We do not consider that the Plan contains sufficient small and medium site allocations, nor does it comply with paragraph 79 of the NPPF. Whilst we accept that the majority of Infill Villages do not provide sustainable locations to allocate development, we do consider that this overlooks a number of Infill Villages which are distinguished from the rest by reason of their proximity to other, higher tier settlements, such as Kneesworth.

Kneesworth is within the Parish of Bassingbourn-cum-Kneesworth and physically connected to Bassingbourn, which is classified as a Minor Rural Centre and recognised within the adopted South Cambridge Local Plan as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire. These services and facilities are highly accessible to Kneesworth, including the land to the south of The Causeway, Kneesworth (Site Reference: 40216), which has been promoted by Scott Properties for residential development throughout the emerging Plan process.

The site received an ‘amber’ score for suitability within the HELAA, and was scored ‘green’ for both availability and achievability. Having achieved more ‘green’ scores for many aspects of the suitability assessment, it also represents the most suitable site within Bassingbourn-Cum-Kneesworth. As noted in our comments on Policy S/SH, we consider that Bassingbourn and Kneesworth should be recognised as a single settlement for the purposes of the hierarchy, owing to their close proximity and functional relationship, both of which fall within the Parish of Bassingbourn cum Kneesworth.

The site scores ‘amber’ in relation to Accessibility to Services and Facilities. Whilst this recognises that the site is less than or equal to 450m in distance from public transport, these are actually within 200m of the site both to the east and the west of the site, providing regular services to the surrounding villages and to Royston, the centre of which (also the location of the train station) is approximately 3km from the site.

To the west of the site, Bassingbourn is accessible to pedestrians via a continuous footway along The Causeway. As such, it is considered that the sustainability of the site is not accurately reflected within the HELAA, and should have been scored ‘green’.

The site also received an ‘amber’ score in relation to Flood Risk, due to the southern-most part being within Flood Zone 2. As shown within the Masterplan Concept Layout accompanying this submission, this area is proposed as open space, with built form proposed only within the areas of the site with Flood Zone 1. As such, the site does not present any issues with flood risk, and the assessment should be amended to ‘green’.

With regards to Transport and Roads, the site notes that the site is potentially part of a cluster, and may require a cumulative assessment. The site has consistently been promoted by Scott Properties in its own right, and not in conjunction with any other site. Further, this conclusion contradicts with the methodology set out in Annex 1 to the HELAA, which states that ‘sites were assessed individually with no account given to cumulative impacts/constraints of combining them with other sites being tested. If sites near to or adjoining each other are selected for allocation cumulative impacts will be considered during the preparation of the Local Plan.’ As such, and in accordance with the methodology, such conclusions are beyond the scope of the HELAA and in this instance have resulted in an unduly negative assessment of the site, which should be amended to ‘green’.

As recognised within the site’s assessment in relation to Noise, Vibration, Odour and Light Pollution, the site is capable of being developed to provide healthy internal and external environments, therefore should have scored ‘green’. There are no such constraints on the site, which would be developed to reflect the existing pattern and orientation of existing dwellings fronting The Causeway.

More detailed consideration of the settlements of Shepreth and Kneesworth demonstrates that these locations would be suitable for growth, which would be consistent with the aims of the NPPF and the Plan in supporting the vitality of rural settlements. Due to the approach taken, which automatically ruled out any Infill Village from being considered as part of this process, these areas have been unduly overlooked. It does not appear, however, that a consistent approach has been taken in relation to this.

As shown in Table 4.23 of the SA, sites outside of Rural Centres, Minor Rural Centres and Group Villages have been subject to SA appraisal, such as 29 Station Road in Shepreth. We are unclear why this particular site was assessed within the SA, to the exclusion of any others within Shepreth or other Infill Villages. Further, we note that the HELAA states in relation to Landscape and Townscape in the assessment of 29 Station Road, that ‘due to the proximity of the railway line, it is recommended that only employment or industrial uses are considered.’ Despite this, the site has been subject to assessment for residential use within the SA. Whilst we acknowledge that this is not a proposed allocation within the Plan, we highlight this point as a further example of inconsistencies within the evidence base, and, more concerningly, an example of where the conclusions of the HELAA appear to have been overlooked.

As set out in our comments on the SA, we consider that the spatial distribution fails to direct sufficient growth to villages, and therefore does not fit with the contention that this was strongly influenced by the desire to support rural communities to thrive and sustain services.