The NPPF para 32 identifies that:
“Local plans and spatial development strategies should be informed throughout their preparation by a
sustainability appraisal that meets the relevant legal requirements. This should demonstrate how the plan
has addressed relevant economic, social and environmental objectives (including opportunities for net
gains). Significant adverse impacts on these objectives should be avoided and, wherever possible,
alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse
impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible,
compensatory measures should be considered).”

The GCLP First Proposals have been subject to Sustainability Appraisal which considers the preferred
options in the First Proposals and reasonable alternatives (see pg.19 of supporting text). The GCLP concludes
that:
“drawing on our evidence and consultation feedback, alternatives to our preferred option would either
distribute development to less sustainable locations that are distant from Cambridge or without the benefit
of very high quality public transport (existing or proposed) that would generate greater car use contrary
to our climate change theme, or would require the release of large areas of Green Belt on the edge of
Cambridge which would cause significant harm to the purposes of the Cambridge Green Belt. Full
information regarding the testing of these alternatives can be found in the Sustainability Appraisal
accompanying the First Proposals.”

However, having reviewed the Sustainability Appraisal, we consider that the Appraisal fails to properly
assess options in relation to employment land requirements under the following objectives:
• SA 12.6: Does the Plan support development which is in close proximity to city, district and rural centres,
services and facilities, key employment areas and/or public transport nodes, thus reducing the need to
travel by car?
• SA 14.1: Does the Plan provide for an adequate supply of land and the delivery of infrastructure to meet
Greater Cambridge’s economic and employment needs?
• SA 14.2: Does the Plan support opportunities for the expansion and diversification of businesses?
• SA 14.5: Does the Plan support stronger links to the wider economy of, and contribute to meeting
sustainable economic growth envisaged across, the Oxford-Cambridge Arc?
• SA 15.1: Does the Plan provide for employment opportunities that are easily accessible, preferably via
sustainable modes of transport?

As we set out in more detail below, we consider that the existing employment evidence is not sufficiently
robust as it fails to provide a full and objective assessment of distribution and industrial needs. In the
absence of this, the GCLP Sustainability Appraisal assesses the emerging Policy J/NE: New employment
development proposals with “No Policy” as the only alternative option (SA, pg.322). Given the requirements
of para 83 of the NPPF to plan “…for storage and distribution operations at a variety of scales and in
suitably accessible locations”, we are not convinced that “no policy” can be regarded as either a legitimate or
single alternative option for the purposes of appraising the Local Plan. We would expect that the
Sustainability Appraisal of the Local Plan Regulation 19 will assess appropriately the alternative options of
the emerging Policy J/NE and any other policy in relation to strategic employment requirements and land
supply.