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 North BRLOG that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable. It appears that the assessment against sustainability objectives is not robust because it does not critically review or challenge the evidence provided by the Councils.

North BRLOG 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 North BRLOG 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 are 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 strategic allocations in sustainable locations that deliver affordable housing such as on the edge of Cambridge.

The promoted development by North BRLOG at South West 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. 52643 Land North of Barton Road and land at Grange Farm, 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.

North BRLOG’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 would provide between 2,500 and 2,800 dwellings, including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and student accommodation. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG and submitted with Issues & Options representations) highlighted that there is sufficient residual value in strategic greenfield sites on the edge of Cambridge, including at South West Cambridge to support planning obligations and policy requirements including affordable housing. It is requested that the score for housing is changed to ‘significant positive effect likely’.
• SA Objective 2: Access to Services and Facilities – A significant positive effect likely/minor positive effect is identified. The site is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities and employment opportunities available in neighbouring areas and within the City Centre. The promoted development includes a primary school, community centre, health centre, and neighbourhood centre with a food store and other shops. 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 mixed minor/negligible effect is identified. No comments. The promoted development would deliver housing and a substantial amount of affordable dwellings. The promoted development would provide 40% affordable housing. The site is also well related to other employment opportunities available elsewhere within and on the edge of the City. All of the employment opportunities are accessible by walking, cycling or public transport. In addition, the promoted development would provide jobs during the construction phase, and there would be jobs available within the proposed school, shops, and health centre. The promoted development would deliver positive social inclusion and equality benefits. It is requested that the social inclusion and equalities score is changed to ‘significant positive effect’.
• SA Objective 4: Health – A minor positive effect/negligible effect is identified. The promoted development would include substantial areas of open space and recreation areas for outdoor activities, walking and cycling facilities for active travel, and a health centre. It is requested that the health score is changed to ‘significant positive effect likely’.
• SA Objective 5: Biodiversity and Geodiversity – A minor negative effect is identified. A Preliminary Ecological Appraisal has been undertaken of the site. The County and City Wildlife Sites, the network of ditches, the Bin Brook watercourse, and the hedgerows at the site would all be incorporated into the promoted development. The proposed development provides a number of opportunities for ecological enhancement, including the re-naturalisation and ‘rewilding’ of the Bin Brook and the creation of a dedicated arable weed reserve. An assessment of the benefits from these ecological enhancements will need to be calculated, but are likely to be beneficial. It is requested that the biodiversity score is changed to ‘significant positive effect likely’.
• SA Objective 6: Landscape and Townscape. A significant negative effect is identified. A Landscape and Visual Appraisal and Green Belt Review has been undertaken of the site. The promoted development includes a substantial central east-west open corridor through the site which takes into account some of the primary viewpoints towards the City from the west, retains existing landscape features, and locates development to avoid potential adverse effects on the setting of landmark/taller heritage assets in the City. The key views across the site would be retained as part of the promoted development, and there would be additional landscaping at the edge of and within the proposed residential areas. It is requested that the landscape and townscape score is changed to ‘negligible’.
• SA Objective 7: Historic Environment: A minor negative effect is identified. An Initial Heritage Impact Assessment has been undertaken of the site, to identify the significance and setting of heritage assets that might be affected by the promoted development. The most sensitive parts of the site in heritage terms and the key views across the site remain undeveloped, and are part of the central east-west corridor through the site.
• SA Objective 8: Efficient Use of Land – A mixed significant negative/minor positive effect is identified. The site is greenfield, although a substantial part of the site would remain as open space and green infrastructure as part of the promoted development and the soil resources would be retained. A variety of densities and building heights would be provided within the promoted development, consistent with the findings of the landscape and heritage assessments and with an edge of City location. The proposed densities at the site are appropriate for this location, and represent an efficient use of land. The mixed effect score is appropriate.
• 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 minor negative effect is identified. The promoted development would need to meet water conservation standards.
• SA Objective 11: Adaptation to Climate Change – A minor negative effect identified. The promoted development would need to meet climate change adaptation requirements.
• SA Objective 12: Climate Change Mitigation – A significant positive effect/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. An Air Quality Constraints Report has been prepared for the site. The 250m wide landscape buffer along the western edge of the site and adjacent to the M11 would also address air quality impacts on the promoted development. The promoted development 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 overall.
• 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 ‘significant positive effect likely’.
• SA Objective 15: Employment – A significant positive effect likely is identified. The promoted development is adjacent to West Cambridge, which provides existing employment opportunities but is due to grow substantially in the near future. The site is also well related to other employment opportunities available elsewhere within and on the edge of the City. All of the employment opportunities are accessible by walking, cycling or public transport. In addition, the promoted development would provide jobs during the construction phase, and there would be jobs available within the proposed school, shops, and health centre. It is agreed that the promoted development would deliver a ‘significant positive effect’ for employment.

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