The edge of Cambridge

Support the policy- details the importance of sustainable public transport links to key facilities in central Cambridge

(Education) The Council will continue to work closely with both Cambridge City Council and South Cambridgeshire District Council in the development of area action plans and policies. One key aspect for education place planning is always around timing of a development and as clear an understanding of housing mix as possible, so as not to destabilise existing provision and to ensure the curriculum effectiveness and long-term financial viability of schools, for example. A second is around connectivity and transport issues for early years and school access with the integration of provision within a community.
There are possibly quite complicated scenarios arising in Cambridge East where the Council will be interested to support policy development.

The Councils are committed to complete the new developments. The Trumpington Residents' Association argues that there is a continued need for support and special provisions while these areas are being completed, even when s106 funding has been used up, including continued support for community development, youth services, etc. The expansion of housing requires an increase in Council provision and officers to support the increased population, from the County Council as well as the City and District Councils (social workers, planning officers, etc.).

Whilst it is recognised that locating development on the edge of Cambridge is a sustainable development option it is considered that too much emphasis is placed on this as a location within the emerging Local Plan. This focus of providing larger sites in this location could lead to problems associated with infrastructure provision and housing delivery. There needs to be a better balance with more housing being apportioned to the rural area. Without a redistribution of housing this would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened. In addition to this there is more of a focus on home working since Covid and less reliance on needing to be close to larger cities so there is not as much need or desire for housing to be located in these types of locations.

To improve and develop the Cambridge Biomedical site for the 2 hospitals and for research is right & sensible. Accommodation at affordable prices for those working on the site, particularly nurses and other medical staff is needed.

West Cambridge: Businesses have already shown they are not interested in moving to this area. Thus those living around the Cambourne area have to work in and around Cambridge and cause a large part of the congestion into the City. There is no point developing this further.

Whilst it is recognised that locating development on the edge of Cambridge is a sustainable development option it is considered that too much emphasis is placed on this as a location within the emerging Local Plan. This focus of providing larger sites in this location could lead to problems associated with infrastructure provision and housing delivery. There needs to be a better balance with more housing being apportioned to the rural area. Without a redistribution of housing this would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened. In addition to this there is more of a focus on home working since Covid and less reliance on needing to be close to larger cities so there is not as much need or desire for housing to be located in these types of locations.

Huntingdonshire District Council has no comment on this matter.

Although no significant growth is yet planned in the greenbelt surrounding Coton, for many years the Parish Council has opposed the GCP preferred C2C off-road busway route which is a consequence of development to the West and East of the village. The proposed destruction of the rural environment and way of life in one of the city's few unspoilt necklace villages has been given very low priority by the GCP and South Cambs District Council. The arguments for our opposition are well rehearsed

The preservation of the semi rural quality of West Cambridge and the Green Belt to the west between the Backs and the M11 is vital for the unique setting of Cambridge in the West and any development of the city edge

There is no limit in the plan on individual scheme sizes on the edge of town. The plan should set out more clearly the requirements on developers to provide better space access and community areas: lessons should be learned from developments like GB1 and GB2 where there will be over 400 properties with NO facilities for inhabitants and poor access routes for pedestrians and cyclists (ie low-carbon transit). As a result In GB1 and GB2 the Council is now in the invidious position of having to mildly request the developers to improve on this – a request so far ignored by the developers. This is not compatible with the stated aim of the plan to build houses which minimise transport and of building new communities.

We are generally and broadly in favour of these developments

Map Fig 25: shows Existing and Proposed allocations outside this broad location, including North East Cambridge covered under Policy S/NEC.
It is noted that the corresponding Waste Water Treatment Works relocation process set out in Policy S/NEC is being led by Anglian Water under a separate process. However, map Fig 25 should also display for reference the proposed relocation site for the Waste Water Treatment Works in a similar manner to the NEC area, to provide proper context for the S/NEC Policy in terms of future land use and corresponding Green Belt cost, or neither until the DCO is approved.

As the Local Plan is progressed, the evidence supporting it and the resulting policies must take a holistic view of the combination of different elements, including the historic and natural environment, which make up the character of Greater Cambridge. This is particularly important when considering the edge of Cambridge and the Green Belt. When identifying land for development, how highly land performs against the functions of the green belt must also be considered against the value of the land for its built and natural heritage.

We support the Councils’ plan to complete the development of new neighbourhoods on the edge of Cambridge as well as bringing forward new opportunities for sustainable developments.

The University will continue to develop the West Cambridge Site and the North West Cambridge Site which are included in the Preferred Options proposals. We also support the North Barton Road Landowners Group’s proposals for the development of South West Cambridge, and consider that this should be included as a site in the Greater Cambridge Local Plan.

General support, but encroachment onto greenbelt must be minimal. Traffic congestion could prevent those in villages reaching education and work within Cambridge. Must be part of an integrated public transport system

In order for the GCSP to plan at a scale necessary to generate investment for significant infrastructure and to meet the housing and employment needs of the area, it is necessary to adopt a strategy that combines different locations for focusing growth. Realistically, a growth strategy that directs new development to the edge of Cambridge is the only option likely to generate the quantity of land in sustainable locations that are suitable for development. This reinforces the importance and value of Cambridge East and the capacity that it is able to deliver through the growth strategy.

As identified through the CPIER (Page 42), Cambridge East is the only side of the city that is not constrained and could accommodate significant levels of housing and employment growth, whilst still having the advantage of being close to the principal centres of employment and the existing transport infrastructure. There are no other sites with this scale of opportunity, that are released from the Green Belt and sustainably located so close to the city centre.

GBI considers there is an over-reliance on the proposed amount and location of development on the northern edge of Cambridge in relation to the distribution and amount of existing and committed employment development to the south of the City.

TMLC supports new development on the edge of Cambridge as a sustainable location for new housing sites. TMLC supports land within the Green Belt on the edge of Cambridge being released for development.

Trumpington South is one such site, which can be delivered within the first five years of the new plan period. It is well connected to existing/proposed public transport nodes (such as Cambridge South Train Station & Trumpington Park & Ride) and it is well connected to jobs (such as the Cambridge Bio-medical campus).

With insufficient brownfield sites in the urban area and too few allocated sites to meet long term demand, new land must be allocated in the Local Plan if growth in Cambridge is to be effectively enabled for the wider benefit of residents and the economy. Given the significant investment planned in new sustainable transport infrastructure, there are places at the edge of Cambridge that offer an equivalent opportunity to accommodate the demand that will come forward in the future in a way that is sustainable and inclusive.

Through the effective development of the CBC Vision 2050, which promotes an inclusive, sustainable, mixed use development approach to improve and grow the Cambridge Biomedical Campus, CBC Ltd and the landowners have shown how edge of Cambridge development, to the south of the Campus could be realised and be effective at supporting the priorities of the Local Plan. We recognise the clear direction in the First Proposals that any expansion of the Campus in this plan period must be focussed on the land immediately to the south of the existing development. We agree that this area could accommodate additional development without undermining the wider function of the Green Belt or impacting on landscape.

With insufficient brownfield sites in the urban area and too few allocated sites to meet long term demand, new land must be allocated in the Local Plan if growth in Cambridge is to be effectively enabled for the wider benefit of residents and the economy. Given the significant investment planned in new sustainable transport infrastructure, there are places at the edge of Cambridge that offer opportunity to accommodate future demand in a way that is sustainable and inclusive. Vision 2050 identifies how the land SE and SW of Cambridge Biomedical Campus can be developed to form a sustainable urban extension.

Edge of Cambridge - general comments Any new site-specific allocations for this area must confirm the need to undertake an appropriate assessment of existing health infrastructure capacity, and require any applicant/developer to fully mitigate the impact of any proposals through appropriate planning obligations – and early engagement with the NHS on the form of infrastructure required.

The site-specific allocations should set out principles for delivering improvements to general health and wellbeing, and promote healthy and green lifestyle choices through well-designed places.

Concentrating development in the Northern and Eastern quadrants will be of significant local benefit.

Teversham is on the eastern edge of Cambridge and will be directly affected by at least four if not five of the planned developments (Marleigh, Bellway, Cambridge East, Coldhams Lane and Ida Dawin). We are concerned that this is overdevelopment. Whilst affordable housing is mentioned, we would like assurances that this is includes real social housing and keyworker housing.

Shepreth Parish Council (SPC) supports the development of Bourn Airfield but would wish to minimise any encroachment on Green Belt.

Broadly supportive but OBJECT to some of the detail. The Biomedical Campus and West and North West Cambridge developments reflect Cambridge’s specific strengths. The availability of the Airport site is another major opportunity to meet growth aspirations. We continue to work with Marshalls, Hills and SCDC as Marleigh is developing as a community as well as a building project within our Parish.

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

Vision and development strategy
Vision and aims
THE VISION
The vision is contradictory, misconceived and undemocratic, unquestioning, unachievable, and based on inadequate evidence. The draft Plan and this whole consultation are premature.

It is contradictory in that the vision of a big decrease in climate impacts is totally undermined by blindness to fundamental incompatibilities between growth and carbon reduction. Its claims of sustainability and Net Zero are not credible given that the carbon costs of construction are not included in the Plan’s definition of a Net Zero Carbon building.

It is misconceived and undemocratic in that it claims to want “the variety of homes and jobs we need” when all the proposed options involve levels of growth dictated by a combination of Government fiat (through both imposed housing targets and four growth corridors led by the Ox Cam Arc) and the ambitions of a local oligarchy (exemplified by Cambridge Ahead) which is unrepresentative of the people of Greater Cambridge. The Arc proposals are in direct conflict with the “levelling up” agenda, will not deliver “levelling up” in terms of Cambridge’s inequalities (notably affordable housing) and should not be taken as justification for the level of growth being proposed (https://smartgrowthuk.org/wp-content/uploads/2021/09/The_Overheated_Arc_Part_3_September_2021.pdf).

The Plan’s “predict and provide” approach fails to even question the desirability or deliverability of this imposed growth. Nor does it begin to tackle the severe challenges arising from past and present growth, notably in terms of affordability (in the most unequal city in England), and transport capacity issues (first identified by Holford 70 years ago), both of which have been exacerbated by growth, and will be further exacerbated, not diminished, by the growth now proposed.

It is unachievable in that
a) it ignores environmental capacity limits, most immediately in relation to water issues, but also in relation to the physical character of Greater Cambridge, and the capacity challenges of accommodating the intense activity of a 21st century city within the built fabric and spaces of a historic University town and its hinterland.
b) its claims to increase nature, wildlife and green spaces rely on a quantum of development that, considered holistically, will have an opposite effect.
c) the Plan’s growth proposals will compound the damaging impacts of current growth on our unique heritage and landscapes.

Its evidence base is incomplete and inadequate. Inexcusably, it has no assessment whatever of environmental capacity (a fundamental issue for the Plan) other than in relation to water supply. The Climate change evidence is inadequate and misleading, notably because it uses a definition of Net Zero Building which omits the embodied carbon of construction. There is no review or assessment of the success or failure of current local plan or other policies. This is compounded by the woefully inadequate historic environment evidence base, which has no strategic consideration of Cambridge as a world famous historic city, and is so incomplete that it only mentions one Conservation Area Appraisal (the Historic Core) when all the city’s Conservation Areas are covered by Appraisals, and fails to use the readily available evidence contained within them.
The draft Plan and the whole consultation are premature pending
1) A thorough understanding and appreciation of the current character of Greater Cambridge and its environmental capacity
2) The forthcoming Water Resources East consultation on the Regional Water Plan, on which these proposals depend
3) Transport solutions which can be accommodated in the space available, including those currently and imminently out for consultation on transport capacity and links within and outside the city.

THE AIMS
The Plan’s aims do not include what is arguably the most vital: how to maintain, enhance, and provide more equitable access to what makes Cambridge special, in the face of the combined challenges of growth and Climate Change. This should be a key priority of the Historic Environment Strategy which is required by the NPPF, but absent from the First Proposals.

As someone from the Tech industry said in a meeting last year with Stephen Kelly, Director of Planning: “Malta has concrete high rises, no one goes there. The Tech sector comes here because it’s a nice place to be. If Cambridge takes a predict and provide approach, it will accelerate into catastrophe.”

How much development, and where – general comments
No more development allocations until issues arising from existing approved growth have been identified and tackled. This means waiting for the Regional Water Plan and coherent publicly-endorsed proposals for tackling existing congestion and capacity issues, challenging the assumptions underlying the Ox Cam Arc, and carrying out a holistic assessment of environmental capacity and the limits to growth. All in line with the principles of Doughnut Economics which the City Council says that it has adopted.

The evidence base is seriously inadequate in relation to environmental capacity. There is no evaluation of the success or failure of existing policies in maintaining the special character of Cambridge, an aim which the new Plan seeks to maintain. Such consideration needs to include not only impacts of the form, scale and location of new development, but also of the transport and other infrastructure required by it. Current growth is putting massive, and unresolved pressures on the capacity of existing transport links, and the physical capacity of Cambridge’s roads system and public realm.

The GCP’s Making Connections proposals, currently under consultation, attempt to resolve some of the challenges, but have no detailed assessment of the capacity of Cambridge’s streets to take the extra volumes of bus and cycle traffic being proposed. Given that Cambridge’s congestion problems are historic, and compounded by growth, this consultation on Local Plan proposals for additional growth is premature in the absence of credible and detailed proposals to tackle current capacity issues.
S/DS: Development strategy
How can the proposals aim for net zero with this sheer volume of proposed development (while whole-life costing of large new proposals is welcome, what about the carbon cost of developments in the pipeline? - see above and comments on CC/NZ below).
No mention of impacts of transport links required for these proposals. Need to ensure that these are brought forward in concurrently with the Local Plan proposals.
Cambridge urban area
Cambridge urban area - general comments

Massive environmental capacity issues, with inadequate space in City streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

No mention of Covid and opportunities for city centre residential / other uses resulting from potential radical changes in retail.
No new cultural or provision for other “city-scale” needs, so putting the city centre under even greater pressure.

S/NEC: North East Cambridge
Vividly illustrates the issues. Gross over development.
Edge of Cambridge
Edge of Cambridge - general comments
The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

This highlights a vital flaw of the Plan, its failure to take a holistic view of the combination of different elements (including historic and natural environment) which make up the character of Greater Cambridge. The Government may have tried to artificially separate the natural and built environment with its Environment Act, but that doesn’t mean this approach should be followed in Cambridge!

Climate change
Climate change - general comments

The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Already out of date in terms of Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice.
Support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. How will this be done? Outline planning permissions must be subject to the aspirations articulated in draft local plan. How will this be done?
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” (sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)
Agree that development should be located so that low carbon transport links can be accessed. However, such locations should not be chosen based on proposed busways – the delivery of these is uncertain and their construction generates carbon emissions through the embodied carbon in the building materials, tree felling reducing carbon capture, maintenance and serving works, and lighting, contrary to the Council’s net zero carbon agenda.

CC/NZ: Net zero carbon new buildings
The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

CC/CE: Reducing waste and supporting the circular economy
Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

Incredibly, no mention of retrofit in the Climate Change topic paper! The Council’s apparent view that retrofit is not within the scope of the Plan is mistaken. The only place in which retrofit is mentioned, and far too narrowly, is in policy GP/CC in the Great Places paper. This is one of several instances where a holistic approach should require read-across between Policies in different sections (e.g. also between historic environment and natural environment).

Retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent.
[Case in point is the new Institute for Sustainability Leadership building (conversion of former telephone exchange) on Regent St. Major impact on appearance of building which makes (or made) a positive contribution to the Conservation Area, not a heritage asset but requiring planning permission. The submitted justification included every possible assessment criterion apart from townscape / heritage impact (shockingly not even considered by the applicants!). What has been approved and is now being built involved losing the window detailing which was a key part of the building’s character. Since that scheme was approved, PAS 2038 (non-domestic retrofit guidance) has come into force: it would have required a more comprehensive approach by the applicants, and might have led to a different decision. ]

Retrofit is also within the scope of the Sustainable Design and Construction SPD, which needs to be updated to include embodied carbon, over the whole life cycle of construction (including retrofit and refurbishment), as set out in British Standard BS EN 15978:2011:
SEE ATTACHED
(slide by Alice Moncaster)

This Climate Change section should include specific policies covering retrofit, which will feature ever more strongly as Govt targets for Band C etc bite. These targets present serious challenges now, and will get ever more serious during the Plan period, with high risks of carbon (and money) being wasted on inappropriate works. Yet Net Zero Carbon for existing buildings is mentioned only cursorily, on a single page (35) of the Local Plan’s Net Zero Carbon Evidence Base.

There is no mention whatsoever of the need for a different approach to buildings of traditional solid wall construction. These form at least a quarter of the existing stock; this proportion should have been considered and assessed as part of the Evidence Base. It could even be as high as 35%, the proportion quoted in the BRE study “Solid wall heat losses and the potential for energy saving” published by DECC in 2015.

The specific challenges of traditional buildings , and the risks of unforeseen consequences (and of consequent waste, rather than saving, of carbon and money) are highlighted in PAS2035, the Government’s guidance on domestic retrofit, which is referenced in Policy GP/CC. However the reference to PAS 2035 in the Policy is futile in its draft form because the PAS (although Government guidance) is not freely available, but published by the British Standards Institute, costing £190, and so is inaccessible to home owners and others who need the guidance.

The Climate Change section of the Plan should quote key principles and guidance* from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with ALL traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. See https://stbauk.org/whole-house-approach/. This is essential to achieve the aims of the PASs and to minimise unintended consequences.
*including (e.g.) section 0.1.1 of PAS 2035:
SEE ATTACHED

Biodiversity and green spaces
Biodiversity and green spaces - general comments
Serious environmental capacity issues (see above), particularly in relation to intensification of pressures on green spaces..

BG/BG: Biodiversity and geodiversity
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” and any other such schemes are protected from subsequent inappropriate changes of use or management)

BG/GI: Green infrastructure
Flawed in that green infrastructure and historic environment re considered separately (see comments on Edge of Cambridge, River corridors, and Protecting open spaces). A holistic approach is essential – see NPPF definition of the historic environment..

BG/RC: River corridors
The River Cam Corridor initiative does not mention the historic environment, historic environment designations, or conservation area appraisals. High risks of more intensive use. no mention of environmental capacity issues or recognition that there may be capacity limits to growth or access by either/both local people and visitors (impacts of punt operators on Cam, etc). No mention of historic environment designations. No consideration of areas under particular threat. No consideration of historic / characteristic uses and land management. The whole river corridor from Byron’s Pool to Baits Bite, and its historic uses are vital parts of the historic and cultural as well as landscape character of Cambridge and should be safeguarded. Grantchester Meadows, one of the key river corridor historic and cultural spaces, is the only vital section of the corridor currently without Conservation Area designation; it is currently threatened by visitor pressures and by possible removal of the grazing cattle which play a vital part in traditional water meadow management.

BG/PO: Protecting open spaces
No mention that many open spaces are historic, and form part of the historic environment (see NPPF definition of the historic environment) need to consider their significance as a whole, not just in terms of green infrastructure. Historic environment and local identity are vital elements of the wellbeing identified here

BG/EO: Providing and enhancing open spaces
Open space is not just green space - what about the market square, Quayside etc etc? Need to manage existing pressures, and avoid harmful intensification of use, on all open spaces, and ensure that new development does not increase these pressures. The river corridor is particularly vulnerable.


Wellbeing and inclusion
Wellbeing and inclusion - general comments
There are no documents in the Document Library to support this theme. Why not?

The Topic Paper highlights the importance of place and space, but its text is focused on new developments, and does not mention the contribution made to wellbeing by the beauty and special character of existing places, including the city of Cambridge, the towns and villages, and valued countryside. The historic environment is a vital part of wellbeing.

Nor is Covid mentioned, even though the pandemic has highlighted the vital importance of access to local green space, and to local fresh food. Small local producers have continued to provide when the supermarkets supply chains fail. Cambridge market, and the local producers who sell from it, continues to provide a lifeline of health and wellbeing for many people, as well as providing vital opportunities for business start-ups including makers as well as food sellers.

There is no assessment of existing cultural activities, of current demands for space, or of demands for new space arising from either existing approved growth or that now proposed. Nor is there any assessment of related opportunities in terms of under-used retail space post-Covid. This is a totally inadequate baseline for a credible Plan.

The forthcoming Cultural Infrastructure Strategy for Greater Cambridge will need to recognise Cambridge’s international cultural significance in terms of both its historic environment (which meets UNESCO’s Outstanding Universal Value criteria for World Heritage sites), and its past and present cultural activities. The Local Plan should include policies to protect this significance, and specifically to support cultural activities, and to provide for, and safeguard, public and private spaces for arts and other activities.

Great places policies
Great places – general comments

The Great Places paper refers to Heritage Assets, but completely fails to recognise that the city of Cambridge is a heritage asset of worldwide significance which meets UNESCO’s Outstanding Universal Value criteria for World Heritage status. This significance derives from the combination of its built and natural heritage. The draft Plan fails to recognise the vital role which this special character plays in making Cambridge a great place to live in, work, study, and visit.

The draft Plan also fails to recognise the historic relationships between Cambridge as a market town, its market, and its productive hinterland.

The draft Plan’s approach involves a false separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Cambridge’s special character has been, and continues to be, under severe threats from the quantum of already approved growth (built developments and pressures on both streets and green spaces). There are severe environmental capacity issues in trying to accommodate the demands of a 21st century city within what remains the built fabric and spaces of a medieval market town. These fundamental conflicts between growth on the one hand and environmental capacity and special character on the other should have been recognised as a key challenge for the draft Local Plan. so why wasn’t the Historic Environment Baseline Study prioritised, and published as part of the Nov 2020 tranche?

But the draft Plan documents include no assessment of current pressures, let alone the impacts of the draft First Proposals.

Instead, para 3.2.4 of the Strategic Heritage Impact Assessment: baseline makes a totally unevidenced statement that:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity".

Overall, the Evidence base for Great Places is inadequate, and the proposals are premature pending a thorough review of the success or failure of existing policies.


GP/LC: Protection and enhancement of landscape character
Over-intensification of use is a major threat to landscape character.

GP/GB: Protection and enhancement of the Cambridge Green Belt
I strongly support protection of the Green Belt, but the Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

The Council appears to have forgotten that the Green Belt was set up to protect the setting of the historic University city.

GP/QP: Establishing high quality landscape and public realm
Serious issues of street capacity.

GP/HA: Conservation and enhancement of heritage assets
A vital issue given totally inadequate consideration and priority. The historic environment (not just heritage assets) is a vital part of Cambridge, not just in terms of Great Places, but also for Wellbeing, and for the city’s prosperity.

The historic environment, and its capacity (or not) to withstand existing growth (let alone new growth proposed) should have been considered at the start of the Great Places chapter. Understand what you have, then consider its capacity for change
Fails to consider anything other than designated heritage assets. No consideration of heritage significance of Cambridge as a whole, or of the heritage significance of undesignated buildings, spaces, and intangible heritage –notably Cambridge’s market, which pre-dates the University, and Grantchester meadows.
The Heritage Impact Assessment is not fit for purpose, and clearly written by consultants who have limited knowledge of Cambridge, and of issues, policies, and initiatives relating to its historic environment. There is no mention of any Conservation Area appraisal apart from the Historic Core, and no cumulative assessment of significance and issues identified in these Appraisals.
.
The “Strategic Heritage Impact Assessment: baseline” is woefully inadequate in both its scope and its approach:
a) In its scope, because it confines itself to stages 1 (identify the historic assets” and 2 (“define and analyse the settings”) of Historic England’s ”Settings of Heritage Assets: Good Practice Guide”, without considering the dynamic of the city as a whole, what has been happening in its recent years, or the potential impacts of currently approved growth. It is almost as if the Council asked for an updated version of the 1971 publication “Cambridge Townscape”, whilst completely disregarding the award-winning conservation plan approach of the 2006 Historic Core Appraisal which sought to understand not just the physical character of Cambridge but its dynamic, and threats and opportunities, as part of shaping policies.

b) while the document references the Historic Core Conservation Area Appraisal, it does not even mention other Conservation Area Appraisals (ignoring the complete Appraisal coverage of the City's Conservation Areas) or issues and opportunities identified therein. Nor does it mention the Suburbs and Approaches Studies. It is all too clear that the consultants have taken only a superficial look at the baseline information.

c) I would have expected consultants preparing this “high level” document to consider the historic environment, and the extent of designations, strategically (a great opportunity for this combined Plan) - but the document does not even consider the extent to which Cambridge’s historic and cultural landscape (including the river corridor from Byron’s pool to Baits Bite Lock) is or is not protected.

d) The study completely fails to assess the significance of Cambridge as a whole. Dennis Rodwell’s “Conservation and Sustainability in Historic Cities” puts Cambridge on a similar level of international significance to Venice.

e) For the options involving development in and adjacent to Cambridge, it seems to assume that most problems can be resolved by Design, completely ignoring environmental capacity issues. At a most immediate level, what if any detailed assessment has been made of the wider visual impacts of tall buildings on the North-East Cambridge site?

There are fundamental environmental capacity issues in terms of pressures on the character and spaces of the historic core and surrounding landscape, due to not only the additional volumes of development, people and traffic being generated by the proposed additional growth, but all of these arising from existing approved growth plus the transport links required to enable it.

There is no assessment whatever of the cumulative impacts on landscape, townscape and environmental capacity of all the GCP and other proposals including busways, City Access, Greenways, Active Travel schemes etc.

A third-party, holistic overview is essential to identify and try to resolve some of these key strategic issues and balances, and consider to what extent further growth is viable. In relation to heritage, growth is seriously threatening what makes Cambridge Special. I suggest that Historic England’s Historic Places Panel are invited to visit Cambridge and provide strategic recommendations which can inform the Local Plan.

The flaws in the current approach are exemplified by a claim in the Strategic Heritage Impact Assessment: baseline:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity"
This statement can only be described as unevidenced, shockingly ignorant and ludicrously complacent.
Moving from strategic issues to safeguarding individual heritage assets and their settings, there are serious questions in relation to the effectiveness of existing policies which are proposed to be carried forward.

A case in point is the former Mill Road Library a grade II listed building of high public significance, which was recognised to be “at risk” but ignored by both the City and County Councils during the development and approval of the City’s Depot site redevelopment. This was a massive opportunity which would not have been missed had the City complied with its own Local Plan policy regarding heritage assets. While the County has belatedly refurbished the former Library, it has not been integrated as a public building within the new development. It appears that the County may now be offering this public building, built for the public, for private sale!

GP/CC: Adapting heritage assets to climate change
This policy is basically very good -but should relate to all buildings of traditional construction, and needs some updating. Needs direct read-across to CC/NZ. See my comments on CC/NZ.
Supporting documents on which we are consulting
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)

The Sustainability Appraisal fails to tackle the key environmental capacity issues arising from existing growth, let alone that now proposed.

The whole definition of “Sustainable Development” is too narrow given that since 2010 the UN has included Culture as the 4th pillar of Sustainable Development - and Cambridge's historic environment is a cultural asset of worldwide significance.

Within the current UK sustainability assessment process (dating from 2004 and excluding culture), there is a separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Edge of Cambridge - general comments:
We are very concerned at the apparent lack of consideration for Cambridge’s historic environment. For example, the Green Belt assessment omits consideration of historic environment designations and landscape character constraints. We agree with Cambridge Past, Present and Future’s policy statement that “preventing urban sprawl so as to protect the setting of the historic city is irreconcilable with continued city fringe development.” [1]
[1] https://www.cambridgeppf.org/cambridgeppf-green-belt-policy

SUMMARY BELOW, REPRESENTATION DOCUMENT ATTACHED

ADDITIONAL DOCUMENTS SUBMITTED TO HELAA SITE 40096

7. Summary & Conclusions

7.1. The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

7.2. The JLP also does not identify how Cambridge can meet its future job targets or identified need, particularly in the mid-tech sector. To achieve the transport, employment and socio economic aims of the JLP, and separately the NECAAP, a radical reappraisal and interrogation of its supporting evidence base is required.

7.3. The evidence base is inconsistent and in places flawed. An allocation for CSPN provides the supporting policy and development management framework to recognise and harness CSP’s continued evolution and regional role as a significant contributor to employment, research and development for the Cambridge and UK economy. Additionally, an allocation for CSPN provides the capacity to deliver on the JLP’s stated employment aims. Its allocation is also an exciting opportunity to keep Cambridge at the forefront of innovation, securing a mid-tech future for Cambridge, the region, and the UK as a Scientific Superpower. Cambridge Science Park

7.4. Cambridge Science Park is the most sustainable location for further employment growth within Greater Cambridge, therefore the emerging JLP should reference the continued importance of Cambridge Science Park as an employment site.

7.5. Given the recognition of all other comparable science parks and employment destinations within the emerging JLP, and the recognition that North East Cambridge is the most sustainable location for development in Greater Cambridge.

7.6. The emerging JLP should therefore include the following policy: Policy S/CSP: New Employment Provision – Cambridge Science Park Appropriate proposals for employment development and redevelopment on Cambridge Science Park (as defined on the Policies Map) will be supported, where they enable the continued development of the Cambridge Cluster of high technology research and development companies. The need for Mid-Tech

7.7. As part of our Call for Sites submission we provided a 2019 report by Volterra (resubmitted for ease of reference), which clearly set out the floorspace requirements of mid-tech occupiers, to 2031 as ranging between c. 80,000 - 450,000 sqm of new floorspac.

7.8. A further Technical Note by Volterra is submitted with these representations setting out our feedback on the methodology and why we believe that the emerging mid-tech sector is not appropriately considered or acknowledged in these requirements, leading to a substantial under-provision of space which, if taken forward, will result in constraints on employment growth in the future. The importance of mid-tech and why it is not covered in the Employment Land Review are summarised as follows: • Mid-tech is not included in the ‘key sectors’ that are used to forecast employment need as these identify previously growing sectors, rather than future growth sectors; • The densities and use classes used to estimate future floorspace need may not be appropriate for the mid-tech sector.

7.9. We would urge Greater Cambridge to review the evidence with regard to mid-tech needs, and to engage with the Cambridge Science Park team to understand the needs of the sector.

7.10. We ask why has there been no consideration of mid-tech as a growth sector? Had this been done, it would be clear that (i) it has a large growth potential and (ii) it would benefit from clustering with CSP.

7.11. Our own analysis of the sectors which make up mid-tech highlights a very significant concentration of mid-tech in the local area. Why is this not acknowledged or given any weight?

7.12. The emerging JLP should recognise the importance of the research, development & innovation that occurs within the Cambridge economy and the need to accelerate the move to net-zero by supporting scientific innovation. The appraisal of CSPN

7.13. A review of the HELAA results for the other large employment sites identifies that there are other sites scoring similarly that are taken forward for Green Belt release.

7.14. Interrogating the two red scores for CSPN these relate to Landscape and the Strategic Highways Impact, the former has been considered on a strategic basis and takes no account of the local landscape (ie the impact of the A14) nor the landscape improvements included within the proposals. The Strategic Highways Impact is questioned for a scheme committed to no net increase.

7.15. However, despite CSP North being categorised as Red for its suitability, the site has been carried forward for the SA and an appraisal undertaken.

7.16. The site again scores similarly to other Green Belt sites taken forward for release. The SA then undertaken for the policies relating to those sites includes the policy mitigation, for example where landscape improvements are included within the policy, those sites are then afforded a more positive score than a site not taken through to policy wording. If this approach were undertaken for CSPN the site would score similarly well through the SA process.

7.17. The arguments made for other sites could also be said of CSP/CSPN but in the context of midtech rather than life sciences. CSP plays a recognised role in the clustering and growth of high-tech firms, supporting start-ups and scale-up businesses, but now needs space to enable mid-tech firms to continue to innovate and grow here. Whilst this growth could occur to a lesser scale on alternative sites outside the Green Belt, this would not benefit from the clustering with CSP and therefore the growth would be lower and less productive (the opportunities provided by a co-located Campus). CSP has, and CSPN will, be subject to significant private sector investment (just as valuable – arguably more so – than public investment) which in turn will deliver benefits to the public sector, such as playing a crucial role in delivering the sustainable travel objectives of the area.

7.18. It is therefore questioned as to why these arguments are recognised in the context of other Green Belt sites but not CSPN? Exceptional circumstances

7.19. The need for mid-tech is demonstrated, and the need for this type of employment space in close proximity to Cambridge Science Park and Cambridge Science Park has a distinct and unique set of characteristics, not available anywhere else at other research facilities in the sub-region and fully aligned with the Government’s Industrial Strategy.

7.20. CSPN would benefit from proximity to CSP and the long term custodianship of Trintiy College Cambridge, the later having made CSP one of the most successful Science Parks in Europe.

7.21. The socio-economic benefits in this location are illustrated, and links to Cambridge Regional College and wider educational institutions will benefit the next generation of innovators.

7.22. The sustainability credentials of delivering this site on a key transport route are clear, whilst the vision for a site with the highest environmental quality are demonstrated. Risks to NECAAP

7.23. Without significant interventions such as those which may be delivered by CSPN, a reduction in vehicle trips at CSP, sufficient to allow the delivery of the wider NECAAP will be difficult to deliver.

Conclusion

7.24. The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

7.25. The JLP also does not identify how Cambridge can meet its future job targets or identified need, particularly in the mid-tech sector. To achieve the transport, employment and socio economic aims of the JLP, and separately the NECAAP, a radical reappraisal and interrogation of its supporting evidence base is required. The evidence base is inconsistent and in places flawed.

7.26. An allocation for CSPN provides the supporting policy and development management framework to recognise and harness CSP’s continued evolution and regional role as a significant contributor to employment, research and development for the Cambridge and UK economy. Additionally, an allocation for CSPN provides the capacity to deliver on the JLP’s stated employment aims. Its allocation is also an exciting opportunity to keep Cambridge at the forefront of innovation, securing a mid-tech future for Cambridge, the region, and the UK as a Scientific Superpower.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). While it is acknowledged that the principle of this growth is already established through adopted development plan documents, the additional dwellings at Cambourne is proposed through the emerging GCLP and associated East West Rail.
While it is acknowledged that the Council's preferred development strategy is to utilise those edge of Cambridge sites which were previously developed, the redevelopment of both North-east Cambridge and Cambridge East poses significant challenges. North-east Cambridge requires the relocation of a sewage treatment works and existing businesses; Cambridge East requires the relocation of airport related uses and businesses. The development of these site is therefore very complex and highly likely to cause delays to delivery within the plan period and also highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The Councils' preferred development strategy also refers to speeding up housing delivery rates at some new settlements. However, there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. The Councils have not evidenced if any site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings per year over the plan period.

In order to ensure that the overall plan is deliverable, there needs to be greater certainty that sites will come forward within the plan period to deliver the growth required and, in turn, to address the under-delivery of affordable housing within Greater Cambridge. This under­ delivery is evidenced through the affordable housing contributions that have come forward on major strategic sites as follows:

• Northstowe (Phase 1and 2) - 20%

• Waterbeach - 30%

• Cambridge East - (Wing) - 30%

• Cambourne West - 30%

The development strategy should allocate some sites that are capable of delivering policy­ compliant levels of affordable housing. Land at Gazelle Way does not have infrastructure constraints and, as such, can provide policy-compliant levels of 40% affordable housing to help address the significant under-delivery in Greater Cambridge. The potential for sites like this to deliver policy compliant levels of affordable housing has been evidenced at Land north of Cherry Hinton.

It is acknowledged that the development of Land at Gazelle Way requires some release of land from the Green Belt, and that the Council have dismissed this as a preferred option as per the following conclusion:

"Whilst edge of Cambridge Green Belt sites performed in a similar way in many respects to Cambridge East, they would have significant Green Belt impacts and given the relatively good performance of Cambourne, which is not in the Green Belt and would benefit from there was considered to be no exceptional circumstances for releasing land on the edge of Cambridge to meet development needs as a matter of principle and that spatial option was not preferred."

Greater Cambridge has significant affordability issues and addressing such affordable housing needs should be a priority for the Local Plan. Allocating the land east of Gazelle Way which will deliver the affordable housing required provides justification for the release of Green Belt land, especially since this land is located sustainably and is well served by public transport as required by paragraph 742 of the NPPF when reviewing Green Belt boundaries.

Land at Gazelle Way is located on the edge of Cambridge, only three miles from the City Centre. The site benefits from existing sustainable transport infrastructure, including access to existing cycle routes and bus service provision to access surrounding local amenities and facilities, as well as convenient access into the City Centre. The site will also benefit from being located along the proposed Fulbourn Greenway route and has potential to accommodate a new train station along the Cambridge-Ipswich line. The accessibility of the site is not reliant on expensive major new infrastructure.

The development strategy needs to fully embrace and reflect the strategy for the City of Cambridge to be net zero carbon by 2030. The allocation of highly sustainable sites where housing and jobs are located together, reducing the need to travel, will be instrumental in achieving this goal. The Land at Gazelle Way is within a highly accessible location which means that new residents would not be reliant on their cars to access jobs, shops or socialise either within the Site or within the City. The vision for this site is to provide a highly sustainable community which locates homes and jobs together.

In summary, Endurance Estates wish to object to the 'high risk' nature of the development strategy, which is dependent upon the delivery of some strategic, complex sites. The development of these is highly likely to cause delays to delivery within the plan period and highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The development strategy should allocate some additional sites such as Land east of Gazelle Way that are capable of delivering policy compliant levels of affordable housing. The allocation of the site would also contribute to the Council's aspirations to become a zero-carbon authority by 2030 by offering an opportunity to be a truly sustainable community which locates homes and jobs together.