Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56814

Received: 05/12/2021

Respondent: Mr Mark Colville

Representation Summary:

I strongly support the protection of the Cambridge Green Belt.
Any erosion of the Green Belt will result in a reduction in its ability to achieve its primary purpose to “prevent communities in the environs of Cambridge from merging into one another and with the city”, as well as its other purposes.
At the very least the Green Belt Assessment report rating system should be used and any parcel of land forming part of a site proposal that received a “Very High”, “High” or “Moderate High” harm rating in the Green Belt Assessment should receive a Red flag in HELAA.

Full text:

I strongly support the protection of the Cambridge Green Belt. Enhancement is also fine in the way described in this policy, but must never be confused with development of the Green Belt. Developers and land owners will make many (entirely self-serving) arguments about the sustainability benefits of developing the Green Belt. However, these arguments are all entirely without merit. In rare instances where some small pockets of Green Belt land may benefit from some form of rejuvenation, this should never mean housing (or other forms of) development. Such development ruins the character of the Green Belt and undermines its very purposes, as set out in the policy definition.

Any erosion of the Green Belt will result in a reduction in its ability to achieve its primary purpose to “prevent communities in the environs of Cambridge from merging into one another and with the city”, as well as its other purposes. This wording of purpose is clear, and for all the empty promises and obfuscation of the facts in amongst glamorous development proposals (put together be paid agents and consultants on the part of wealthy Green Belt land owners with vested financial interest in developing the land), one over-riding fact is abundantly clear: any development of the land will diminish its achievement of this very clearly stated purpose.

The Greater Cambridge Green Belt Assessment report does a great job of classifying individual parcels of land within the Green Belt according to the level of harm to the Green Belt that would be suffered were these parcels of land to be released. Whilst in my earlier comments, I have questioned the need for this piece of work to have been carried out when a simple policy aim of not eroding the Green Belt would have been better, now that the work has been done, it should at least be properly relied upon.

Each parcel of land is assigned a harm rating, ranging from “Very High” to “Low”. However, in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA report), wherein site proposals are evaluated using a Red-Amber-Green flag system, the Green Belt Assessment findings, whilst being mentioned in the HELAA report, do not seem to be a criteria attracting a flag rating. My suggestion would be a simple approach whereby land in the Green Belt should automatically receive a Red flag in the HELAA. However, understanding that SCDC seems to wish to avoid a blanket ban on Green Belt development, at the very least the Green Belt Assessment report rating system should be used and any parcel of land forming part of a site proposal that received a “Very High”, “High” or “Moderate High” harm rating (i.e. 1 of the the top 3 ratings) in the Green Belt Assessment should receive a Red flag. Otherwise we appear to be merely observing significant harm to the Green Belt would be caused by development of a site but not actually taking it into account in the evaluation of that site. I note that the HELAA report states that sites containing Green Belt land should meet NPPF requirements demonstrating exceptional circumstances, and that this should be assessed elsewhere. But nowhere else in the First Proposals evidence base does there seem to be such a rigorous site by site analysis as in the HELAA report. Therefore the Green Belt should be considered within the flag system adopted by this report, otherwise its importance is being implicitly and systematically deprioritised relative to the 14 Constraints and Impacts that are scored with a flag.

The Green Belt Assessment criteria do in general all appear quite subjective in terms of how a harm rating is arrived at, though the need for some level of subjectivity is recognsied. The statement that “Where a release of land would encompass areas with different harm ratings, the overall harm rating will always equate to the highest component harm rating” is noted and agreed with.

In general, the idea that a “Low” harm level can be achieved through the release of any Green Belt land appears flawed. This is perhaps a terminology point in classifying varying levels of harm. But fundamentally, the release of any Green Belt land is harmful and terms like “Low” seem to suggest it should be acceptable, when I hope what is meant is that it may be less disastrous than releasing some other parcels of land from the Green Belt.