from an aggregate of 500 for the two separate sites to a whopping 700. No logic for this further increase appears to have been offered. The HELAA appears particularly flawed in relation to this site as it classes the flood risk as only being Amber when it is Red for 40041 in isolation. One can only assume this relates to the density of housing across the whole site, but ultimately there would not be fewer than 50 houses built on the 40041 site under this proposal because the total number of planned houses is greater than the aggregate proposed under 40041 and 40232. In particular, since the two constituent sites are owned by different companies, the owners of 40041 will still want to see at least 50 units on their portion of the site, which is already enough to warrant a Red flag in the separate assessment of that site. The fact that there would be 650 additional houses on the combined site cannot possibly reduce the flood risk from Red to Amber: in fact it exacerbates it, making the requirement for a Red flag classification all the more clear.

Site access is flagged Amber, but as explained for 40041, this appears outdated and should now be Red. Whilst the impact on Transport and Roads of such a big site must now surely be upgraded to Red flag status.

In all cases, the fact they lie (almost) entirely on Green Belt land should constitute a Red flag, but as is described in relation to policy GP/GB, the HELAA does not seem to adequately take this into account. All 4 sites receive an Amber flag for the “Adopted Development Plan Policies” criterion, which mentions the Green Belt. If impact on the Green Belt is intended to be captured here then the flag should be Red.

As a general point regarding the HELAA, it seems that obtaining 1 or more Red flags is the disqualification threshold for a site, so Amber flags seem in the end to count for nothing. All 4 of the above sites contain between 2 and 4 Red flags in addition to between 6 and 9 Amber flags. The total number of Red and Amber flags is 10 or 11 in all cases, so the one site with only 2 Red flags contains 9 Amber flags, though as argued above more of these should in fact be Red. However, the point is that were a site not to have any Red flags, but had 6-9 Amber flags, it would surely not in practice be a suitable site for development. The Amber flags should cumulatively form an additional disqualification criteria, such that whilst 1 Red flag is cause for disqualification, the same should be true for 2 or more Amber flags. On a site with 2 Red flags and 9 Amber flags, this would mean that there are in fact 6 separate reasons for disqualification (each by itself sufficient to require disqualification) – i.e. each of the 2 Red flags plus 4 additional pairs of Amber flags.

Finally, I note that a response to the 2020 First Conversation consultation from agents Strutt & Parker, on behalf of NIAB, makes various additional comments on the site proposals (40232, 40236 and 40239). These comments are once again entirely self-serving and seek to promote even greater scales of development in the Greater Cambridge area, a fundamental revaluation of the Green Belt (since it does not suit their specific purpose, but without any regard for the purpose it does continue to serve) and make various comments about encouraging walking and cycling in an effort to partially mitigate the impact their developments would have on strategic highways (whilst in no way offering any evidence as to why they would offer a net zero increase in traffic – which they can’t offer because it is simply not true). This response makes no effort and offers no evidence to address any of the fundamental concerns raised by the HELAA report (or those missed by the HELAA report) including on site access, flood risk, traffic increases etc.

These sites appear to fall so far short of any reasonable threshold for inclusion in the local plan that they are worthy of no further consideration whatsoever, now or in the future.