Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58742

Received: 13/12/2021

Respondent: Trumpington Meadows Land Company (‘TMLC’) a joint venture between Grosvenor Britain & Ireland (GBI) and Universities Superannuation Scheme (USS)

Agent: Grosvenor Britain & Ireland

Representation Summary:

Land north of M11 and west of Hauxton Road, Trumpington (HELAA site 40048)

TMLC promoted Trumpington South within Call for Sites, Issues & Options stages. Vision document sets out proposals for site.

TMLC aspirations accord with goals of Plan - promoting sustainable travel, access to public open space, higher net gain in biodiversity than Policy BG/BG, net zero homes and generally scheme with sustainability and climate change at core. Site can be developed within first five years of plan period.



TMLC considers the site has been incorrectly scored and consider that it is suitable for development.

Site in Green Belt. Location on edge of Cambridge would be appropriate to be released. Green Belt Assessment classed site as ‘Relatively Significant’ to Purpose 1, and, ‘Moderate’ to Purpose 2 and 3. Harm rating of losing this Green Belt is ‘high’, which is lower than proposed allocation at Cambridge Biomedical Campus.

Site assessment (Ref. 40048) red for Suitable and green for available and achievable. If further constraints are included site scores red on landscape, impact onto strategic road network and Green Belt (assuming proforma missed including this).

• Landscape - TMLC Vision document makes it clear TMLC will provide double the amount of open space required, plant native trees and 25% net biodiversity gain. Aspirations for sensitive development which enhances its surroundings.

• Strategic road network - TMLC consider should be amber score. Vision document sets out how site will aim to reduce vehicle trips due to location to key public transport nodes which TMLC consider will help mitigate vehicle trips onto M11.

• Green Belt – part of parcel TR6 which includes country park and agricultural land. Should be subdivided. Much agricultural land retained as permanent green zone to M11. Masterplan configured to specifically to ensure once a new Green Belt boundary is established it shouldn’t be altered at end of plan period, and sprawl and encroachment could not occur. Overall harm assessment of High for parcel TR6 should be reduced.

Full text:

TMLC have promoted Trumpington South within the Call for Sites, Issues & Options stages of this emerging Local Plan. The vision document for the Call for Sites sets out the following proposals for the site:
• Up to 750 zero carbon homes in operation, with a commitment to reducing and reporting on the associated embodied carbon emissions in construction as defined by the UK Green Building Council
• 40% affordable homes
• Primary school
• Mobility hub and community concierge services
• Active travel networks and segregated paths
• Car free zones and centralised parking locations
• New community and co-working facilities
• In excess of double the public open space requirements (up to 23 Ha)
• 25% net gain in biodiversity
• Up to 10% of open space planted with native trees

The emerging Local Plan has declared a climate emergency and as TMLC own the site they more flexible over the proposed development. TMLC aspirations are in the accordance with the goals of this proposed Local Plan such as promoting sustainable travel, access to public open space, higher net gain in biodiversity than Policy BG/BG, net zero homes and generally a scheme which has sustainability and climate change at its core. The site is in agricultural use with tenant farmer Trumpington Farm Company operating under a rolling Farm Business Tenancy and can be developed within the first five years of the new plan period.

The site is in the Green Belt. We consider its location on the edge of Cambridge (e.g., by Trumpington Park & Ride, close to the new Cambridge South Train Station and close to Cambridge Biomedical Campus) would be an appropriate site to be released from the Green Belt. The Greater Cambridge Green Belt Assessment (August 2021) classed the site as being ‘Relatively Significant’ according to Purpose 1, and, ‘Moderate’ according to Purpose 2 and 3. The harm rating of losing this Green Belt is ‘high’, which is a degree of harm lower than the proposed allocation at Cambridge Biomedical Campus where the harm rating is ‘very high’. In addition to the Biomedical campus expansion the site allocation also includes possible affordable housing and enhanced landscaping. Trumpington South has a lower impact than this Site and will provide a mix of development.

The Councils’ Strategic Topic Paper (page 208, Appendix 1D) states that 23 sites were submitted within the Green Belt on the edge of Cambridge. The paper states that 14 sites did not seek to justify exceptional circumstances and 4 sites did but these 18 sites were discounted. 5 sites provided bespoke arguments for exceptional circumstances and of these two were allocated within the plan (Land at Cambridge Airport and Cambridge Biomedical campus). TMLC Issues and Options and Call for Sites Vision document stated that this site could demonstrate exceptional circumstances, but the Topic Paper does not state where the site sits within the 23. TMLC would like to understand where Trumpington South sits within the review of the 23 Green Belt sites, as the site is suitable for development.

The site assessment (Ref. 40048) has a summary of red for Suitable and green for available and achievable. The Suitable criteria of red is based on 13 issues (1 as red, 8 amber and 4 green). It is not clear if the ‘further constraints’ are part of the scoring for the suitable criteria either. Based on these individual scoring TMLC doesn’t understand how the Council have concluded that this site scores as red (especially if further constraints are not included). If further constraints are included then the site scores red on landscape, impact onto the strategic road network and the Green Belt (assuming that the proforma accidentally missed including this as red). We consider the following in respect of the two first points:

• Within the Councils’ Landscape Character Assessment (2021) the site is located within Character Area 3D - Cam & Granta Tributaries Lowland Farmlands. The site serves as part of an existing Southern Fringe Area Action Plan and is land retained as undeveloped, to create an enhanced gateway into the City between Hauxton Road and the River Cam inclusive of hedgerow planting, foot and cycle paths, wildlife habitat enhancements and noise attenuation. It is considered that development at Trumpington South would have a significant impact on the local and wider landscape character. The Landscape Character Assessment identifies Trumpington Meadows as a nature reserve and within the Local Plan call for sites feedback it suggests that the Trumpington Meadows development has been designed to include a distinctive urban edge with a green foreground providing a gateway to the city. Given the character setting of the area, the LPA’s are against development which will use the M11 as an enclosing boundary. TMLC disagrees with this assessment given that the site will be designed taking into consideration and enhancing its surroundings. In addition, the vision document makes it clear that TMLC will provide double the amount of open space required, plant native trees and will have a 25% net biodiversity gain which is 5% larger than the proposed policy. TMLC aspirations is for sensitive development which enhances its surroundings.

• Highways England have considered the site to be unsuitable for development due to falling within Zone 8 (M11 North) which states that the site would need to ensure no net increase in vehicle trips onto the strategy road network. The Councils’ Housing and Economic Land Availability Assessment (HELAA) 2021 states (page 54) that this ‘does not rule out sites at this stage. However, to be acceptable in planning terms development proposals within these zones will need to demonstrate (through a Transport Assessment and Travel Plan) no net increase in vehicles trips on the strategic road network’. TMLC consider that an amber score would be more considerable given this position from Highways England. This is also based on the pending planning application for the relocation of the ‘Trumpington Park and Ride’ to the south of the M11, that Highways England consider the principle of development to be acceptable, under the assumption there will be a ‘trip budget’ approach to minimise vehicle traffic, resulting an acceptable minimal impact on the Strategic Road Network. Furthermore, the TMLC vision document sets out how the site will aim to reduce vehicle trips due to the location to key public transport nodes which TMLC consider will help mitigate vehicle trips onto the M11.

In terms of the Green Belt assessment undertaken by LUC, there are a number of important points that appear to be overlooked (in addition to the points above) and in conjunction with the landscape character of the site, which are as follows:

• Trumpington South is located within parcel TR6. This parcel includes part of Trumpington Meadows Country Park as well as the agricultural land within which the development is proposed. Previously we have argued that this area should be subdivided into two parcels reflecting the distinctive and well-defined landscapes of the country park and agricultural land. We maintain this view, especially given this distinction is incrementally becoming more pronounced as the park establishes. Notwithstanding this important point, what is undisputable is that by including the county park the scoring of how this land contributes to Green Belt purposes increases, given it form part of the River Cam corridor, a defining feature of the Cambridgeshire Green Belt. In the scoring for Cambridge Purpose 2 (setting), the LUC assessment specifically references the Country Park as part of the reasoning why this parcel is important to this Green Belt purpose.

• Further, much of the agricultural land within parcel TR6 is not proposed to be developed and will be retained as designated Green Belt. This is fundamental point as it will establish a wide and permanent green zone between the M11 and the development edge. Given a new Park and Ride is proposed south of the M11, in combination this would establish a permanent land use arrangement between Trumpington and Hauxton. This would not only meet the obligation that once a new Green Belt boundary is established it shouldn’t be altered at the end of the plan period, but also ensure sprawl (National Purpose 1) and encroachment (National Purpose 3) could not occur. Indeed the masterplan for Trumpington South has be configured to specifically to achieve this objective.

• It is relevant to note that the overall assessment for this parcel has determined that the level of harm is less than the surrounding land. This reflects parcel TR6 immediate relationship to the existing urban edge and the strong existing boundaries that are readily recognisable and permanent, fully in accordance with policy 143 of the NPPF. When considering the additional point highlighted above it is considered that the overall harm assessment of High for parcel TR6 should be reduced.

TMLC consider that the site has been incorrectly scored as per the points set out above and consider that it is suitable for development.