This policy is considered to only illustrate further the lack of distribution in housing and employment sites across villages within South Cambridgeshire. The vast majority of proposed allocations are carried forward, with only 3 new residential allocations and a single new mixed use allocation. These sites are in Melbourn, Caldecote and Oakington. The latter two of these both being Group Villages like Hauxton. The residential allocations propose a total of 104 homes and the mixed use allocation 120 homes. These are considered to be small additional contributions to housing allocations in the entirety of the rural area.

Furthermore, whilst land has been allocated for employment uses, specifically research and development facilities, these are at established sites such as the Genome Campus, Babarham Institute and Cambridge Biomedical Campus to strengthen existing clusters. However, as identified in the Council’s own employment evidence base, Greater Cambridge has a diverse range of employment sectors and in order to ensure that existing settlements benefit from jobs in close proximity to their homes to reduce the need to commute into Cambridge and further afield, consideration of new employment allocations within and close to existing settlements should be examined further as part of the next stage of the Local Plan. The FWWTW site provides an opportunity for consolidating the employment opportunities that have been created by the adjacent Mill SciTech Park on the eastern side of the A10.

If the Councils are of the view that new housing and employment uses will come forward through windfall sites, then Bridgemere Land Plc consider that this is highly unlikely. The settlements in South Cambridgeshire have tight settlement boundaries and the availability of land within these boundaries for future housing and employment development is limited. This is evident given the exceptionally high demand for land for development in the district. Indeed the risk may be that small sites come forward for 2 or 3 houses at a time, given the size of plots, which will increase the overall population of existing settlements, but without the means to secure funding to improve local services and facilities. As such, the Council should be taking a more comprehensive approach, whereby housing and employment allocations are identified at this stage to deliver much needed homes and jobs in a planned manner, alongside funding for important local infrastructure.

The Greater Cambridge Local Plan Development Strategy Options – Summary Report (November 2020) sets out work undertaken to assess further whether the spatial choices set out in the Greater Cambridge Local Plan: First Conversation consultation were indeed reasonable.

Consequently, eight choices were taken forward for testing as strategic options, which included:

‘Spatial Option 5: Focus on Dispersal: Villages - this approach would spread new homes and jobs out to the villages.’

The document sets out that such distribution would ‘result in multiple smaller sites that are likely to be deliverable in the short to medium term; this would also meet the NPPF requirement to allocate a percentage of small sites.’

It was however considered to be the worst for carbon emissions with the worst transport links. However, this is a generalised statement and does not recognise the different attributes of individual settlements. Key to a sustainable scheme is accessibility. Hauxton is in close proximity to Cambridge, the largest settlement in the Greater Cambridge area and the location of the major employment, retail and leisure opportunities. Cambridge is readily accessible from Hauxton (and vice versa) by bicycle, bus or via Park and Ride, and by car would only be subject to very short journeys. It is also at the confluence of several forthcoming transport initiatives, which will place the Site within a dynamic and highly sustainable transport corridor.

It is therefore considered that the conclusion reached in the evidence base is not representative of Hauxton, and that the Council should give further consideration to the delivery of housing and employment in this location, which relates to further comments that Bridgemere Land Plc have to Policy S/RRA - Site H/2 - Bayer CropScience Site, Hauxton.

Policy S/RRA - Site H/2 - Bayer CropScience Site, Hauxton:

The First Proposals Consultation Document contains Draft Policy S/RRA which comprises a small number of site allocations within the rural area. As part of this policy, Site H/2 is identified as the Bayer CropScience Site to the East of the A10 in Hauxton. It is proposed that the proposed policy direction for this site will be amended from the adopted 2018 Local Plan, to encompass only the employment areas of the Bayer CropScience site, which are still to be developed, the rest of the scheme now having been completed and occupied.

At this stage, the proposed policy direction is limited within the consultation document and therefore it is not clear whether the emerging policy will contain similar provisions within the supporting text, concerning the FWWTW site. Paragraph 7.13 of Policy H/2 in the adopted 2018 Local Plan sets out the following:

Proposals for the redevelopment of the recreation buildings and waste water treatment facility on the western side of the A10 will be considered in the context of proposals that do not comprise inappropriate development within the Green Belt. As a planning objective it would be highly desirable to secure the removal of the incongruous industrial structures on the western part of the site. Particular consideration should be given to proposals that remove these structures and improve the visual appearance of the Green Belt through proposals that are consistent with Policy NH/9 and the NPPF (2012) paragraph 89.

Whilst not contained within the specific wording of the policy, the identification that the remediation of the Site is a planning objective and that particular consideration should be given to proposals that remove the existing structures and improve the visual appearance of the Green Belt are of use in determining planning applications for the Site, including the recent permission for 32 homes on the Site.

During the determination of the planning application for 32 homes, it was apparent to all parties, the highly complex nature of the Site, which aside from its planning designations, has a significant number of environmental requirements to satisfy in order to remove the contamination from the Site. This unique set of circumstances ultimately informs the type and scale of development needed on the Site in order to see it remediated, the existing structures removed and an appropriate scheme found for the Site, which improves the visual appearance of the Green Belt. Such a scheme is highly likely to be for a greater quantity of homes than currently approved or alternatively an employment use to complement the Mill SciTech Park.

This would be in accordance with the objective of paragraph 145 of the NPPF, which ‘sets out that once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, including looking for opportunities to improve damaged and derelict land’.

Furthermore, paragraph 119 of the NPPF sets out that ‘strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land’. This is a strategy which the Government have continued to advocate through recent briefings and the Autumn Budget 2021.

Taking this into account and given the unique circumstances of this Site, Bridgemere Land Plc are of the view that the Site requires more than a supporting paragraph within the emerging Local Plan, but a policy of its own, in order to fully realise the development potential of this Site. Therefore, the Site has been put forward as a Major Development Site within the Green Belt as part of the Call for Sites Consultation 2021.

The extant planning permission demonstrates that it is possible for a scheme to come forward on this land within the Green Belt, utilising the Previously Developed Land. However, given the complexities of the Site, specifically around the extent of remediation required, it is vital to include a site specific policy within the emerging Local Plan, which recognises the complete development potential of this Site for delivery of housing, employment or a mixture of both and to support its delivery, which Bridgemere Land Plc consider to be greater than currently approved.

The Green Belt Assessment (2021) undertaken by LUC on behalf of Greater Cambridge places the Site into Parcel HX12. Within its assessment, it identifies that the parcel makes limited or no contribution to the preservation of Cambridge as a compact, dynamic city and that it makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting and preventing communities from merging with one another, in this context, Hauxton and Haslingfield.

Notwithstanding this, the assessment identifies that the release of the land as an expansion to Hauxton would not be favourable, given the presence of the A10 as a strong separating feature between the settlement of Hauxton and parcels of Green Belt to the west, including Parcel HX12. As such, the suggestion is to not release the land from the Green Belt, but to identify it as a development site within the Green Belt, taking into account national and local Green Belt policy, but also recognising that the Site does have a very special set of specific circumstances, which need to be considered as a whole in order to bring forward this Site and see it improved for the benefit of all. Bridgemere Land Plc consider that these specific circumstances of the Site which include the ability of a scheme to remediate the contamination on Site and making the most efficient use of the previously development land resource available, requires a scheme of greater scale than currently approved and that working collaboratively with the local planning authority and key stakeholders this can be achieved on the Site.

To facilitate this, a site specific policy should be included in the emerging Local Plan and to assist the Council, such a draft policy for the Site could include:

A. Proposals for the re-development of the Former Waste Water Treatment Works, Hauxton as previously developed land within the Green Belt will be permitted where the re-development:

a. contributes towards local housing needs and/or provides new jobs;
b. removes the existing incongruous industrial structures on the western part of the Site;
c. would not have significantly greater impact on the openness of the Green Belt;
d. where the scheme delivers significant environmental benefits including remediation of the Site and that these benefits are recognised as very special circumstances that should be given great weight in the planning balance and consideration of harm;
e. improves the visual appearance of the Green Belt through a comprehensive landscaping strategy;
f. where possible, seeks to connect to existing and/or emerging sustainable transport schemes linking to existing villages and the City of Cambridge; and,
g. contributes to the authorities’ sustainable development principles as set out in other policies in the Plan.

B. The Council will assess the proposed re-development scheme based on the following:

a. the very special circumstances of the re-development scheme and ensuring that site specific benefits are given great weight against any assessment of harm to the Green Belt;
b. the visual impact of the development would not cause substantial harm to the Green Belt, when taking account of the existing built form, the context of the Site, the significant environmental and/or employment/housing benefits and the notable features, including new transport projects within the vicinity;
c. the activities / use of the new development compared to the existing/established use;
d. the contribution of the development to remediate the Site so that it diminishes the risk to human health and the environment and provides a safe and habitable/working environment for the end users; and
e. taking into account other policies within the Plan when taken as a whole.

Wider Green Belt Context
As part of the consideration for this Site, one needs to recognise that there are a number of emerging local transport schemes in close proximity to the Site, as outlined in paragraph 2.8 above, which will alter the visual context of the Site, but also bring with them considerable improvements to sustainable connections between the Site and the City. These schemes are being brought forward by the Greater Cambridgeshire Partnership in conjunction with Cambridgeshire County Council and the East West Railway Company and have funding and approval to move forward to construction, subject to obtaining the relevant consents. All are located in the Green Belt:

(a) A new travel hub on land to the west of junction 11 of the M11, to the north of the FWWTW and west of the A10. This travel hub will provide 2,150 car parking spaces, 326 cycle parking spaces and associated coach parking, a new travel hub building, bridge across the M11 and associated highway infrastructure works to the M11 junction and dedicated busway into Cambridge. Whilst the planning application for that scheme still remains under determination by the County Council, the location of that site within the Green Belt to the proximate north-west of parcel HX12 is notable and will alter the appearance of this part of the Green Belt.

(b) A number of Greenways have been approved linking villages on the periphery of Cambridge with the City and the Partnership are in the process of detailing these routes. Immediately to the west of the site, will be the junction for the Melbourn and Haslingfield Greenways, with their indicative route into the City Centre utilising land directly to the west of the Site. This Greenway will link into the new travel hub to the north, providing onward routes for pedestrian and cyclists over the M11 and into Cambridge. As a shared use path, it is expected that it will be approximately 3 m in width, potentially with some level of lighting, and will certainly form a new distinctive western edge to the FWWTW Site.

The above are important factors to consider and ones that could equally be harnessed for the benefit of a future scheme on the Site.

Whilst the Site is seen to be separated from the core settlement of Hauxton, the above context demonstrates that to the west of the A10 a sustainable transport corridor is highly likely to come forward, which places this previously developed site in an ideal location to provide a scheme which can contribute towards meeting local housing and/or employment needs in a highly sustainable location and a rapidly-changing context, which makes it very unique and readily deliverable.