1. Paragraph 140 of the NPPF confirms that Green Belt boundaries should only be altered where exceptional circumstances can be demonstrated as part of the preparation of a Local Plan. The preparation of the GCLP provides the opportunity for the Councils to consider undertaking a review of the Cambridge Green Belt in the context of the challenges and opportunities facing the area in respect of delivering housing and employment growth, whilst also reducing climate change.

2. Over the plan period and beyond, significant investment and growth will come forward in Greater Cambridge. The HERR recommends pursing a jobs target of between 58,500-78,700 a range of some 20,200 jobs – equivalent to a potential 12,100 additional homes on what is proposed in the First Proposals document. The growth of Greater Cambridge is driven by the following initiatives:
• The Greater Cambridge City Deal seeks to speed up housing delivering, create 45,000 new jobs and provide £1bn of local and national public sector investment.
• The Cambridge and Peterborough Combined Authority (CPCA) have confirmed that due the high levels of growth and ‘exceptional’ housing market conditions in Greater Cambridge, the Government will provide £100m housing and infrastructure fund to help deliver infrastructure for housing and growth and at least 2,000 affordable homes.
• The CPCA have confirmed that Central Government are to provide an additional £70m ring fenced for Cambridge to help meet the ‘exceptional’ housing needs of the city.
• The CPCA anticipate that economic output will increase by 100% over the next 25 years. The GVA of the area is estimated to increase from £22bn to over £40bn.
• Cambridge City and South Cambridgeshire anchors the eastern end of the Oxford-Cambridge Arc as defined by Central Government in March 2019. The Government have stated that the Arc area is an economic asset of international standing and can be influential to the performance of the national economy. The National Infrastructure Committee (NIC) found the Arc area to be home to UK’s most productive and fast-growing cities and has significant potential for transformative Growth. However, the growth and opportunity in this area is currently constrained by poor east-west infrastructure and a lack suitable housing. The Arc initiative aims to realise the full economic potential of the area by delivering significant new infrastructure and building up to 1 million new homes by 2050.

3. To accompany and support economic growth in Greater Cambridge the following major infrastructure improvements are either being planned or have started:
• The A14 road improvements between Huntingdon and Cambridge - Completed
• A new railway station close to Addenbrookes Hospital to the south of the city centre - Expected completion date 2025
• The duelling of the A428 between Black Cat Roundabout and Caxton Gibbet - Expected completion date 2026
• The delivery of East-West rail, which includes a Phase 3 link running between Bedford and Cambridge - Expected completion date 2030. As with the Black Cat to Caxton Gibbet A428 road improvements, the delivery of East-West forms key elements of Oxford-Cambridge Arc.

4. In light of all of the above Martin Grant Homes consider that there is a set of exceptional circumstances which clearly justifies Green Belt release as a spatial strategy. The Cambridgeshire Green Belt was defined many years ago and the opportunity can now be taken through the preparation of the GCLP to refresh those existing Green Belt boundaries. A strategy to release appropriate sites from the Green Belt, is supported by:
• The immediate need to deliver housing growth in order to support the aims and objectives of the Greater Cambridge City Deal and the Oxford-Cambridge Arc.
• The need to deliver economic growth in Greater Cambridgeshire, which is of national importance to the UK economy and international importance to the innovation and education sector
• The requirement for the planning system to deliver all three dimensions of sustainable development (Paragraph 8 of the NPPF);
• The need for Plans and decisions to take into account local circumstances in order to achieve sustainable development (Paragraph 9 of the NPPF);
• The need for the planning system to be genuinely plan led (Paragraph 15 of the NPPF); and
• The need to ensure that planning proactively drives and supports sustainable economic development to deliver the homes, employment opportunities and thriving local places that the country needs (paragraph 82 of the NPPF)

5. The scale of economic and housing growth required in Greater Cambridge, as recommended by the HERR, is unlikely to be delivered in a sustainable manner without the suitable and evidenced release of Green Belt land. Accordingly, MGH welcomes and endorses the Councils decision to undertake a review of Green Belt boundaries as part of preparing the GCLP.

6. Page 39 of the First Proposals document states that the Councils do not consider that housing need alone provides exceptional circumstances to justify removing land from the Green Belt. MGH agrees with this conclusion as there is a broader and compelling case for exceptional circumstances in this case relating to economic growth and the unique circumstances and opportunity that Greater Cambridge is presented with.

7. The First Proposals documents seeks to make only one limited Green Belt release to support the development and growth of the Cambridge Biomedical Campus. MGH contend that the opportunity and indeed need to make further limited and specific Green Belt release extends beyond this one site.

8. Paragraph 142 of the NPPF confirms that when reviewing Green Belt boundaries local planning authorities need to promote sustainable patterns of development. The NPPF goes on to states that “where it is has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously development and or is well-served by public transport”.

9. Paragraph 143 advises that the definition of Green Belt boundaries should ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development and not include land which it is unnecessary to keep permanently open. The GCLP is shaped by the requirement to meet housing needs, which we contend should be higher and align with the recommendations of the HERR. It is also contended that the current Development Strategy is not sound or robust in its approach to promoting a balanced and flexible housing supply and ensuring rural communities will thrive and sustain their existing service provision over the plan period.

10. To remedy the above-described flaws it is contended that housing growth should be distributed to established sustainable rural settlements which possess excellent public transport links. Having established that there is a compelling case for exceptional circumstances in Greater Cambridge there is a clear case to support small and focused Green Belt releases. Green Belt sites in combination with delivering other non-Green Belt sites will make a material contribution to meeting objectively assessed housing need, accommodating economic growth and delivering a flexible and balanced Development Strategy.

11. MGH are promoting ‘land at Ambrose Way, Impington’ for release from the Green Belt and subsequent allocation for residential development through the GCLP preparation process. Having set out our case that there is a need for further limited and specific Green Belt release it is now necessary to establish how the site itself meets the five purposes of Green Belt as set out at paragraph 138 of the NPPF. To this end MGH have commissioned consultant EDP to review findings of the Council’s Green Belt Study prepared by consultants LUC. In addition, EDP have also undertaken their own review of the site in the context of paragraph 138.

12. The EDP Green Belt Appraisal (GBA), is appended to these representations and evidences the following conclusions in respect of the Ambrose Way site’s contribution to the Green Belt purposes:
- Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/Moderate.
- Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/No contribution
- Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate.
- Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as No Contribution.
- Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a.

13. The detail underpinning the above listed conclusions is evidenced in the submitted GBA document. In light of the specific assessment against each Green Belt purpose the GBA provides an overarching conclusion which confirms that the Ambrose Way site provides a low contribution to the NPPF Green Belt purposes. In respect of bringing forward development at the site the Appraisal concludes that,
“development can occur in this location without compromising the fundamental aims of the NPPF to keep land permanently open and while continuing to serve the five of Green Belt at this northern edge of Histon and Impington; primarily to check the unrestricted sprawl, prevent merging of settlements and safeguard the countryside from encroachment.”

14. Paragraph 140 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional circumstances. Martin Grant Homes believe that exceptional circumstances exist to justify making limited and site-specific modifications to the Green Belt in order to deliver housing and employment sites needed to meet the needs of Greater Cambridge. Indeed, such modifications will allow a sustainable Development Strategy to come forward which will deliver a varied, flexible and robust housing supply and spread the benefits arising from sustainable development to rural areas, which in the main are not currently supported by the GCLP First Proposals.

15. The proposed distribution of new growth and allocations via the GCLP is a fundamentally flawed and will not deliver a varied, flexible and robust housing supply or spread the benefits arising from sustainable development to rural areas.

16. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for development. It is strongly contested that this is the case for the Land at Ambrose Way, Impington. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out at paragraph 8 of the NPPF and assist in supporting economic growth which is of regional and national importance.