Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57055

Received: 09/12/2021

Respondent: CEMEX UK Properties Ltd

Agent: Carter Jonas

Representation Summary:

It is considered that the Sustainability Appraisal has not sought to make the emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

Full text:

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by CEMEX that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to the CEMEX representations are: SA1 Housing; and SA2 Access to Services and Facilities.

The CEMEX representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the CEMEX representations to Policy S/DS, there are no housing allocations made in most villages, including Orwell, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 12 affordable dwellings in Orwell will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. CEMEX has requested that land west of Malton Road in Orwell is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in the CEMEX representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Orwell is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 12 affordable dwellings in Orwell. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Orwell, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 12 affordable dwellings in Orwell, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Orwell, will not be met by the development strategy or the strategy for rural areas. Orwell contains a primary school, village store including a post office, a public house, a hairdresser, a village hall, church hall, recreation facilities, a mobile library service, businesses, and a bus service which is due to be improved. The accessibility to services and facilities is good for Orwell, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land west of Malton Road in Orwell is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.