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 Dudley Developments 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.

Dudley Development’s 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 Dudley Developments representations to Policy S/DS, there is the over reliance on the existing new settlements and planned new neighbourhoods to meet the housing requirements. The key parts of the development strategy for emerging GCLP is the delivery of extensions to Cambourne, the planned new settlements at Northstowe, Waterbeach and Bourn Airfield, and the new communities on the edge of Cambridge at North East Cambridge and Cambridge East. These are all complex developments that also require the delivery of transport and community infrastructure. The predicted housing delivery rates at these developments are challenging. Most of these developments will provide less affordable housing than required by policy, at least in the initial phases, to reflect the amount of infrastructure that is needed. The proposed redevelopments at North East Cambridge and Cambridge East are complex and involves the relocation of the existing uses. The Sustainability Appraisal and the assessment of the development strategy simply assume that delivery of these developments will be as predicted without any delays and that the delivery of less affordable housing is acceptable. An alternative approach to address these housing related matters should have been recommended in the Sustainability Appraisal to improve sustainability outcomes e.g. additional small allocations in sustainable locations that deliver affordable housing such as on the edge of Cambridge. Small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge, including at Cherry Hinton on land within the Green Belt, because such sites can also deliver affordable housing to meet identified needs.

The promoted development by Dudley Developments at land off Limekiln Road in Cambridge was assessed in the SA against a series of sustainability objectives and compared against other edge of Cambridge Green Belt site options – see Table 4.19 in SA (Site Ref. 40528 Land North of Cherry Hinton Caravan Club, Limekiln Road, Cambridge). The assessment of the site has not fully taken into account what is proposed in the promoted development or the submitted Vision Document and technical reports prepared for the site.

Dudley Development’s comments on the findings of the SA for the site are as follows:

• SA Objective 1: Housing – A minor positive effect is identified. The promoted development for 14 dwellings, would be required to include a proportion of affordable housing, making a contribution towards the identified affordable housing needs of Cambridge.
• SA Objective 2: Access to Services and Facilities – A significant positive effect likely/minor positive effect is identified. The promoted development at land off Limekiln Road in Cambridge is accessible by sustainable modes of transport. Queen Edith's Way and Cherry Hinton Road are on bus routes. The Greater Cambridge Partnership’s Making Connections project identifies Cherry Hinton as a key location on a bus corridor, with improved bus links to Addenbrooke’s and Cambridge Station. There is a dedicated cycle path on Cherry Hinton Road. The Greater Cambridge Partnership’s proposed Fulbourn Greenway project, which includes new dedicated walking and cycling routes and improvements, passes through Cherry Hinton. It is requested that the assessment score for access to services and facilities is changed to ‘significant positive effect likely’ only.
• SA Objective 3: Social Inclusion and Equalities – A negligible effect is identified. No comments.
• SA Objective 4: Health – A minor positive effect/negligible effect is identified. Cherry Hinton contains doctor’s surgeries, leisure centres for residents to improve their health and fitness, and walking and cycling facilities for active travel.
• SA Objective 5: Biodiversity and Geodiversity – A significant negative effect likely is identified. A Preliminary Ecological Appraisal is submitted with the representations to the HELAA site assessment (Site Ref. 40528).The promoted development includes open space. There are parks and open spaces in the local area. The site is close to Cherry Hinton Chalk Pits SSSI. It is noted that Policy BG/BG: Biodiversity and Geodiversity of emerging GCLP is likely to include a requirement for developments to provide mitigation measures to address recreational impacts on nature conservation sites. The promoted development would provide mitigation measures. The promoted development would provide on-site ecological mitigation measures including enhancement of existing trees, planting of species rich calcareous grassland, and providing bird and bat boxes and hedgehog domes. The promoted development would need to make off-site contributions to address recreational pressure on nature conservation sites, in accordance with emerging Policy BG/BG.
• SA Objective 6: Landscape and Townscape. A minor negative effect likely is identified. The site is not visible from the surrounding area. The promoted development would retain the tree within the site and the hedgerows and vegetation at the site boundary. Additional trees and landscaping would be provided within the site to enhance landscape character. It is requested that the landscape and townscape score is changed to ‘negligible effects’.
• SA Objective 7: Historic Environment: A minor negative effect is identified. The promoted development does not affect any heritage assets. It is noted that the site assessment in the HELAA scored the site ‘green’ for historic environment matters. It is requested that the heritage score is changed to ‘negligible effects’.
• SA Objective 8: Efficient Use of Land – A minor negative effect is identified. It is acknowledged that the site is currently greenfield. The density of the promoted development is appropriate for the site, and compatible with the character of the site and the surrounding area.
• SA Objective 9: Minerals: A significant negative effect likely identified. An assessment of the mineral resource at the site will need to be undertaken to determine what resources exist. If there are any suitable mineral resources it is unlikely that the site would be suitable for mineral extraction because of the close proximity of residential areas, and the need for substantial buffers to be provided at mineral extraction sites to protect residential amenity.
• SA Objective 10: Water – A negligible effect is identified. The promoted development would need to meet water conservation standards.
• SA Objective 11: Adaptation to Climate Change – A negligible effect identified. The promoted development would need to meet climate change adaptation requirements.
• SA Objective 12: Climate Change Mitigation – A minor positive effect identified. The promoted development would need to incorporate climate change mitigation measures.
• SA Objective 13: Air Quality – A minor negative effect is identified. The promoted development is small scale. It is accessible by sustainable modes of transport, and there are realistic alternatives to the car for most journeys from the site to reduce potential increases in traffic and associated impacts on air quality. The phasing out of petrol and diesel vehicles and the requirement for new residential developments to include electric vehicle charging points should help to improve air quality. It is not clear what impacts on air quality would arise from the promoted development.
• SA Objective 14: Economy – A negligible effect is identified. The additional housing and affordable housing provided at the promoted development would meet the needs of employees and support the economy of Cambridge. It is requested that the economy score is changed to ‘minor positive effect likely’.
• SA Objective 15: Employment – A significant positive effect likely is identified. The promoted development is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to employment opportunities in Cambridge. All of the employment opportunities are accessible by walking, cycling or public transport.

It is requested that the above comments are taken into account when the SA is updated.