These representations are submitted by Pegasus Group on behalf of Clarendon Land and Development Ltd who has land interests in land west of Long Lane, Fowlmere (LPA ref: 40327). We have previously submitted responses to the Call for Sites exercise (March 2019) and Regulation 18 Consultation (February 2020). These representations should be read in conjunction with these previous comments.

The Sustainability Appraisal (SA) for the Local Plan First Proposals (Oct 2021) is flawed as it is based on the preconceived judgement that development in villages is unsustainable due to car dependency. It is acknowledged in the SA that affordability is a key issue in Greater Cambridge (Chapter 3) but this does not form a key measure to rate sustainability.

The SA is an unwieldy document and difficult to understand the methodology and processes used. It is a 473-page document with numerous tables and colour coding and symbols which are not easily referenced.

Spatial Option 5 refers to the total development need of Greater Cambridge being dispersed to villages which results in:
• 40% located in rural centres
• 40% located to minor rural centres
• 17% located in group villages
• 3% located in infill villages.

This option was deemed unsustainable in the SA. It is clear that this level of growth solely directed at rural areas would cause sustainability issues and impact the area. However, this option should not be discounted on this skewed assessment alone. A sensible approach would be a blend of all options which results in some growth in villages not the entire growth for the whole District. It is unclear if the SA has assessed this blend of options or if it has discounted growth in villages based on this assessment.

The SA concludes that development may help to support viability of existing services and facilities at these villages and will improve access to these services. This point is reiterated in the Framework and it is important to ensure that these services and facilities have an adequate customer base to safeguard their survival. If modest development is not allowed in these communities, these services will fail and disappear during the plan period. The SA supports growth in more rural locations which is likely to help support services and facilities and may even help provide new facilities or build a business case for improved public transport. This would help to achieve the social, inclusion and equality objective of the SA. However, this objective is not carried through to the proposed Development Strategy within the Local Plan and no explanation is provided as to how the services and facilities in these communities are likely to survive with no housing or economic growth.

In its assessment of villages, the SA is unclear as to why all sites put forward as part of the Call for Sites exercise are not listed and assessed (Table 4.23). The ranking used and assessment of points is unclear and very confusing. There is no weighting of factors. It is considered that the impact on housing delivery in these areas, the impact on affordability and the benefit to the vitality of these communities are considerable and should be assessed as such. It is considered that these factors are not given enough significance in the planning balance.

The SA is a lengthy and unwieldy document but is concluded in paragraph 6.2 very simply by stating that "the proposed direction of the Local Plan performs well in sustainable terms." This brief conclusion of a document which runs to 473 pages is not considered adequate to summarise such a complex document and subject and has not provided a full analysis of all the differing factors which relate to a complicated spatial strategy with a multitude of development options.