GP/GB: Protection and enhancement of the Cambridge green belt

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Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56472

Received: 02/11/2021

Respondent: Mrs Margaret Starkie

Representation Summary:

Endorse the general principles of the policy however they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. Relocating the CWWTP to Green Belt in order to create a brownfield site to develop housing for NECAAP does not meet these objectives above. The Green Belt Assessment 2021 considered that the Cambridge Green Belt Purposes of 2003 and their inclusion in subsequent Local Plans, including the 2018 LP, were still relevant and they were used to assess the potential harm of new development. However, this 2021 Local Plan fails to include the incursion in the Green Belt at Honey Hill in order to release a commercial site (Cambridge Waste Water Treatment Plant at Cowley Road) in order to produce a brownfield site on which to build housing, retail and offices. The relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 pf Greater Cambridge Local Plan First Proposals) which states that a Local Green Space is required to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton where it is used for recreational purposes by walkers, runners, cyclists and equestrians and is good quality agricultural land with rich mixture of fauna.
It is also contrary to Policy BG/EO: Providing and enhancing open spaces which states that open spaces are often fundamental to the character of the area. Honey Hill is flat fenland close to the SSSI at Quy Fen and therefore the relocation of the CWWTP will change that character.

Full text:

Endorse the general principles of the policy however they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. Relocating the CWWTP to Green Belt in order to create a brownfield site to develop housing for NECAAP does not meet these objectives above. The Green Belt Assessment 2021 considered that the Cambridge Green Belt Purposes of 2003 and their inclusion in subsequent Local Plans, including the 2018 LP, were still relevant and they were used to assess the potential harm of new development. However, this 2021 Local Plan fails to include the incursion in the Green Belt at Honey Hill in order to release a commercial site (Cambridge Waste Water Treatment Plant at Cowley Road) in order to produce a brownfield site on which to build housing, retail and offices. The relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 pf Greater Cambridge Local Plan First Proposals) which states that a Local Green Space is required to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton where it is used for recreational purposes by walkers, runners, cyclists and equestrians and is good quality agricultural land with rich mixture of fauna.
It is also contrary to Policy BG/EO: Providing and enhancing open spaces which states that open spaces are often fundamental to the character of the area. Honey Hill is flat fenland close to the SSSI at Quy Fen and therefore the relocation of the CWWTP will change that character.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56509

Received: 15/11/2021

Respondent: Mrs Catherine Martin

Representation Summary:

Destruction of a large segment of Green Belt at Honey Hill is at odds with this policy. This green belt serves the purpose of preventing urban sprawl. It protects the approach toThe city. Allowing an industrial/ factory size complex (26m & 17 metre heights) on open Green Belt will impact on the views on the approach to the city and permanently change the character of the conservation areas which surround Honey Hill. This is a particularly open area with long vistas which an never be screened by planting. It will blight the amenity of the area for PROW users/residents

Full text:

Destruction of a large segment of Green Belt at Honey Hill is at odds with this policy. This green belt serves the purpose of preventing urban sprawl. It protects the approach toThe city. Allowing an industrial/ factory size complex (26m & 17 metre heights) on open Green Belt will impact on the views on the approach to the city and permanently change the character of the conservation areas which surround Honey Hill. This is a particularly open area with long vistas which an never be screened by planting. It will blight the amenity of the area for PROW users/residents

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56635

Received: 25/11/2021

Respondent: Gamlingay Parish Council

Representation Summary:

Support

Full text:

Support

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56753

Received: 03/12/2021

Respondent: Croydon Parish Council

Representation Summary:

There does not appear to be any enhancement. There is a danger of having urban sprawl around the outside of the Green Belt, looking like a doughnut with City, Green Belt and sprawl.

Full text:

There does not appear to be any enhancement. There is a danger of having urban sprawl around the outside of the Green Belt, looking like a doughnut with City, Green Belt and sprawl.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56814

Received: 05/12/2021

Respondent: Mr Mark Colville

Representation Summary:

I strongly support the protection of the Cambridge Green Belt.
Any erosion of the Green Belt will result in a reduction in its ability to achieve its primary purpose to “prevent communities in the environs of Cambridge from merging into one another and with the city”, as well as its other purposes.
At the very least the Green Belt Assessment report rating system should be used and any parcel of land forming part of a site proposal that received a “Very High”, “High” or “Moderate High” harm rating in the Green Belt Assessment should receive a Red flag in HELAA.

Full text:

I strongly support the protection of the Cambridge Green Belt. Enhancement is also fine in the way described in this policy, but must never be confused with development of the Green Belt. Developers and land owners will make many (entirely self-serving) arguments about the sustainability benefits of developing the Green Belt. However, these arguments are all entirely without merit. In rare instances where some small pockets of Green Belt land may benefit from some form of rejuvenation, this should never mean housing (or other forms of) development. Such development ruins the character of the Green Belt and undermines its very purposes, as set out in the policy definition.

Any erosion of the Green Belt will result in a reduction in its ability to achieve its primary purpose to “prevent communities in the environs of Cambridge from merging into one another and with the city”, as well as its other purposes. This wording of purpose is clear, and for all the empty promises and obfuscation of the facts in amongst glamorous development proposals (put together be paid agents and consultants on the part of wealthy Green Belt land owners with vested financial interest in developing the land), one over-riding fact is abundantly clear: any development of the land will diminish its achievement of this very clearly stated purpose.

The Greater Cambridge Green Belt Assessment report does a great job of classifying individual parcels of land within the Green Belt according to the level of harm to the Green Belt that would be suffered were these parcels of land to be released. Whilst in my earlier comments, I have questioned the need for this piece of work to have been carried out when a simple policy aim of not eroding the Green Belt would have been better, now that the work has been done, it should at least be properly relied upon.

Each parcel of land is assigned a harm rating, ranging from “Very High” to “Low”. However, in the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA report), wherein site proposals are evaluated using a Red-Amber-Green flag system, the Green Belt Assessment findings, whilst being mentioned in the HELAA report, do not seem to be a criteria attracting a flag rating. My suggestion would be a simple approach whereby land in the Green Belt should automatically receive a Red flag in the HELAA. However, understanding that SCDC seems to wish to avoid a blanket ban on Green Belt development, at the very least the Green Belt Assessment report rating system should be used and any parcel of land forming part of a site proposal that received a “Very High”, “High” or “Moderate High” harm rating (i.e. 1 of the the top 3 ratings) in the Green Belt Assessment should receive a Red flag. Otherwise we appear to be merely observing significant harm to the Green Belt would be caused by development of a site but not actually taking it into account in the evaluation of that site. I note that the HELAA report states that sites containing Green Belt land should meet NPPF requirements demonstrating exceptional circumstances, and that this should be assessed elsewhere. But nowhere else in the First Proposals evidence base does there seem to be such a rigorous site by site analysis as in the HELAA report. Therefore the Green Belt should be considered within the flag system adopted by this report, otherwise its importance is being implicitly and systematically deprioritised relative to the 14 Constraints and Impacts that are scored with a flag.

The Green Belt Assessment criteria do in general all appear quite subjective in terms of how a harm rating is arrived at, though the need for some level of subjectivity is recognsied. The statement that “Where a release of land would encompass areas with different harm ratings, the overall harm rating will always equate to the highest component harm rating” is noted and agreed with.

In general, the idea that a “Low” harm level can be achieved through the release of any Green Belt land appears flawed. This is perhaps a terminology point in classifying varying levels of harm. But fundamentally, the release of any Green Belt land is harmful and terms like “Low” seem to suggest it should be acceptable, when I hope what is meant is that it may be less disastrous than releasing some other parcels of land from the Green Belt.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56834

Received: 07/12/2021

Respondent: Save Honey Hill Group

Representation Summary:

Endorse the general principles of the policy but they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. That proposal is contrary to Policy BG/PO: Protecting open spaces (p183 ) which states that a Local Green Space is required to be demonstrably special to a local community and hold a particular local significance. Honey Hill has been used for recreational purposes, as well as farming, for hundreds of years.

Full text:

The objectives of the Policy:
preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
maintain and enhance the quality of its setting
prevent communities in the environs of Cambridge from merging into one another and
with the city.
Endorse the general principles of the policy however they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. Relocating the CWWTP to Green Belt in order to create a brownfield site to develop housing for NECAAP does not meet these objectives above. The Green Belt Assessment 2021 considered that the Cambridge Green Belt Purposes of 2003 and their inclusion in subsequent Local Plans, including the 2018 LP, were still relevant and they were used to assess the potential harm of new development. However, this 2021 Local Plan fails to include the incursion in the Green Belt at Honey Hill in order to release a commercial site (Cambridge Waste Water Treatment Plant at Cowley Road) in order to produce a brownfield site on which to build housing, retail and offices.

The relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 pf Greater Cambridge Local Plan First Proposals) which states that a Local Green Space is required to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton where it is used for recreational purposes by walkers, runners, cyclists and equestrians and is good quality agricultural land with rich mixture of fauna.
It is also contrary to Policy BG/EO: Providing and enhancing open spaces which states that open spaces are often fundamental to the character of the area. Honey Hill is flat fenland close to the SSSI at Quy Fen and therefore the relocation of the CWWTP will change that character.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56987

Received: 09/12/2021

Respondent: Trumpington Residents Association

Representation Summary:

The Trumpington Residents' Association strongly supports the policy. We stress the importance of the Green Belt to the south of the city and the way it fulfils the policy, including the land to the south of Addenbrooke's Road/Glebe Farm and to the south of CBC plus the River corridor and Hobson's Brook corridor. We are very concerned at the threat to the Green Belt of the CBC proposals. We are also seriously concerned at the threat to the Green Belt policy and the setting of the city that would have been the case if Site 056 had been approved.

Full text:

The Trumpington Residents' Association strongly supports the policy. We stress the importance of the Green Belt to the south of the city and the way it fulfils the policy, including the land to the south of Addenbrooke's Road/Glebe Farm and to the south of CBC plus the River corridor and Hobson's Brook corridor. We are very concerned at the threat to the Green Belt of the CBC proposals. We are also seriously concerned at the threat to the Green Belt policy and the setting of the city that would have been the case if Site 056 had been approved.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57022

Received: 09/12/2021

Respondent: Mr Howard Kent

Agent: Cheffins

Representation Summary:

Land adjacent Spring House, Church Lane, Sawston

The land adjacent Spring House, Church Lane, Sawston should be allowed to come forward as an infill residential plot for a self-build opportunity. The site is not part of Sawston Hall as evidenced within the submitted documents and does not fulfil any of the five purposes of the Green Belt as set out within the NPPF. The Green Belt boundary should therefore be amended as per the attached plan. The review of the Local Plan provides the opportunity to address this anomaly which has historically been recorded incorrectly.

Full text:

The evidence document supporting this policy: ‘Cambridge Green Belt Assessment (2021)’ maps the current Green Belt designations within Sawston under SAP2 and includes the land adjacent Spring House, Church Lane, Sawston within the Green Belt boundary (the land in question is shown on the attached Site Location Plan). Part of the land has been assessed as an ‘absolute constraint’ due to the land falling within the Registered Park and Garden of Sawston Hall. However, this land is not part of Sawston Hall and therefore the Registered Park and Garden and as such should not be included as an absolute constraint. Please find attached documentation which provides evidence of the ownership of this land and conclusively demonstrates that this should not be shown as part of the grounds of Sawston Hall. Historically the land was intended to be a sewage treatment plant (please find attached documentation which provides evidence of this); this was never implemented however nevertheless it further demonstrates that the site is not, nor has ever been part of the setting of Sawston Hall.

The anomaly is further demonstrated by the way the boundary of the Green Belt currently cuts through part of the site within our client’s ownership (as shown on the attached Site Location Plan) which demonstrates that historically there has been an error in terms of the mapping of the boundary.

The site in question has been subject to a previous application and subsequent appeal for the development of a single dwelling. There are some important points to note from the appeal decision in relation to the site’s designation as part of the Green Belt. The Inspector states that:

“The appellant has advanced a case that the site does not fulfil a role in preventing encroachment of the countryside or neighbouring towns merging. This is also touched upon by the Council in their committee report where it is stated that the site may not serve the purposes of including land within the Green Belt”.

"Notwithstanding that, paragraph 83 of the Framework states that the Green Belt boundaries should only be altered in exceptional circumstances through the preparation or review of the Local Plan. Therefore, until such a review is undertaken the site is located in the Green Belt and the effects of any development must be considered in line with the Development Plan policy and the Framework.”

As the land is currently designated as Green Belt the Inspector has to consider it as such, though reference is made to the Council’s statement that the site does not serve the purposes of the Greenbelt. Through this current Green Belt review the Council should amend the boundary of the Green Belt to correctly reflect where the openness begins and where the built up area should finish to amended this anomaly and allow this plot of land to come forward as an infill plot for a self-build opportunity.

The National Planning Policy Framework Paragraph 138 states that the Green Belt serves 5 purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
This site’s designations within the Green Belt does not fulfil any of the 5 purposes as stated above, for the following reasons:

1. The site represents limited infilling and therefore its designation does not ‘check urban sprawl’ or ‘safeguard the countryside from encroachment.’ In the appeal decision in relation to the previous application, as referenced above, the Inspector refers to the assessment of the plot as infill by the Council: “I am conscious that the Council have stated that, without other planning constraints, the site would be suitable as an infill plot. It is also noted that the Council have concluded that the development would result in limited harm. In this respect, I agree with the Council that only limited harm would result in the character and appearance of the area from the proposed development as a result of the erosion of the countryside”

2. The site does not preserve the setting and special character of a heritage asset. The potential impact from development of the site upon the setting of Sawston Hall and its gardens have been assessed as ‘very limited’ by the Inspector in the appeal decision of the previous application. The Inspector stated: “The principal heritage concern relates to the setting of Sawston Hall and the historic park. The Hall itself is not visible from the appeal site and is somewhat divorced from it. This, together with the existing residential development on either side of the appeal site, means that the harm which would arise from the development to the setting of the Hall and its gardens is very limited”.

3. Given the location of the site, its Green Belt designation does not prevent neighbouring towns merging nor does it assist urban regeneration. The plot is an infill plot leftover after the residential development along St Marys Road and its development would ‘round’ off the settlement edge.

In summary, the land adjacent Spring House, Church Lane, Sawston should be allowed to come forward as an infill residential plot for a self-build opportunity. The Green Belt boundary should therefore be amended as per the attached plan. Our client has received full support from the Parish Council in relation to this matter (as demonstrated through the attached email). The review of the Local Plan provides the opportunity to address this anomaly which has historically been recorded incorrectly.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57028

Received: 09/12/2021

Respondent: Bedfordshire, Cambridgeshire & Northamptonshire Wildlife Trust

Representation Summary:

The Wildlife Trust supports the inclusion of proposals to enhance the Green Belt for recreation and biodiversity. For Cambridge to grow sustainably much more positive use of the Green Belt must be made, including delivery of the proposals within the Cambridge Nature Network.

Full text:

The Wildlife Trust supports the inclusion of proposals to enhance the Green Belt for recreation and biodiversity. For Cambridge to grow sustainably much more positive use of the Green Belt must be made, including delivery of the proposals within the Cambridge Nature Network.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57044

Received: 09/12/2021

Respondent: Dr William Harrold

Representation Summary:

EWR’s current proposal is a 10m embankment which does great damage to the green belt. It solves a public transport problem for Cambourne which can be solved with much less Green Belt damage by the city deal / GCP. GCSP should not implicitly support EWR because it unnecessarily damages the green belt.

Full text:

EWR’s current proposal is a 10m embankment which does great damage to the green belt. It solves a public transport problem for Cambourne which can be solved with much less Green Belt damage by the city deal / GCP. GCSP should not implicitly support EWR because it unnecessarily damages the green belt.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57181

Received: 10/12/2021

Respondent: Southern & Regional Developments Ltd

Agent: Claremont Planning Consultancy

Representation Summary:

It is welcomed that the Local Planning Authority have identified exceptional circumstances for Green Belt release within the plan area. It is considered however, that the LPA have not gone far enough in releasing Green Belt land to meet the demanding housing requirements for the Greater Cambridge area. It is considered that additional land should be identified in the rural area for moderate levels of Green Belt release to ensure that the viability of the rural areas within the plan area are protected and enhanced.

Full text:

It is welcomed that the Local Planning Authority have identified exceptional circumstances for Green Belt release within the plan area. It is considered however, that the LPA have not gone far enough in releasing Green Belt land to meet the demanding housing requirements for the Greater Cambridge area. It is considered that additional land should be identified in the rural area for moderate levels of Green Belt release to ensure that the viability of the rural areas within the plan area are protected and enhanced.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57257

Received: 10/12/2021

Respondent: European Property Ventures (Cambridgeshire)

Agent: Claremont Planning Consultancy

Representation Summary:

It is welcomed that the Local Planning Authority have identified exceptional circumstances for Green Belt release within the plan area. It is considered however, that the LPA have not gone far enough in releasing Green Belt land to meet the demanding housing requirements for the Greater Cambridge area. It is considered that additional land should be identified in the rural area for moderate levels of Green Belt release to ensure that the viability of the rural areas within the plan area are protected and enhanced.

Full text:

It is welcomed that the Local Planning Authority have identified exceptional circumstances for Green Belt release within the plan area. It is considered however, that the LPA have not gone far enough in releasing Green Belt land to meet the demanding housing requirements for the Greater Cambridge area. It is considered that additional land should be identified in the rural area for moderate levels of Green Belt release to ensure that the viability of the rural areas within the plan area are protected and enhanced.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57415

Received: 10/12/2021

Respondent: Huntingdonshire District Council

Representation Summary:

Huntingdonshire District Council has no comment on this matter.

Full text:

Huntingdonshire District Council has no comment on this matter.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57422

Received: 10/12/2021

Respondent: Mrs Catherine Martin

Representation Summary:

Claim only 4 areas taken out of the Green Belt, this is obviously not correct because a large area has been taken for the relocation of the sewage works- moving it just a couple of fields to precious Green Belt. NEC is not a brownfield site, it is a working commercial site. Green Belt is being destroyed here to actually create a brownfield site. This contravenes this policy GP/GB & policies BG/PO, BG/EO

Full text:

Claim only 4 areas taken out of the Green Belt, this is obviously not correct because a large area has been taken for the relocation of the sewage works- moving it just a couple of fields to precious Green Belt. NEC is not a brownfield site, it is a working commercial site. Green Belt is being destroyed here to actually create a brownfield site. This contravenes this policy GP/GB & policies BG/PO, BG/EO

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57518

Received: 10/12/2021

Respondent: R2 Developments Ltd

Agent: Pegasus Group

Representation Summary:

Land to the north and east of Barrington Road, Foxton, (HELAA site 40412) and Land to the south-east of Cambridge Road, Foxton (HELAA site 40408)

Deliverable and sustainable sites found not to contribute to the five purposes of the Green Belt should be released and allocated for development. This includes Land to the north and east of Barrington Road, Foxton, (HELAA Ref: 40412) and Land to the south-east of Cambridge Road, Foxton (HELAA Ref: 40408). The release of these sites from the Green Belt will allow developments to come forward which will assist in delivering a varied and balanced housing supply and meeting the rising housing needs of Greater Cambridge.

Full text:

1. In accordance with the NPPF, Green Belt boundaries should only be altered in exceptional circumstances through the preparation or updating of plans. Given the significant investment and planned growth in Cambridge and South Cambridgeshire, R2 Developments support the case that exceptional circumstances exist to warrant such a review and consider that a modification to the Green Belt is required to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance.

2. Our client has commissioned a Landscape and Visual Appraisal (LVA) to assess the contribution of their sites (Land the north and east of Barrington Road, Foxton, HELAA Ref: 40412 and Land to the south-east of Cambridge Road, Foxton, HELAA Ref: 40408) to the five purposes of the Green Belt as established by the NPPF. The submitted table extract from the LVA assesses both of the promoted sites’ contributions to the five purposes of the Green Belt.

(SEE SEPERATE SHEET FOR TABLE 1)

3. The content of Table 1 indicates that Land to the north and east of Barrington Road, Foxton (Ref: 40412) does not significantly contribute to Green Belt purposes. Accordingly, the land should be considered for release from the Green Belt and allocation for residential development as part of revised GCLP development strategy which delivers a higher housing requirement to support increased levels of economic growth and development at sustainable rural settlements such as Foxton and other Group Villages.

(SEE SEPERATE SHEET FOR TABLE 2)

4. The content of Table 2 indicates that Land to the south-east of Cambridge Road, Foxton (Ref: 40408) does not significantly contribute to Green Belt purposes. Accordingly, the land should be considered for release from the Green Belt and allocation for mixed use development as part of revised GCLP development strategy which delivers a higher housing requirement to support increased levels of economic growth and development at sustainable rural settlements such as Foxton and other Group Villages.

5. Tables 1 and 2 provide a site specific review of the land’s contribution to Green Belt purposes. The published ‘Greater Cambridge Green Belt Assessment’ prepared by LUC (August 2021) identifies both sites as being within the same parcel reference no. FX2. Our client objects to this approach as the two sites are being promoted separately and are capable of being delivered independently.

6. We note that the Assessment concludes that the release of Parcel FX2 would give rise to ‘moderate high’ harm. The ‘moderate high’ harm conclusion is drawn from the following assessments.

• To preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre – Assessment: No contribution

• To maintain and enhance the quality of Cambridge’s setting – Assessment: Relatively Limited Contribution

• To prevent communities in the environs of Cambridge from merging into one another and with the city – Assessment: Moderate

• Release of land as an expansion of Foxton: Assessment: Minor-moderate

7. The individual strands of assessment do not support the overall ‘moderate high’ harm conclusion. The Green Belt Assessment should be reviewed and amended so that the two sites are assessed individually and to ensure that the conclusion reflects the different strands of the assessment. Tables 1 and 2 should also be reflected in any new assessment.

8. Our client strongly advocates that deliverable and sustainable sites found not to contribute to the five purposes of the Green Belt should be released and allocated for development. This includes Land to the north and east of Barrington Road, Foxton, (HELAA Ref: 40412) and Land to the south-east of Cambridge Road, Foxton (HELAA Ref: 40408). The release of these sites from the Green Belt will allow developments to come forward which will assist in delivering a varied and balanced housing supply and meeting the rising housing needs of Greater Cambridge.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57606

Received: 11/12/2021

Respondent: Mr J Pratt

Representation Summary:

Relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 Greater Cambridge Local Plan First Proposals) - a Local Green Space has to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton for recreation - walkers, runners, cyclists and equestrians - and very good quality agricultural land with rich mixture of fauna.
Honey Hill is flat fenland close to the SSSI at Quy Fen so the relocation of the CWWTP will change that character.

Full text:

Relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 Greater Cambridge Local Plan First Proposals) - a Local Green Space has to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton for recreation - walkers, runners, cyclists and equestrians - and very good quality agricultural land with rich mixture of fauna.
Honey Hill is flat fenland close to the SSSI at Quy Fen so the relocation of the CWWTP will change that character.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57689

Received: 11/12/2021

Respondent: Mrs Jennifer Conroy

Representation Summary:

Supported : Note- Fulfilment of S/NEC Policy through relocation of CWWTP to Honey Hill is contrary to this Policy

Full text:

Supported : Note- Fulfilment of S/NEC Policy through relocation of CWWTP to Honey Hill is contrary to this Policy

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57718

Received: 11/12/2021

Respondent: Dr Cressida Harding

Representation Summary:

I strongly support maintaining the greenbelt. Development of it is only ever appropriate for uses other than housing, e.g. re-wilding or supplying access to green spaces. Developers have a vested interest in representing their proposals as ‘sustainable’, however any housing or building development on greenbelt land is necessarily at odds with the aims of this policy and I do not support it.
The ‘harm rating’ determined in the greenbelt assessments must be recorded within HELAA report assessment as a red-amber-green flag. Else, impact on the green belt is ignored in comparison to the other areas which do attract flag ratings.

Full text:

I strongly support maintaining the greenbelt. Development of it is only ever appropriate for uses other than housing, e.g. re-wilding or supplying access to green spaces. Developers have a vested interest in representing their proposals as ‘sustainable’, however any housing or building development on greenbelt land is necessarily at odds with the aims of this policy and I do not support it.
The ‘harm rating’ determined in the greenbelt assessments must be recorded within HELAA report assessment as a red-amber-green flag. Else, impact on the green belt is ignored in comparison to the other areas which do attract flag ratings.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57723

Received: 11/12/2021

Respondent: Bassingbourn-cum-Kneesworth Parish Council

Representation Summary:

We support this policy.

Full text:

We support this policy.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57795

Received: 11/12/2021

Respondent: Coton Parish Council

Representation Summary:

Coton Parish Council supports the preservation of the greenbelt surrounding Cambridge. The Parish Council strongly opposes the GCP’s preferred off-road busway route through the greenbelt on one of the most visible high points overlooking the City when existing infrastructure exists.

Full text:

Coton Parish Council supports the preservation of the greenbelt surrounding Cambridge. The Parish Council strongly opposes the GCP’s preferred off-road busway route through the greenbelt on one of the most visible high points overlooking the City when existing infrastructure exists.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57968

Received: 12/12/2021

Respondent: Mrs Elizabeth Davies

Representation Summary:

Support the proposed policy direction here, including maintenance of existing Green Belt Boundary on west of Cambridge between city and M11

Full text:

Support the proposed policy direction here, including maintenance of existing Green Belt Boundary on west of Cambridge between city and M11

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58012

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

The current policies carried over from 2018 seem to have little protective effect: in practice the Green Belt seems to be “protected until someone with economic power wants another piece”, as exemplified by the relentless progress of the Biomedical campus and other nearby developments into the Green Belt.

The plan should list specific and very exceptional circumstances that might allow for further destruction of the green belt, and should more clearly demand alternatives of at least equal size and environmental benefit in the area if more land is taken out of Green Belt

Full text:

The current policies carried over from 2018 seem to have little protective effect: in practice the Green Belt seems to be “protected until someone with economic power wants another piece”, as exemplified by the relentless progress of the Biomedical campus and other nearby developments into the Green Belt.

The plan should list specific and very exceptional circumstances that might allow for further destruction of the green belt, and should more clearly demand alternatives of at least equal size and environmental benefit in the area if more land is taken out of Green Belt

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58050

Received: 12/12/2021

Respondent: Histon & Impington Parish Council

Representation Summary:

Building on the green belt should always be a last resort. Whilst acknowledging we need more homes and businesses, green belt is often an easy option but not the best.

Full text:

Building on the green belt should always be a last resort. Whilst acknowledging we need more homes and businesses, green belt is often an easy option but not the best.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58072

Received: 12/12/2021

Respondent: Horningsea Parish Council

Representation Summary:

The Horningsea Parish Council is flabbergasted that the local plan does not mention the proposed move of the Cambridge Waste Water Treatment Plant - a fully functioning waste water treatment plant - to Green Belt. The public has a right to know why it is being expected to give up Green Belt land to relocate a fully functioning wastewater treatment plant.

Full text:

The Horningsea Parish Council is flabbergasted that the local plan does not mention the proposed move of the Cambridge Waste Water Treatment Plant - a fully functioning waste water treatment plant - to Green Belt. The public has a right to know why it is being expected to give up Green Belt land to relocate a fully functioning wastewater treatment plant.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58086

Received: 12/12/2021

Respondent: Mr Daniel Lister

Representation Summary:

The green belt should be protected, and not released for large developments like the expansion of the Cambridge Biomedical Campus when demand could be met through investment within the current campus boundary.

Full text:

The green belt should be protected, and not released for large developments like the expansion of the Cambridge Biomedical Campus when demand could be met through investment within the current campus boundary.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58100

Received: 12/12/2021

Respondent: Jesus College

Agent: Bidwells

Representation Summary:

Para. 149 of the NPPF confirms that exceptions to inappropriate development in the Green Belt can include for limited infilling of villages. The adopted South Cambridgeshire District Council Local Plan includes for a policy to allow for infilling in the Green Belt (Policy NH/9). Policy GP/GB should equally be clear on the forms of development that would not constitute inappropriate development in the Green Belt.

Full text:

Notwithstanding the underlying purposes of the Green Belt (Para. 138 of the NPPF), where it can be demonstrated that appropriate development can be brought forward in the Green Belt, sites should be considered within the context of their individual circumstances.
Para. 149 of the NPPF confirms that exceptions to inappropriate development in the Green Belt can include for limited infilling of villages. The adopted South Cambridgeshire District Council Local Plan includes for a policy to allow for infilling in the Green Belt (Policy NH/9). Policy GP/GB should equally be clear on the forms of development that would not constitute inappropriate development in the Green Belt.
The proposed residential development on Land off Station Road, Harston, is considered appropriate development in the context of Para. 149 and would comprise suitable infill development that would extend only as far as the existing development line of its neighbouring residential and agricultural properties. The proposed residential development would respect the immediate character and would retain the openness of the Green Belt and purpose of the land to the same extent as existing neighbouring development. Land off Station Road is therefore considered suitable to become a residential site allocation as it would comprise a moderate extension to the village and
suitable infill development.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58138

Received: 12/12/2021

Respondent: Mr Matthew Asplin

Representation Summary:

Policy GP/GB is supported in principle in seeking to protect the Green Belt but this isnt reflected throughout the GCLP.
The Government attaches great importance to Green Belts, (NPPF 2021), the essential characteristics of which are their openness and permanence and states that local planning authorities should ensure that substantial weight is given to any harm to the Green Belt.
It is therefore unclear why Policy S/NEC: makes no reference to the corresponding loss of Green Belt land, required to relocate what is a fully operational WWTW in the draft Local Plan to provide a balanced view on land use.

Full text:

Policy GP/GB is supported in principle in seeking to protect the Green Belt but this isnt reflected throughout the GCLP.
The Government attaches great importance to Green Belts, (NPPF 2021), the essential characteristics of which are their openness and permanence and states that local planning authorities should ensure that substantial weight is given to any harm to the Green Belt.
It is therefore unclear why Policy S/NEC: makes no reference to the corresponding loss of Green Belt land, required to relocate what is a fully operational WWTW in the draft Local Plan to provide a balanced view on land use.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58160

Received: 13/12/2021

Respondent: Mrs Hannah Thomas

Representation Summary:

Make this policy stronger as it is currently toothless and weak. At present, the proposed GCP CSET scheme is planned inside the greenbelt, despite there having been an early (and obvious) option outside the greenbelt. This reveals the greenbelt status to be meaningless, and therefore it should be strengthened at every opportunity.

Currently, I feel the Local Plan policy does not take account of the need for high quality agricultural land around Cambridge to remain agricultural land, to feed Greater Cambridge from local sources, and provide more opportunities for farmers markets, local sustainable food initiatives and community forest gardens.

Full text:

Make this policy stronger as it is currently toothless and weak. At present, the proposed GCP CSET scheme is planned inside the greenbelt, despite there having been an early (and obvious) option outside the greenbelt. This reveals the greenbelt status to be meaningless, and therefore it should be strengthened at every opportunity.

Currently, I feel the Local Plan policy does not take account of the need for high quality agricultural land around Cambridge to remain agricultural land, to feed Greater Cambridge from local sources, and provide more opportunities for farmers markets, local sustainable food initiatives and community forest gardens.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58229

Received: 13/12/2021

Respondent: Christ's College

Agent: Bidwells

Representation Summary:

Greater Cambridge Green Belt Study Land Parcel CH10 (South of Cottenham)

As part of the preparation of any local plan, all land within its Green Belt should be thoroughly examined against the five purposes of the Green Belt set out in the NPPF and the three purposes set out in the Local Plan, the outcome of which, should direct if any land should be released from the Green Belt designation if it does not perform well against the purposes. Site CH10 scores low against the five purposes of the the Green Belt. The release of the site from the Green Belt would have negligible harm as supported by the LPA's evidence.

Full text:

As part of the preparation of any local plan, all land within its Green Belt should be thoroughly examined against the five purposes of the Green Belt set out in the NPPF and the three purposes set out in the Local Plan, the outcome of which, should direct if any land should be released from the Green Belt designation if it does not perform well against the purposes. Site CH10 scores low against the five purposes of the the Green Belt. The release of the site from the Green Belt would have negligible harm as supported by the LPA's evidence.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58243

Received: 13/12/2021

Respondent: Cambridgeshire & Peterborough NHS Foundation Trust

Agent: Savills

Representation Summary:

Cambridgeshire and Peterborough NHS Foundation Trust seek a change to the Green Belt boundary at the Fulbourn Hospital site to exclude land in the northern part of the site from such a designation having regard to the existing built built up character of the site and its relationship to Tescos and Capital Park.

Full text:

Savills (UK) Ltd are instructed by Cambridgeshire & Peterborough NHS Foundation Trust to make the necessary and relevant representations to the Greater Cambridge Local Plan – First Proposals Document which has been published for consultation.
We appreciate that the consultation documents reflect the fact that we remain at the early stage of plan preparation and that the document only sets out the broad policy direction of the new Joint Local Plan but nevertheless remains important for the Trust to engage in the plan making process
Policy GP/GB “Protection and Enhancement of the Cambridge Green Belt”
One of the key policy directions within the new Joint Local Plan for Greater Cambridge is envisaged to be the retention of the Green Belt and the relevant policy justification that accompanies this designation. This follows on from references to Green Belt policy within National Planning Policy Guidance which sets out specific requirements for how planning proposals in these areas should be considered as well as providing the reasons why Green Belt designation applies to certain areas.
Paragraph 138 of the NPPF states:
“Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns;
and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land”.
Paragraph 140 then states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or of updating of plans. Consequently, the preparation of a new joint Local Plan provides the opportunity to review such boundaries and in such circumstances is entirely appropriate for the Trust to respectfully suggest the need to amend the Green Belt boundary at Fulbourn Hospital on the basis of the contribution (or not) it makes to Green Belt purposes.
The Trust is the landowner of land at Fulbourn Hospital. The site is bounded to the west by Yarrow Road, by Cambridge Road to the south and by Tescos and Fulbourn Old Drift to the north. The Green Belt designation covers the whole of the site despite a significant amount of built form located in the northern part of the site and planning permission having been granted on 30 April 2021 for a new Resource Centre. This latter development was granted through a demonstration of Very Special Circumstances having regard to the presence of the Green Belt designation and its inclusion as part of the Development Plan.

It is the view of the Trust that legitimate questions should be asked about the appropriateness of including the Fulbourn Hospital site within the Green Belt given the significant amount of built form in the northern part of the site and the consequent character of the site in question. It is also relevant to refer to the commentary contained within the evidence base prepared in support of the initial work on the Local Plan. Topic Paper 5 is the Greater Cambridge Green Belt Assessment report and Appendix B to that document specifically relates to Site CH15 which is the land parcel including Tescos, Fulbourn Hospital and Capital Park immediately east of the hospital site. It is the view of the Trust that the largely built up nature of certainly the northern part of CH15 is such that it merits removal from the Green Belt.

Site CH15 is referred to in Appendix B to the Green Belt Assessment (Appendix B – Cambridge – Arbury to Cambridge North”)

Indeed the Green Belt assessment for Site CH15 states:

“While the southern area of the parcel is more open, the parcel contains more significant urbanising elements including Fulbourn Hospital, Capital Park and a Tescos superstore”. The whole of land parcels CH15 lies adjacent to the existing built up area and it is acknowledged that the presence of a tree line and the edge of the built up area along Yarrow Road means that the views are dominated by urban development which is certainly not a characteristic in our view having regard to Green Belt designation.
Having regard to the three purposes of including land within the Green Belt, we make comment on each of these three purposes in italics below:

Cambridge Purpose 1 - To preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
The Green Belt assessment acknowledges that the contribution is limited. It states that the parcel has some relationship with the urban area and we would certainly confirm that is the case since it lies adjacent to the built up area. The assessment concludes that the parcel makes a “relatively limited contribution to Cambridge Purpose1”

Cambridge Purpose 2– to maintain and enhance the quality of Cambridge’s setting.
It is certainly the case that Fulbourn Hospital, Tescos and Capital Park weaken the rural character of this edge of the City and whilst it is acknowledged that the land falls within Fulbourn Conservation Area this do not relate to land being included within the Green Belt nor the justification for it. Whilst it is the case that the southern parts of the land parcel have more open elements, it is the built up areas to the north and that character which dilutes the importance of including the land within the Green Belt. It cannot be the case that the built up area contributes positively to the character and the landscape and setting and thus there is no case for built up areas such as those being included within Green Belt designation.

Cambridge Purpose 3– to prevent communities in the environs of Cambridge from merging into one another and with the City.
It is the case that the Green Belt assessment confirms that the contribution in this context is “relatively limited” because the land forms an area between Cherry Hinton and the village of Fulbourn where an urbanising development reduces any perceived separation.
It is clear that the Council’s technical assessment work which has looked at the contribution that Parcel CH15 makes to the Green Belt has led to a conclusion which places the land parcel CH15 in the “Moderate High” harm rating as shown in Figure 4.4 below. It is our view that that the character of the land parcel is such that it cannot be classed as a single site since there are clear differences between the more open southern areas at Cambridge Road and the far more built up areas to the north. It is considered that the built up areas to the north of the land parcel including the footprint of the buildings at Fulbourn Hospital should be removed from the Green Belt

The attached plan (taken from the Adopted Local Plan 2018) shows the suggested revision to the Green Belt boundary at it affects the Fulbourn Hospital site.