As set out in our comments on Policy S/DS, we do not consider that the Sustainability Appraisal (SA) provides a consistent and thorough assessment of the options for growth, particularly in relation to Option 5 – dispersal – villages.

We consider that the SA has made a number of broad assumptions in relation to villages, which are not applicable to all, resulting in an overly negative score which has unjustly influenced the decision to distribute limited growth to villages.

In relation to SA objective 1: Housing, we note the conclusions as to the uncertainty with locating homes within new settlements, as this may not result in the necessary range of housing types or sufficient housing to come forward until later in the Plan period. We echo this concern, as set out in our comments on various proposed policies, that there is a heavy reliance upon sites which will not be capable of delivery within the short-medium term period of the Plan, with a concerning absence of sufficient site allocations within this period.

Option 5 – Dispersal – villages is assessed as mixed significant negative and minor positive effects likely in relation to SA objective 2: Access to services and facilities. The assessment states at paragraph 4.37 that this option performs least well as it is most likely to put pressure on existing services and facilities and result in development that is less likely to provide new services and facilities, whilst being more distant from larger
centres. We would highlight that this assumption does not apply to all villages within the settlement, many of which benefit from day-to-day facilities and services, and also transport links which provide sustainable access to additional facilities. We would also highlight the conclusions in paragraph 4.32, which notes the uncertainty of the timings of the railway station and public transport improvements at Cambourne, which would leave residents with less access to services and facilities further afield. As such, we dispute the more positive assessment for the preferred option compared to village locations, which does not reflect the commentary in the SA.

The assessment of village locations which is subject to a number of unjustified assumptions and fails to recognise the sustainability of many villages. These assumptions are also made in relation to SA objective 3: Social inclusion and equalities, resulting in a conclusion that uncertain mixed minor effects are likely. Again, in relation to the preferred option, paragraph 4.38 confirms that many of the proposed services and facilities are not likely to be provided during the Plan period, in addition to the proposed rail route and public transport improvements. The SA notes in paragraph 4.40 that development may help to support existing services and facilities at villages, providing this is distributed between a number of villages.

The SA conclusions as to SA objective 5 – Biodiversity and geodiversity, predicts significant negative uncertain effects for option 5 (dispersal – villages), based on the assumption that it is likely that development would take place on greenfield land and may intersect with or be adjacent to an ecological designation, and mitigation will be difficult to achieve due to the likely smaller scale of development.

Paragraph 4.60 states that ‘as many of the villages across Greater Cambridge contain or are located within close proximity to designated and non-designated biodiversity assets, and development is likely to come forward on greenfield land, both options could lead to loss of biodiversity, depending on the exact location of village growth.’ Again, this is a broad assumption resulting in a negative score, despite this not being applicable to all villages. It is noted that paragraph 4.59 confirms that Cambourne contains a number of designated and non-designated habitats, despite this concludes that minor positive effects are likely for the preferred option. The assessment also states in the same paragraph that ‘it is noted that greenfield sites themselves are not always of particular ecological value, but they can provide supporting habitat for nearby more sensitive locations.’ However, this is not recognised in relation to villages, where instead the assumption is made that greenfield development could lead to the loss of biodiversity. This inconsistency has resulted in an artificially negative score for villages, with the SA appearing to place artificial significant on greenfield land around village locations but not at the preferred option. The SA seeks to justify the approach by contending that larger developments are able to incorporate green infrastructure and ecological networks, however, all sites will be required to receive a net biodiversity gain of at least 10% as required within the Environment Act 2021, so it is not considered that the SA can justify that significant negative effects on biodiversity and geodiversity are likely at villages and in no other spatial options.

Option 5 is also the least performing option in relation to SA objective 6: landscape and townscape. The conclusions in paragraph 4.73 do not support this assessment, however, stating that this option arguably performs best, as more dispersed development is less likely to lead to significant landscape change. Again, this produces an artificially negative assessment and downplays the suitability of villages for growth.

In relation to SA objective 8: Efficient use of land, uncertain significant negative effects are perceived likely for option 5. Paragraph 4.89 states that this ‘performs least well as this option includes development at a broad range of rural locations, so it is likely that development will take place on greenfield land, which has greater potential to be Grade 1, 2 or 3 agricultural land.’ We would highlight the confirmation in paragraph 4.84 that development around Cambourne and the surrounding area would also result in the loss of Grade 1, 2 and/or Grade 3 land, and although is combined with brownfield locations, it is as yet unknown the grade of land that would be lost to development around Cambourne, as no specific sites have been identified.

In relation to SA objective 11: Adaptation to climate change, the SA concludes that the preferred option is capable of mitigating any flood risk (despite no specific sites at Cambourne having been identified), whereas this assumption is not applied to any other scenario. It also assumes that due to the scale of development, Cambourne would be expected to provide new green space, which could incorporate sustainable drainage systems and build climate resilience in the area. Again, this assumption is not applied to any other option, despite sites being required to demonstrate that development does not increase flood risk elsewhere within the NPPF. Other sites would also be required to provide open space, this is not just limited to larger sites, as well as sustainable urban drainage systems in accordance with the NPPF. The SA states at paragraph 4.113 that the Water Study Supplement Study (2021) concludes the least preferable option is option 5, but no reasons are provided.

Option 5 performs least well in relation to SA objective 12: Climate change mitigation, predicted to have significant negative effects, due to it being likely to lead to development with high levels of dependency on the private car. This assumption fails to recognise that many villages within Greater Cambridge contain day-to-day facilities and services which would reduce to need to travel further afield, as well as many which benefit from good public transport links. Despite this, the SA also makes the unfounded general assumption that most villages are not well connected via public transport (particularly regarding the frequency of services) than larger centres. In relation to the preferred option, paragraph 4.118 comments that a substantial number of Cambourne residents commute to Cambridge to work, stating that ‘an increase in development at Cambourne is expected to result in an increase in carbon emissions, although this will be minimised by public transport improvements.’ Despite this, the potential to incorporate low carbon and energy efficient design and designing in walking and cycling are considered to be positives. This is true of all development, not just at the preferred option, and we note that Cambourne is located a considerable distance from Cambridge which would preclude cycling or walking to work.

We would highlight that some village locations are much closer to Cambridge and would offer the opportunity to walk and cycle to work, with others being within close proximity with one another and sharing facilities and services accessible to both by non-car means. As such, the SA is wrong to assume significant negative effects likely in relation to this objective. Further, it overlooks the Government’s commitment to ban the sale of new diesel and petrol engines from 2030, and the rising prevalence of electric vehicles and facilitating infrastructure within the UK.

We echo our comments in relation to SA objective 13: Air pollution, whereby option 5 is the least preferred due to it being likely to lead to development with high levels of dependency on the private car.

In relation to SA objective 15: Employment, we question how the preferred option would result in likely mixed minor effects, despite acknowledgement in paragraph 4.145 that a large number of employment opportunities will not come forward until after the Plan period. Option 5 again performs least well due to the assumption that existing centres of employment are likely to be less accessible to development under this option. This fails to acknowledge the proximity of some village locations to employment opportunities and/or decent public transport links, in addition to sites which are of the quantum able to deliver employment opportunities alongside new housing.

In light of the above, we do not support the suggestion that the Council’s evidence shows that Greater Cambridge’s villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of Greater Cambridge’s villages (paragraph E.9 of Appendix E to the SA). We do not consider that the SA has been undertaken consistently and accurately, nor does it provide a solid foundation on which to support the proposed spatial distribution within Greater Cambridge, which seeks to allocate less than 3% of growth to villages within Greater Cambridge. The approach taken is inconsistent with the NPPF, and the Councils' own objectives to support rural communities to thrive and sustain services.