S/RRA: Allocations in the rest of the rural area

Great & Little Eversden ; The proposed sites lie in the greenbelt and outside the villages’ existing Development Framework Boundary. The proposed developments significantly exceed in scale Policy S/12 for infill villages in the South Cambs Local Plan, Sept 2018
. The rejection of the proposed sites is the correct one for a community with virtually no infrastructure or local amenities where such quantities of additional homes will be wholly unsustainable.
The Eversdens needs sensitive improvement in infrastructure – above all, one greenway cycle path to Comberton - for the future of our community

We act for (text redacted) in respect of Land off High Street, Little Eversden (Site Ref: 40211).

On behalf of our client, we make the following comments on the Regulation 18 Preferred Options Consultation.

We act for KB Tebbit Ltd in respect of Land off Chapel Road, Great Eversden (Site Ref: 40212).

On behalf of our client, we make the following comments on the Regulation 18 Preferred Options Consultation.

The local plan for S/RRA/H Land at Highfields (phase 2), Caldecote should be amended to account for both factual errors and alignment with previous planning applications for this site if this land is retained within the local plan.

See attached files for revised plans and wording, justification, and additional information.

We act for KB Tebbit Ltd in respect of Land West of Comberton (Site Ref: 40152)

On behalf of our client, we make the following representations on the Regulation 18 Preferred Options Consultation.

The First Proposals document makes very few additional allocations in the rural area and Janus Henderson objects to this approach.
It is requested that Site Reference S/RRA/H/3 : Fulbourn and Ida Darwin Hospitals be extended to include Capital Park as it is considered a suitable and sustainable location for additional development. In order to achieve the identified development aspirations it is also appropriate to release the developed area of Capital Park from the Green Belt.

This policy is considered to only illustrate further the lack of distribution in housing and employment sites across villages within South Cambridgeshire. The vast majority of proposed allocations are carried forward, with only 3 new residential allocations and a single new mixed use allocation. These sites are in Melbourn, Caldecote and Oakington. The latter two of these both being Group Villages like Hauxton. The residential allocations propose a total of 104 homes and the mixed use allocation 120 homes. These are considered to be small additional contributions to housing allocations in the entirety of the rural area.

Furthermore, whilst land has been allocated for employment uses, specifically research and development facilities, these are at established sites such as the Genome Campus, Babarham Institute and Cambridge Biomedical Campus to strengthen existing clusters. However, as identified in the Council’s own employment evidence base, Greater Cambridge has a diverse range of employment sectors and in order to ensure that existing settlements benefit from jobs in close proximity to their homes to reduce the need to commute into Cambridge and further afield, consideration of new employment allocations within and close to existing settlements should be examined further as part of the next stage of the Local Plan. The FWWTW site provides an opportunity for consolidating the employment opportunities that have been created by the adjacent Mill SciTech Park on the eastern side of the A10.

If the Councils are of the view that new housing and employment uses will come forward through windfall sites, then Bridgemere Land Plc consider that this is highly unlikely. The settlements in South Cambridgeshire have tight settlement boundaries and the availability of land within these boundaries for future housing and employment development is limited. This is evident given the exceptionally high demand for land for development in the district. Indeed the risk may be that small sites come forward for 2 or 3 houses at a time, given the size of plots, which will increase the overall population of existing settlements, but without the means to secure funding to improve local services and facilities. As such, the Council should be taking a more comprehensive approach, whereby housing and employment allocations are identified at this stage to deliver much needed homes and jobs in a planned manner, alongside funding for important local infrastructure.

The Greater Cambridge Local Plan Development Strategy Options – Summary Report (November 2020) sets out work undertaken to assess further whether the spatial choices set out in the Greater Cambridge Local Plan: First Conversation consultation were indeed reasonable.

Consequently, eight choices were taken forward for testing as strategic options, which included:

‘Spatial Option 5: Focus on Dispersal: Villages - this approach would spread new homes and jobs out to the villages.’

The document sets out that such distribution would ‘result in multiple smaller sites that are likely to be deliverable in the short to medium term; this would also meet the NPPF requirement to allocate a percentage of small sites.’

It was however considered to be the worst for carbon emissions with the worst transport links. However, this is a generalised statement and does not recognise the different attributes of individual settlements. Key to a sustainable scheme is accessibility. Hauxton is in close proximity to Cambridge, the largest settlement in the Greater Cambridge area and the location of the major employment, retail and leisure opportunities. Cambridge is readily accessible from Hauxton (and vice versa) by bicycle, bus or via Park and Ride, and by car would only be subject to very short journeys. It is also at the confluence of several forthcoming transport initiatives, which will place the Site within a dynamic and highly sustainable transport corridor.

It is therefore considered that the conclusion reached in the evidence base is not representative of Hauxton, and that the Council should give further consideration to the delivery of housing and employment in this location, which relates to further comments that Bridgemere Land Plc have to Policy S/RRA - Site H/2 - Bayer CropScience Site, Hauxton.

Policy S/RRA - Site H/2 - Bayer CropScience Site, Hauxton:

The First Proposals Consultation Document contains Draft Policy S/RRA which comprises a small number of site allocations within the rural area. As part of this policy, Site H/2 is identified as the Bayer CropScience Site to the East of the A10 in Hauxton. It is proposed that the proposed policy direction for this site will be amended from the adopted 2018 Local Plan, to encompass only the employment areas of the Bayer CropScience site, which are still to be developed, the rest of the scheme now having been completed and occupied.

At this stage, the proposed policy direction is limited within the consultation document and therefore it is not clear whether the emerging policy will contain similar provisions within the supporting text, concerning the FWWTW site. Paragraph 7.13 of Policy H/2 in the adopted 2018 Local Plan sets out the following:

Proposals for the redevelopment of the recreation buildings and waste water treatment facility on the western side of the A10 will be considered in the context of proposals that do not comprise inappropriate development within the Green Belt. As a planning objective it would be highly desirable to secure the removal of the incongruous industrial structures on the western part of the site. Particular consideration should be given to proposals that remove these structures and improve the visual appearance of the Green Belt through proposals that are consistent with Policy NH/9 and the NPPF (2012) paragraph 89.

Whilst not contained within the specific wording of the policy, the identification that the remediation of the Site is a planning objective and that particular consideration should be given to proposals that remove the existing structures and improve the visual appearance of the Green Belt are of use in determining planning applications for the Site, including the recent permission for 32 homes on the Site.

During the determination of the planning application for 32 homes, it was apparent to all parties, the highly complex nature of the Site, which aside from its planning designations, has a significant number of environmental requirements to satisfy in order to remove the contamination from the Site. This unique set of circumstances ultimately informs the type and scale of development needed on the Site in order to see it remediated, the existing structures removed and an appropriate scheme found for the Site, which improves the visual appearance of the Green Belt. Such a scheme is highly likely to be for a greater quantity of homes than currently approved or alternatively an employment use to complement the Mill SciTech Park.

This would be in accordance with the objective of paragraph 145 of the NPPF, which ‘sets out that once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, including looking for opportunities to improve damaged and derelict land’.

Furthermore, paragraph 119 of the NPPF sets out that ‘strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield land’. This is a strategy which the Government have continued to advocate through recent briefings and the Autumn Budget 2021.

Taking this into account and given the unique circumstances of this Site, Bridgemere Land Plc are of the view that the Site requires more than a supporting paragraph within the emerging Local Plan, but a policy of its own, in order to fully realise the development potential of this Site. Therefore, the Site has been put forward as a Major Development Site within the Green Belt as part of the Call for Sites Consultation 2021.

The extant planning permission demonstrates that it is possible for a scheme to come forward on this land within the Green Belt, utilising the Previously Developed Land. However, given the complexities of the Site, specifically around the extent of remediation required, it is vital to include a site specific policy within the emerging Local Plan, which recognises the complete development potential of this Site for delivery of housing, employment or a mixture of both and to support its delivery, which Bridgemere Land Plc consider to be greater than currently approved.

The Green Belt Assessment (2021) undertaken by LUC on behalf of Greater Cambridge places the Site into Parcel HX12. Within its assessment, it identifies that the parcel makes limited or no contribution to the preservation of Cambridge as a compact, dynamic city and that it makes a relatively limited contribution to maintaining and enhancing the quality of Cambridge’s setting and preventing communities from merging with one another, in this context, Hauxton and Haslingfield.

Notwithstanding this, the assessment identifies that the release of the land as an expansion to Hauxton would not be favourable, given the presence of the A10 as a strong separating feature between the settlement of Hauxton and parcels of Green Belt to the west, including Parcel HX12. As such, the suggestion is to not release the land from the Green Belt, but to identify it as a development site within the Green Belt, taking into account national and local Green Belt policy, but also recognising that the Site does have a very special set of specific circumstances, which need to be considered as a whole in order to bring forward this Site and see it improved for the benefit of all. Bridgemere Land Plc consider that these specific circumstances of the Site which include the ability of a scheme to remediate the contamination on Site and making the most efficient use of the previously development land resource available, requires a scheme of greater scale than currently approved and that working collaboratively with the local planning authority and key stakeholders this can be achieved on the Site.

To facilitate this, a site specific policy should be included in the emerging Local Plan and to assist the Council, such a draft policy for the Site could include:

A. Proposals for the re-development of the Former Waste Water Treatment Works, Hauxton as previously developed land within the Green Belt will be permitted where the re-development:

a. contributes towards local housing needs and/or provides new jobs;
b. removes the existing incongruous industrial structures on the western part of the Site;
c. would not have significantly greater impact on the openness of the Green Belt;
d. where the scheme delivers significant environmental benefits including remediation of the Site and that these benefits are recognised as very special circumstances that should be given great weight in the planning balance and consideration of harm;
e. improves the visual appearance of the Green Belt through a comprehensive landscaping strategy;
f. where possible, seeks to connect to existing and/or emerging sustainable transport schemes linking to existing villages and the City of Cambridge; and,
g. contributes to the authorities’ sustainable development principles as set out in other policies in the Plan.

B. The Council will assess the proposed re-development scheme based on the following:

a. the very special circumstances of the re-development scheme and ensuring that site specific benefits are given great weight against any assessment of harm to the Green Belt;
b. the visual impact of the development would not cause substantial harm to the Green Belt, when taking account of the existing built form, the context of the Site, the significant environmental and/or employment/housing benefits and the notable features, including new transport projects within the vicinity;
c. the activities / use of the new development compared to the existing/established use;
d. the contribution of the development to remediate the Site so that it diminishes the risk to human health and the environment and provides a safe and habitable/working environment for the end users; and
e. taking into account other policies within the Plan when taken as a whole.

Wider Green Belt Context
As part of the consideration for this Site, one needs to recognise that there are a number of emerging local transport schemes in close proximity to the Site, as outlined in paragraph 2.8 above, which will alter the visual context of the Site, but also bring with them considerable improvements to sustainable connections between the Site and the City. These schemes are being brought forward by the Greater Cambridgeshire Partnership in conjunction with Cambridgeshire County Council and the East West Railway Company and have funding and approval to move forward to construction, subject to obtaining the relevant consents. All are located in the Green Belt:

(a) A new travel hub on land to the west of junction 11 of the M11, to the north of the FWWTW and west of the A10. This travel hub will provide 2,150 car parking spaces, 326 cycle parking spaces and associated coach parking, a new travel hub building, bridge across the M11 and associated highway infrastructure works to the M11 junction and dedicated busway into Cambridge. Whilst the planning application for that scheme still remains under determination by the County Council, the location of that site within the Green Belt to the proximate north-west of parcel HX12 is notable and will alter the appearance of this part of the Green Belt.

(b) A number of Greenways have been approved linking villages on the periphery of Cambridge with the City and the Partnership are in the process of detailing these routes. Immediately to the west of the site, will be the junction for the Melbourn and Haslingfield Greenways, with their indicative route into the City Centre utilising land directly to the west of the Site. This Greenway will link into the new travel hub to the north, providing onward routes for pedestrian and cyclists over the M11 and into Cambridge. As a shared use path, it is expected that it will be approximately 3 m in width, potentially with some level of lighting, and will certainly form a new distinctive western edge to the FWWTW Site.

The above are important factors to consider and ones that could equally be harnessed for the benefit of a future scheme on the Site.

Whilst the Site is seen to be separated from the core settlement of Hauxton, the above context demonstrates that to the west of the A10 a sustainable transport corridor is highly likely to come forward, which places this previously developed site in an ideal location to provide a scheme which can contribute towards meeting local housing and/or employment needs in a highly sustainable location and a rapidly-changing context, which makes it very unique and readily deliverable.

Small sites in rural villages can provide excellent opportunities for self-build and custom built houses which would see councils meeting the demand for this type of housing as well as meet the needs for local housing, whilst fulfilling their obligations in line with the Self-Build and Custom Housebuilding Act 2015. This policy makes no reference to meeting this obligation. Focusing on offering self-build plots within larger housing developments is not proving to be a successful strategy, and by allocating smaller sites in rural areas this demand would be met and
contribute to the sustainability and vitality of rural villages. Self-build and custom-build development will provide sensitively designed dwellings which will enhance the setting of the village along with providing much needed housing. This will also provide economic benefits through the construction jobs created and from owner/occupiers using local services and facilities.
When undertaking the consultation of the South Cambridgeshire Local Plan, the Council proposed to
allocate a site on Toseland Road, Graveley, for residential development. This site is outside of the
settlement boundary, whereas the proposed sites of south of the High Street, Graveley (site ref: 40231), land at Manor Farm Site, Graveley, (site ref: 40229) and land adjacent Ponds Farm Cottage, Graveley (site ref: 40234) are all better placed to offer housing sites as they are contiguous to the settlement boundary. Although the site on Toseland Road was not allocated, this demonstrates that previously the principle of development outside of the settlement boundary was acceptable. Furthermore, although the site on Toseland Road was supported by the Council, during this time, the land at Manor Farm Site (site ref: 40229) was also considered for development and received local support.
The National Planning Policy Framework 2021 sets out in paragraph 79 that to promote sustainable
development in rural areas, housing should be located where it will enhance or maintain the vitality of
rural communities. Planning policies should identify opportunities for villages to grow and thrive,
especially where this will support local services. Where there are groups of smaller settlements,
development in one village may support services in a nearby villages. The land off the land south of High
Street, Graveley, land at Manor Farm Site, Graveley, and land adjacent Ponds Farm Cottage, Graveley are
all ideally placed to offer housing.
The Greater Cambridge Local Plan should help to meet its housing need by having a combination of large
and small sites and this site would be key to achieving this aim and enable sustainable development in
accordance with paragraph 8 of the National Planning Policy Framework 2021.

Representations to Greater Cambridge Local Plan – First Proposals
On behalf of TTP Campus Ltd

Savills (UK) Ltd are instructed by the TTP Group to make the necessary and relevant submissions to the Greater Cambridge Local Plan – First Proposals document which has been published for consultation.
TTP Group (The Technology Partnership) was established over 34 years ago to create a world leading technology and development organisation. This work has evolved into the TTP Group which is formed by a range of businesses focused on the needs of companies planning to flourish through the use of technology and innovation.
As the enterprise has grown, new companies have been created, some of which have remained within the TTP Group whilst others have been sold, demerged and floated on the London Stock Exchange. The Group is quite rightly proud of its heritage and legacy and an integral part of its success is reflected in its long standing close links with the local community in Melbourn where more recently TTP secured a very significant planning permission to relocate its headquarters building to a site directly north of the existing Melbourn Science Park.
The granting of planning permission on the Birchwood Site
In 2018, TTP submitted a planning application for some 10,000 sq.m. of new commercial floorspace on land north of Melbourn Science Park. Consequently, planning permission was granted in March 2019 for “new office and technology research facilities” under planning application reference S/2941/18/FL. The granting of this permission enabled TTP to set out a clear business strategy for expansion which consented 10,974 sq.m. of new floorspace in two phases comprising:
• The main building (known as The Hive”)
• The Technology Barn
• The Service Building
• The Conference Pod
• The Forum Pod
Since the granting of the original permission a number of design changes were made and resulted in the issuing of a new permission (Section 73) granted in June 2020 (planning application reference S/4535/19/VC). A number of non material amendments were made and all relevant conditions were discharged to enable development to begin on site. Works are at advanced stage on site. A copy of the approved site layout granted planning permission together with the red line application boundary is submitted alongside this text.
It is important to acknowledge at the time of the submission of the application back in 2018 and importantly at the time of determination by the local planning authority, the application site lay outside the identified settlement boundary for Melbourn in the Adopted South Cambridgeshire Local Plan 2018. It was the case at the time of the submission of the original application back in 2018 that the proposals were considered as a departure to the Adopted Local Plan having regard to the Council’s policy position and largely due to the site’s location within what was considered to be countryside where restrictive policies would apply .

Whilst acknowledging that the proposed development would have an impact on the landscape and there would be a loss of agricultural land, the Council also recognised the significant case put forward by the applicant demonstrating the importance of new research and office buildings to support the future needs of TTP adjacent to its existing group of companies and workforce - they acknowledged the continuing importance of TTP in the content of the delivery of important technologies at the regional, national and international market and the planned expansion being able to contribute to local amenities.
The adopted Local Plan policies which sought to ensure the promotion of employment clusters, the development of the employment sector within village frameworks as well as a policy which supported new employment development on the edge of villages were all relevant to the consideration of the planning application. However, the Local Planning Authority acknowledged that there was no specific employment policy within the adopted plan which was directly relevant to the development proposal but it was the case that TTP put forward a case of other material planning considerations to take into account when determining the application. This included the assessment of the economic and social role that TTP play both in terms of the village but also their wider role within the employment sector as a hugely successful home-grown company maintaining significant links to the village.
Consequently, when weighing up the material considerations, officers considered that the adverse impacts arising from the development in terms of environmental harm would not be significant and were demonstrably outweighed by the economic and social benefits of the proposal when taken as a whole.
The granting of this planning permission for the site and its implementation and the current construction on site has clearly changed the character of the area. The previously agricultural character of the land has now been transformed into what will now become a new large modern office and research campus encompassing a series of buildings set in a redesigned landscape with the consequent infrastructure requirements of parking and internal road, cycleways and pathways. The consented scheme and this change in character as a result of the planning permission being implemented now means that this needs the new emerging Joint Local Plan to recognise this context. ie, a change to the inset boundary to include that application boundary within the settlement limit for Melbourn. (see enclosed plan)
This is reflective of the Council’s approval for the development and the recognition that the character of the site and its immediate surroundings will change as a result of the built form and the necessary infrastructural and landscaping works which will come forward as part of the proposal.

Policy S/DS – Development Strategy
One of the key roles for a new Local Plan for the Cambridge area is to set out the proposed strategy for the pattern, scale and design quality of places. The overall strategy is one of directing development to where it has the least climate impact, where active and public transport is a natural choice, where green infrastructure can be delivered alongside new development and where jobs, services and facilities can be located near to where people live, whilst ensuring that all necessary utilities can be provided in a sustainable way.
Clearly, there is a significant change in the character between the built area and the rural area around it and therefore it is imperative that wherever new development comes forward that the distinctive character of the City, towns and villages are not adversely affected through new development.
In this context it is important that any development strategy being adopted by the planning authorities exploits and takes up the opportunities to use brownfield land (previously developed land) to ensure ,where appropriate, the protection of other more sensitive locations in the countryside. In the context of Melbourn, submissions have been made to amend the village framework to acknowledge the change in character of the landscape having regard to the granting of the planning permission for the new TTP headquarters north of Melbourn Science Park. Placing the new buildings within the settlement envelope is the logical approach and acknowledges the policy context where potential expansion could occur on that site having regard to its location within the development envelope. Clearly, the normal development management policies would apply of design, materials, privacy and amenity but importantly the principle of development in that location should not be one that is an issue.
Certainly the principle of supporting new employment development within existing settlements is not new to the plan and we are pleased to see under Policy J/NE “New Employment Development Proposals” that the proposed policy direction with the new local plan is one that acknowledges that employment development (classes E9g), B2 and B8) will be supported “within towns and villages, where it is of an appropriate scale and character to the location and scale of development. The policy would cover both new premises and the expansion of existing premises” (page 228 of the consultation document)
The policy direction for new employment development as set out in the consultation document on page 228 reflects the need of the Councils to acknowledge the crucial role that the Cambridge area plays in terms of the local and national economy. It must provide the policy context for positive growth in the economy and has sought to do this by supporting identified employment clusters for the larger employment locations such as Babraham and at Granta Park as well as the new towns at Northstowe and at Waterbeach.
At the more local level the Councils have allocated a mixed use site adjacent to Melbourn Science Park including some 2.5 has for employment use. The wording under proposed policy S/RRA/CR on page 128 of the consultation document states that such an element represents an opportunity to expand Melbourn Science Park . the allocation is supported by TPP on the basis that such an allocation reflects an acknowledge of the role that Melbourn plays as a Minor Rural Centre in the Plan and the very real important links that the Park has to the local community.

S/RRA/SAS – part of Yarmouth Farm) adj, A14 services at Boxworth.

The University notes the proposed allocation for storage and distribution uses. The University can confirm that it has no objection to the proposed allocation, and being owner of part of the site, will work positively with the Local Planning Authority and adjoining landowners/promoters to refine the details of the allocation and bring forward the site, if allocation is taken forward in the Plan.

This policy illustrates further the lack of distribution in housing sites across villages within South Cambridgeshire. The Council don’t want to allocate housing to areas that are reliant on car travel, yet many of the rural centres have been allocated little or almost no development. The evidence base is not representative of sustainable rural centres like Histon and Impington and the Council should give further consideration to the delivery of housing in these locations. The settlements in South Cambridgeshire have tight settlement boundaries and the availability of land within these boundaries for future housing development is limited.

Our proposed development site at ‘Land east of Cambridge Road, Hardwick’ (Site No. 40414) should be allocated within this section of the emerging Local Plan.

The Site is situated directly adjacent to St Neots Road, with a regular bus service (Citi 4) into Cambridge (east) and Cambourne (west). Public transport provision along the corridor will be further enhanced by the Cambourne-to-Cambridge public transport project and future infrastructure improvements associated with East West Rail. Whilst enjoying the same level of public transport provision as Cambourne (and in the future, Bourn Airfield), the Site benefits from being significantly closer to Cambridge, with safe cycle routes making sustainable modes a realistic alternative.

The Greater Cambridge Housing and Economic Land Availability Assessment (HELAA)(September 2021) assesses the circa 700 potential development sites put forward by landowners and developers through the local plan review process. The HELAA provides an assessment of the various sites in terms of their suitability, availability and achievability. With respect to Land east of Cambridge Road, Hardwick (Site No. 40414), the assessment concludes that the Site is suitable (amber rating), available (green rating) and achievable (green rating). We would note that under ‘Suitable’ there are a mix of green and amber-rated items; none of the items are assessed with a red rating. We would reassure the Councils that all of the amber-rated matters can be addressed and necessary mitigated where necessary, through the design of the proposed development. Site No. 40414 is confirmed to be suitable, available and achievable.

A range of assessments have been undertaken to inform the development concept for the Site. The Development Framework (Vision) Document and other technical documents submitted in support of the Site’s allocation are as follows:
• Development Framework (Vision) Document, December 2021 (Terence O’Rourke);
• Landscape and Visual Appraisal (LVA), December 2021 (Terence O’Rourke);
• Green Belt Review, December 2021 (Terence O’Rourke);
• Heritage Assessment, December 2021 (Barton Willmore);
• Archaeology Desk-Based Assessment, October 2019 (Landpro);
• Preliminary Ecological Appraisal, February 2020 (MKA Ecology);
• Phase 1 Geoenvironmental Assessment, September 2019 (Enzygo).
These documents supplement those previously submitted, including Transport and Drainage.

As illustrated in the Development Framework Document, the Site presents the opportunity to create a high-quality and sustainable residential-led extension to the settlement of Hardwick, commensurate to its scale, in a manner that can sustain, grow and underpin local services and needs, through significant improvements to the village and its community.

The vision for the Site is to create a place that enlivens and enriches the existing village and has a strong emphasis on place-quality, the highest sustainability credentials, community infrastructure and a mixed and balanced demographic. The proposed development includes sustainable transport links; a new local centre with retail, employment space and community facilities; new low-carbon homes; significant biodiversity net gain; a new country park and a range of green infrastructure improvements. The masterplan incorporates accessible woodland, additional sports facilities, community gardens and allotments, informal open space/semi-natural greenspace and extensive playable landscapes.

As set out in the Development Framework Document (page 38):
“The site is perfectly located to address many of [the] community needs including the delivery of new community facilities, improvement to Cambridge Road and diversification and expansion of the recreation offer in the village. Importantly, the development reaches a critical mass, sufficient to support and deliver new facilities and open space which will address the current and significant deficiencies in the village. The development will therefore be transformational, turning an existing commuter settlement into a vibrant and cohesive community.”

A Landscape and Visual Appraisal (LVA) of the Site has helped inform a comprehensive Green Belt Review. The findings are summarised at page 26 of the Development Framework Document. In short, it is concluded that the Site des not contribute to the Cambridge Green Belt purpose 1 and provides a relatively limited contribution for purposes 2 and 3. The development strategy will ensure that a new defensible boundary prevents any further growth eastwards and preserves the remaining and substantial gap from further future development.

The general policy of restraint in relation to the rest of the rural area which fails to recognise the growth potential of areas, including Meldreth and Melbourn, where there is good public transport access.
The proposed allocations at Meldreth and Melbourn do not reflect the fact that this is a highly sustainable location and that sites 40088 and 40089 are very close to Meldreth Station. Both of these areas of land are largely unconstrained and have the potential for sustainable growth.

The general approach to development in this area is supported, however, there is clearly potential for sustainable growth in some areas which is not recognised. The potential of Meldreth and Melbourn to provide additional homes and jobs is not currently reflected in the policies relating to the area.

There is a restrictive approach to development within the rural areas irrespective of the level of sustainability of settlements. In respect of the land the subject of these representations, the villages of Meldreth and Melbourn are clearly in sustainable locations and this has been recognised in the assessments undertaken by the councils.

Furthermore, the relevant guidance provided by the NPPF does not necessary limit growth of an appropriate scale in rural areas, but instead seeks to enable these to prosper and for growth to be promoted where it will maintain or enhance the viability of the settlement and/or areas within it as a source of both homes and jobs. The GCLP does not achieve this objective in its current form, and it is maintained that a greater balance needs to be achieved between promoting development in the key target locations, whilst also recognising the growth potential of sustainable locations with good access to public transport links and employment opportunities.

More specifically, it is considered that the Land to the West of Station Road represents a suitable site for the provision of new housing and that its development would deliver new homes in close proximity to a key public transport node in the form of Meldreth Station. The proximity of the site to Melbourn would also mean that the range of services and facilities in the larger settlement are easily accessible by pedestrians and cyclists. The site itself is largely unconstrained, and represents a deliverable site where because of its scale, development could be realised within five years.

Furthermore, the allocation of this site and its redevelopment for predominantly residential use would enable the creation of a more attractive environment at this key gateway to Meldreth. The presence of poor-quality former agricultural buildings in this prominent location fails to capitalise on the locational advantages of this well-located site at the edge of the settlement, where prospective residents would have safe and convenient access to amenities in both Meldreth and Melbourn.

While it is acknowledged that it would not necessarily be appropriate for the entire area currently identified as site: 40088 to be allocated for development, the areas closest to the settlement would represent an appropriate, proportionate and highly-sustainable addition to the existing residential areas of the village. The development of this site would also result in additional public benefits in the form of enhancements to the accessibility of the countryside and improved linkages between the two settlements. The latter would be provided for by the land owner whose wider holding includes key areas of land between the two villages where improvements to pedestrian and cycle links in particular would significantly improve access to the railway station for residents of Melbourn, and connectivity between the settlements more generally.

There are significant public benefits arising from the development of the site to the West of Station Road, which include:

• Provision of housing in a genuinely sustainable location where there would be convenient access to Meldreth Station and where walking and cycling represent the easiest means of travelling to it.
• Improvements to the vehicular access currently serving the employment site which in its current form does not necessarily provide for a safe and effective junction.

• Improvements to the accessibility of the footpath network to the south of Meldreth and access to the countryside.

In addition, it is notable that the development of this particular site would be preferable to the use of land on the north-eastern edge of Melbourn for mixed-use (including housing), when it would be better for this to be allocated specifically for the expansion of Melbourn Science Park. By contrast to the land at the southern edge of Meldreth, the proposed allocation of land to the north-east of Melbourn would not necessarily represent the most suitable or appropriate location for new housing, particularly since this would be over 2km from the railway station. Prospective residents of new housing in this part of the village would be more likely to use private cars for commuting, whereas residential development on the Site that is the subject of these representations would promote the use of public transport, walking and cycling, ultimately resulting in a more sustainable form of development.

As well as being particularly well-located to the key public transport links providing access to rail services and buses linking Meldreth to other settlements, it is notable that this site is also within easy walking distance of schools with Meldreth Primary School only 500 metres to the north. The Secondary School at Melbourn Village College is also within walking distance of the site. The distance of 1.6km (one mile), between the site and the school site means that this is within reach for children of secondary school age using existing road and footpath links. There are also opportunities to improve access between Meldreth and the secondary school which would further reduce the prospect of the need for journeys between the two areas by private cars.

It is notable that there are commitments to improve public transport to the village as noted in Figure 22 of the GCLP and provide new and improved walking and cycle routes. Development of the land subject to this representation would lead to further improvements in sustainability and support new housing and employment in a sustainable location. This connectivity represents a key advantage and opportunity to generate significant environmental and connectivity improvements for the two settlements. This will increase the wellbeing and social inclusion and spread the benefits of growth, helping to create healthy and inclusive communities.

On the basis of the above, the site is largely unconstrained, and should be considered suitable for development. Accordingly, it should be allocated for residential development which would maximise the opportunity that exists to provide for the sustainable expansion of Meldreth.

The land subject to these representations is also readily deliverable with no known technical or physical constraints that would prevent the site from being developed within the first five years of the Plan period. There is firm interest from a residential developer which is a further indication that the potential of this site, while the size of the site means that it could be developed without the need for significant additional infrastructure. The benefits arising from the development would therefore be realised within the first five years of the plan period.

Please see additional written representations in relation to sites 40088 and 40089 for further details.

Bruntwood SciTech are the recent new freehold owners of Melbourn Science Park and as landowners, seek to engage proactively with the plan making process. Established in 2018, Bruntwood SciTech is a 50:50 joint venture between Bruntwood and Legal & General and is the UK’s largest property provider dedicated to driving the growth of the science and technology sector.

With 10 campuses in six locations across Birmingham, Cheshire, Leeds, Liverpool, Manchester, Oxford and Cambridge, Bruntwood SciTech provides significant opportunities for science and tech businesses to connect, collaborate and grow.

With the new Joint Local Plan that is intended to run up to 2041, it is imperative that landowners such as Bruntwood Sci Tech are involved in the process of shaping policies and plans over this period of time.
Savills (UK) Ltd are instructed by Bruntwood SciTech to make the necessary submissions. (Savills have acted for Melbourn Science Park Ltd as previous owners of the site).
We confirm that a strategy of preparing the first Joint Local Plan for the Cambridge area is supported. There is a very strong symbiotic relationship between the built up area of Cambridge and the surrounding 101 villages as well as the market towns lying further afield. Given that many living within the surrounding villages turn to the City for work, retail, leisure and entertainment it is clear that a planning framework that acknowledges this relationship needs to be developed.

Paragraph 2.1
Figure 4 is an illustrative map showing the locations of proposed new housing development 2020 – 2041 and identifies a site at Melbourn for 140 homes. On the basis of the supporting paragraphs, it is logical to assume that the reasons behind the Council identifying new development in Melbourn is consistent with the strategy of directing development to where it has the least climate impact, where active and public transport is the natural choice, or green infrastructure can be delivered alongside new development and where jobs, services and facilities can be located near to where people live.
In the context of the proposed new housing development in Melbourn, it is the case that the village retains a very strong employment base and the history of major companies being attracted to the village continues to evolve - the current expansion of the new TTP group headquarters on the northern side of Melbourn Science Park and the aspirations of the new owners of that Park (Bruntwood SciTech) reflect the strong commitment of firms to invest in Melbourn. It is Bruntwood Sci Tech’s objective to become the leading network of thriving innovation districts acquiring buildings and sites for the long term and currently brings together a collaborative community of over 500 businesses across the UK. Its business strategy is to continue to grow the business through further acquisitions and the steady growth of existing sites and aims to provide 40,000 high value jobs over next 10 years whilst helping to level-up and rebalance the UK economy. As part of this growth, the company provides business support as standard, supporting science and tech companies to form, scale and grow. This includes facilitating access to finance, talent and new markets through connections and an extensive partner network to support the growth of the UK knowledge economy.
The recognition that the Plan gives to Melbourn as a location where growth can occur is important. The relationship between homes and jobs is, of course not a direct one but the provision of major employment opportunity in villages such as Melbourn is intended to reduce travel to work distances and provide the very opportunities that should exist in every settlement for people who wish to live in that village.


Policy S/JH “New Jobs and Homes”
The proposed new Local Plan is intended to follow the objectively assessed needs for development within the plan period 2020 – 2021 to meet the following:
• 58,500 jobs
• 44,400 homes which reflects an annual objectively assessed need of 2,111 homes per year.
The identification of 58,500 jobs reflects the choice of the Councils to provide for the medium growth level from the strategic options that were published in November 2020. The Council contend that this is the most likely figure of new jobs coming forward and whilst they are cognisant of the fact that the research identified the higher growth forecast, it is intended that the plan builds in some flexibility in case the market delivers more jobs than anticipated.

Policy S/DS “Development Strategy”
This policy sets out the proposed strategy for the pattern, scale and design quality of spaces created within Greater Cambridge and sets out where the homes identified in Policy S/GH should be located in order to meet the vision and aims of the Local Plan. In such a context, a development strategy is proposed which reflects the Councils’ intention to largely retain the Cambridge Green Belt whilst directing growth within Cambridge (20%, the edge of Cambridge (24%), new settlements (38%) and finally the rural areas (18%). The broad strategy is one where jobs and homes can be located close to each other and served by good quality public transport, cycling and walking lengths. Whilst the text does not specifically relate to Melbourn which is the home of Melbourn Science Park now owned by Bruntwood SciTech, it does refer to housing and employment in villages that have good public transport access and are close to jobs.

The development strategy needs to continue to tackle significant commuting patterns that have been established over many years between the outlying villages and Cambridge City. The presence of a tightly drawn Green Belt around the edge of the City and then tightly around the necklace villages and beyond means that the opportunities for expansion on the edge of Cambridge and on the surrounding villages is extremely limited. Consequently, this strategy places great reliance on those areas outside of the Cambridge Green Belt to develop and consolidate their employment sector to provide attractive locations for new investment and jobs. Melbourn Science Park provides such a significant opportunity and the new owners will continue to work with the local planning authorities in order to introduce new investment into the Park whilst ensuring that the very qualities and legacy that has been established over many years continues to thrive and prosper.

Policy S/SH “Settlement Hierarchy”
This policy within the Joint Local Plan is intended to group similar settlements into categories that reflect their scale, characteristics and sustainability. The village of Melbourn remains as a Rural Centre within this emerging Local Plan and is supported having regard to the acknowledgement that the Council’s recognise the role that the village can play in accommodating new development and in particular the allocation for a mixed use site on the eastern side of Melbourn Science Park. A Rural Centre places a settlement in a settlement hierarchy which acknowledges its sustainable location and the opportunity that this brings for new investment in terms of new housing as well as supply of new jobs.
In such a context, with Melbourn Science Park having been developed in its current form some 40 years ago, the demands of tenants, new sustainability targets and technology require a review and assessment of new building provision in order to attract new jobs and investment. Bruntwood SciTech as the new owners of Melbourn Science Park recognise the opportunity for the redevelopment of Melbourn Science Park as a previously developed site to bring forward new buildings and open spaces and land uses which are forward thinking and much better reflect the needs and demands of tenants, the businesses in general as well as visitors and the local community. The opportunity to make the best use of previously developed land in this location in a settlement identified as a Rural Centre is logical and reflects a sensible strategy with the opportunities of growth need not all be on greenfield land but rather need to critically analyse existing forms and sites to make best use of a limited resource.
It is the case that the acquisition of Melbourn Science Park is seen as a key strategic component of Bruntwood SciTech ’s science and technology business and will enable them to share knowledge and expertise across these sectors. The intention is to ensure that the site grows as a successful science and technology cluster that is sustainable in the long-term and contributes to the wider Cambridge economy. The company’s experience in these sectors, and with their relationship with funders, aligned to their commitment to expansion ensures that Bruntwood Sci Tech are ideally placed to deliver further growth at Melbourn Science Park.


Policy S/RRA/CR – Land to the West of Cambridge Road, Melbourn
A new mixed use allocation is identified on a 6.5 hectare site immediately to the west of Cambridge Road, Melbourn adjacent to Melbourn Science Park. This allocation has an indicative capacity for approximately 120 homes and some 2.5 hectares for employment uses. As a site that lies adjacent to Melbourn Science Park, there is a clear opportunity to enhance the village’s existing employment sector through more jobs and investment and providing a logical extension to the Park whilst planning for the adjacent residential development in an appropriate manner. Clearly, the layout and the integration with the adjacent Park will be critical and the ability to provide a sensible and logical arrangement for such uses can be achieved and consequently the identification of this allocation is supported by Bruntwood SciTech as the new owners of Melbourn Science Park.

Policy J/NE “New Employment Development Proposals”
This policy is intended to set out criteria which will determine whether proposals for employment development in urban areas, villages and the countryside are acceptable.
Having regard to our clients’ interests within the existing Melbourn Science Park which is already contained within the built up area of Melbourn, it is entirely appropriate that the proposed policy direction within the Greater Cambridge Local Plan is one that simply assesses the appropriate scale and character having regard to its location and the scale of settlement. It is entirely appropriate in this context to acknowledge that the present use of the site as a employment park is accepted and that the nature and scale of its existing character provides the opportunity for redevelopment to develop a much more modern approach to employment parks and to work alongside the authorities and the local community to develop a strong vision that continues the legacy of this part of the village to the village of Melbourn. As the Local Plan quite rightly acknowledges, for developments within town and village settlement boundaries, it is the scale and character that are key to ensuring that the overall character of the settlement is maintained. In such a case the Council expect that larger proposals are likely to be considered favourably in towns and Rural Centres and where Melbourn as identified as the latter within the settlement hierarchy it is entirely appropriate that our client looks positively at the opportunities that exist for redevelopment of the park. Whilst the Local Plan similarly does not list Melbourn Science Park as one of the key employment sites outside the Green Belt as stated in the Local Plan 2018, supporting text to Policy J/NE states that development in locations which provide a range of suitable units, including for start ups, SME’s and incubatory units will be supported.

The proposed allocations at Meldreth and Melbourn do not reflect the fact that this is a highly sustainable location and that sites 40088 and 40089 are very close to Meldreth Station. Both of these areas of land are largely unconstrained and have the potential for sustainable growth.

The general approach to development in this area is supported, however, there is clearly potential for sustainable growth in some areas which is not recognised. The potential of Meldreth and Melbourn to provide additional homes and jobs is not currently reflected in the policies relating to the area.

There is a restrictive approach to development within the rural areas irrespective of the level of sustainability of settlements. In respect of the land the subject of these representations, the villages of Meldreth and Melbourn are clearly in sustainable locations and this has been recognised in the assessments undertaken by the councils.

Furthermore, the relevant guidance provided by the NPPF does not necessary limit growth of an appropriate scale in rural areas, but instead seeks to enable these to prosper and for growth to be promoted where it will maintain or enhance the viability of the settlement and/or areas within it as a source of both homes and jobs. The GCLP does not achieve this objective in its current form, and it is maintained that a greater balance needs to be achieved between promoting development in the key target locations, whilst also recognising the growth potential of sustainable locations with good access to public transport links and employment opportunities.

More specifically, it is considered that the Land to the East of Station Road represents a suitable site for the provision of new housing and that its development would deliver new homes in close proximity to a key public transport node in the form of Meldreth Station. The proximity of the site to Melbourn would also mean that the range of services and facilities in the larger settlement are easily accessible by pedestrians and cyclists. The site itself is largely unconstrained, and represents a deliverable site where, because of its scale, development could be realised within five years.

While it is acknowledged that it would not necessarily be appropriate for the entire area currently identified as site: 40089 to be allocated for development, the area of 3.8 hectares to the east of the A10 and to the west of Melbourn, would represent an appropriate, proportionate and highly-sustainable addition to the existing village. The development of this site would also result in additional public benefits in the form of improved access across the land (potentially involving a new river crossing and the provision of a more direct link between north and east Melbourn and Meldreth Station), and enhancements to the existing pedestrian and cycle links across land owned by the promoter of this site to improve the attractiveness of making journeys across this land to or from the station.

There are significant public benefits arising from the development of the site to the East of Station Road which include, but are not necessarily limited to:

• The provision of housing in a genuinely sustainable location where there would be convenient access to Meldreth Station and a range of facilities and services in Melbourn;
• Improvements to the accessibility of the existing footpath linking Melbourn and Meldreth Station (the existing link may be upgraded in order to improve the condition and lighting of the existing pedestrian and cycle link);
• Provision of access to the western bank of the River Mel which is not currently accessible to the general public;
• Provision of new pedestrian and/or cycle links across the site to enable the creation of direct links between the northern and eastern areas of Melbourn and Meldreth Station (subject to the provision of a new crossing over the River Mel and continued onward access across third party land).

In addition, it is notable that the development of this particular site would be preferable to the use of land on the north-eastern edge of Melbourn for mixed-use (including housing), when it would be better for this to be allocated specifically for the expansion of Melbourn Science Park. The proposed allocation of land to the north-east of Melbourn would not necessarily represent the most suitable or appropriate location for new housing, particularly since this would be over 2km from Meldreth Station. Prospective residents of new housing in this part of the village would therefore be more likely to use private cars for commuting, whereas residential development on the Site that is the subject of these representations would promote the use of public transport, walking and cycling, ultimately resulting in a more sustainable form of development. The close proximity of housing to both the railway station to the west and the amenities within Melbourn to the east would make it more attractive to travel on foot or by bicycle to gain access to these facilities.

As well as being well-located to public transport links, retail outlets and other associated facilities, it is notable that this site is also within easy walking distance of schools with Meldreth Primary School only 500 metres to the north. The Secondary School at Melbourn Village College is also within walking distance of the site. The distance of 1km between the site and the Secondary School (which it may subsequently be possible to reduce significantly if the access improvements outlined above are achieved), would make the school within easy walking distance for children of secondary school age. Should the improvements in access across the site also be realised, this would significantly improve access and reduce the distance and time taken to travel by foot or by bicycle between Meldreth and the secondary school which would further reduce the prospect of the need for journeys between the two areas by private cars.

It is notable that there are commitments to improve public transport to the village as noted in Figure 22 of the GCLP and provide new and improved walking and cycle routes. Development of the land subject to this representation would lead to further improvements in sustainability and support new housing and employment in a sustainable location. This connectivity represents a key advantage and an opportunity to generate significant environmental and connectivity improvements for the two settlements. This will increase the wellbeing and social inclusion and spread the benefits of growth, helping to create healthy and inclusive communities.

On the basis of the above, it can be concluded that the 3.8 hectare site to the East of Station Road (and in particular the area to the east of the A10), is largely unconstrained, and should be considered suitable for development. Accordingly, it should be allocated for residential development which would maximise the opportunity that exists to provide new housing in a sustainable location which would enhance the viability of local services in Meldreth and Melbourn.

The land subject to these representations is also readily deliverable with no known technical or physical constraints that would prevent the site from being developed within the first five years of the Plan period. There is firm interest from a residential developer which is a further indication that the potential of this site, while the size of the site means that it could be developed without the need for significant additional infrastructure. The benefits arising from the development would therefore be realised within the first five years of the plan period.

Please see additional written representations for further details.

Policy S/RRA (P123)

Further allocations in rural areas are strongly encouraged.

Recommendation: The Plan must acknowledge the benefits of allowing a proportion of the plan period growth in rural areas and should proactively promote sites such as Long Lane, Fowlmere as appropriate locations for future development well placed to support local communities.

1. Section 2.6 of the First Proposals document states the Councils “want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services”

2. As set out in detail in our representations on Development Strategy, the approach put forward in the First Proposals document will not deliver the above stated aim. The proposed distribution of new growth and allocations via the GCLP is fundamentally flawed and will not deliver a varied, flexible and robust housing supply or see the benefits arising from sustainable development reaching established and sustainable rural settlements.

3. MGH objects to the use of the terminology, “where car travel is the easiest or only way to get around”. The use of the word “easiest” in this context is inappropriate and does not represent an objective or robust approach to determining the distribution of growth. The easiest or most convenient travel option available to a person will depend on the specific circumstances of that individual. In terms of promoting sustainable travel patterns, the distribution of development should be based on the quality and frequency of public transport connections serving a settlement; and the settlement’s proximity to larger hubs or urban areas.

4. MGH are promoting ‘Land at Ambrose Way, Impington’ (HELAA Ref: 40392) for removal from the Green Belt and subsequent allocation for residential development. MGH welcomes the publication of the HELAA review which appraises the development potential of the site. However, MGH has noted a number of specific technical flaws in the published appraisal which should be remedied as the GCLP preparation continues.

5. To aid the preparation of these representations a Masterplan for the site has been prepared, along with a number of supporting Technical Notes. The Masterplan and the Technical Notes are summarised and provided in the Site Promotion Document appended to these representations.

6. In light of our review of the HELAA appraisal and the Technical Notes we attach as a separate sheet a schedule of the HELAA inaccuracies and recommended amendments.

(SEE ATTACHED SHEET)

7. Updated Call for Sites Forms have also been submitted to explain and evidence the latest technical work completed by MGH.

8. Providing that a rural settlement has strong sustainability credentials in terms of public transport links, employment opportunities, social infrastructure, shops and services it is abundantly possible to bring forward proportionate levels of new sustainable development. It is contended that bringing forward development at Rural Centres such as Histon & Impington is as sustainable as bringing forward growth at New Settlements which have a similar service provision / planned service provision. The service provision at Histon & Impington is set out in the submitted Site Promotion Document.

9. This set of representations has also demonstrated that the proposed GCLP Development Strategy is flawed in its approach to supporting economic/jobs growth, providing a flexible and varied housing supply and supporting the long-term vitality of established sustainable rural settlement. The representations have also confirmed that there is a compelling package of exceptional circumstances which justifies the focused release of land from the Green Belt.

10. In reviewing and amending the GLCP’s overall housing need requirement, development strategy and the need for additional focused Green Belt releases it is strongly recommended that our client’s site is allocated for residential development and the Green Belt boundary modified to facilitate this. The ‘Land at Ambrose Way’ is a suitable and deliverable site with very limited development constraints (which can be overcome through planning conditions and careful design) and is located at a settlement which is a designated Rural Centre and is an inherently sustainable location for new proportionate growth.

See covering letter for further details - To welcome the inclusion of site S/RRA/H Land at Highfields (phase 2) as an allocation in the Plan, which is necessary in order to enable villages such as Caldecote, which have very good existing and/or planned public transport connections, to grow and thrive. Refinement of wording of policy considered necessary and proposed in relation to dwelling numbers and the site's eastern boundary.

Policy S/RRA – Remaining Rural Area

Endurance Estates consider that their land interest on land at A10 Royston Road, Melbourn, Cambridgeshire (Site Reference 40262) should be allocated as part of the rural allocations under Policy S/RRA of the emerging Local Plan for mixed use employment development.

Other representation to this emerging plan have outlined why we consider that Melbourn and Meldreth should be considered as a Rural Centre allocation in the Settlement Hierarchy and therefore considered for unrestricted housing and employment growth through the Local Plan period.

The village is the largest in the South West of the district and enjoys a prime location on the A10 primary route corridor and is served by a full range of public transport options including the guided bus and National Rail Services, as well as being the subject of future projects such as the Melbourn Greenway.

Previous representations have identified the land to the east and west of the A10 as being suitable for a range of employment uses which included roadside services; employment; battery storage and a care village. Subsequent considerations and discussions with local councillors have now amended this potential development mix to include development for employment on both sites; with Roadside services on the western parcel. The amended masterplan which is provided with the representations outlines the new proposed development mix which focuses on employment uses. The previously proposed care village has been removed from our proposals.

Proposed Scheme (See submitted revised masterplan)
• Employment Uses (Class B2/B8/E(g))
• Roadside Uses (Classes E(a); E(b); Sui Generis)

Discussions with both Local and District Councillors in Melbourn identified that if the sites were to come forward for development they would prefer to see employment development on the eastern parcel (rather than a care village) to provide a balance with the proposed and existing housing growth in the villages (including Meldreth) and provide possible business linkages with Melbourn College.

The emerging Local Plan identifies further residential growth in Melbourn at The Moor (S/RRA/ML) for 20 dwellings and 120 units at Cambridge Road, Melbourn (S/RRA/CR) which includes 2.5ha of employment space to allow expansion of the existing Science Park. Both these allocations are welcomed however they do not go far enough in delivering sufficient employment growth to Melbourn.

In assessing the proposed site allocation through the SHLAA to inform the proposed emerging allocation the site was considered to be achievable and available but was not considered to be suitable. Given the overarching development strategy in the plan we can only consider it was considered unsuitable as the overarching strategy has been to focus new development in the larger settlements rather than in the rural villages.

What however stands Melbourn and Meldreth apart from other rural villages is its accessibility to the A10 corridor to serve business uses but also to deliver employment land on a site which is well related to the villages but is relatively unconstrained and not within the Green Belt. This site therefore offers the perfect destination for new businesses looking for a well-located business cluster which is close to Cambridge or those who are currently occupying inappropriate sites in the district (or surrounding districts) who are looking for a place to relocate therefore potentially freeing up sites for other forms of development.

The only element of the site assessment to score a red score was the Landscape and Townscape assessment. It is unclear from the summary how this assessment was undertaken however the conclusion that the site allows a significant adverse impact on the landscape character is questionable given the adjoining railway line; solar park and large scale farm shop operation adjoining the western parcel and the commercial vehicle business adjoining the eastern parcel. We have therefore provided a Landscape Assessment of the site by Pegasus Landscape Team as a full response to this assessment.

Published Assessments

Contrary to the SHLAA assessment the site does not fall within the 4C: Hatley Wooded Claylands. According to the Greater Cambridge Landscape Character Assessment (February 2021) the majority of the site falls within the Landscape Character Type (LCT) 3 Lowland Farmlands and more specifically its Landscape Character Area (LCA) 3C: Rhee Tributaries Lowland Farmlands. The southern parcel falls within the LCT 8 Lowland Chalklands and LCA 8B Morden to Duxford Lowland Chalklands.

The host LCT 3 is described as: “The Lowland Farmlands Landscape Character Type (LCT) is a gently undulating, intensively farmed arable landscape encompassing densely settled, wide, flat river valleys and their tributaries.”

Its key characteristics are identified in the published assessment as:

“Low-lying, gently rolling topography crossed by river corridors and drained by small streams
Open character and often extensive views
Productive, intensively farmed, predominantly arable landscape that has experienced significant modification during the 20th century, resulting in amalgamation of fields
Generally sparse woodland cover and fragmented network of hedge boundaries
Woodland and traditional orchards often define the edge of settlements
Scattered Medieval moated sites and stone churches are characteristic features
A well settled landscape with a relatively dense rural settlement pattern comprising large and small villages and outlying farmsteads”

The host LCA 3C: Rhee Tributaries Lowland Farmlands has the following key characteristics, based on the published assessment:

“Wide valley of the River Rhee and its tributaries
Predominantly medium to large rectilinear fields organised in a haphazard pattern with pockets of regularity
Small woodland blocks combine with shelterbelts and clumps of trees to create well treed horizons
Small scale fields often found at the edge of villages
Ecological richness including lowland meadows, lowland fen and floodplain grazing marsh
Dense settlement pattern comprising large, nucleated villages in the south of the LCA
Distinctive linear features including Ermine Street Roman road, Wimpole Hall Avenue and the railway”

The LCA specific landscape sensitives have been identified as:

“Small scale fields often found at the edge of villages
Distinctive linear features including Ermine Street Roman road, Wimpole Hall Avenue and the railway”

The LCA specific Landscape Guidelines have been identified as:
“Conserve and enhance the regular small-scale pastoral fields, shelter belts and hedgerows at village edges
Maintain distinctive linear features”

With regard the site’s southern parcel, due to its very small scale it is not reviewed in detail. It is considered that being located on the edge of the LCA 3C: Rhee Tributaries Lowland Farmlands it would exhibit similar characteristics as the majority of the site.

Character of the Site and its Suitability for Development

The site is best described as three level and geometric arable fields associated with and characterised by the proximity to the A10 and Cambridge – Hitchin railway line. The elevated railway embankment, along the western boundary, is a strong linear feature in the landscape separating and screening the site from the wider countryside further west. The A10 follows the railway line in close proximity and reflects its alignment, bisecting the two main parcels. This creates an untypical localised variation in landscape character terms, and the site reads somewhat subservient to these two transport corridors. The settlement of Melbourn is located in very close proximity but the intervening vegetation protects its setting.

The level topography associated with the site does not provide any opportunities for distant or elevated views and the vegetated corridor of the A10 and elevated railway embankment curtails views. The intervening vegetation along field boundaries, tree belts along the A10, and built form associated with the Bury Lane garden centre result in inward looking and short range views, which distinctively lack any special visual relationship with the wider countryside or indeed the settlement of Melbourn. Vegetation along Bury Lane and Royston Road adds to the perception of isolation and segregation from the surrounding landscape. The gently rising topography of Grinnel Hill separates the site from the rising landscape further south east. The elevated Hyde Hill and Goffers Knoll do not act as features in the very close range views associated with the site.

Whilst there are a number of PRoWs in the vicinity of the site, the majority of them are located to the south east of Royston Road and follow existing agricultural tracks, all being bridleways open to all traffic. Three of them lead south east towards the elevated Hyde Hill and Goffers Knoll but stop short from reaching the elevated ground. The bridleway that coincides with Bury Lane is strongly vegetated with views curtailed.

The slightly elevated Royston Road is the only location which allows relatively open and slightly elevated views across the site. Views east and south towards the elevated Hyde Hill and Goffers Knoll are not gained, due to the intervening landform of Grinnel Hill. Views east and north east are characterised by the A10, railway line and built form of the Bury Lane garden centre. The medium range and distant landscape is seen as a backdrop of tree groups and isolated tree canopies, i.e wooded and treed level horizon.

In other words, the site is seen in isolation, without any evident relationship to the surrounding landscape. It does not exhibit the more sensitive characteristics of the host LCT 3 such as the “...often extensive views...” or visibility with local landmarks, vernacular architecture or heritage assets identified as being one of the key characteristics of this LCT.

The site comprises simple rectilinear fields under arable cultivation and does not include traditional orchards or small scale field system recognised as vulnerable to development pressures. The masterplan, included in Pegasus’ Site Promotion Document, retains the existing field boundaries and there are opportunities for the existing landscape framework to be supplemented with additional planting. The function and detail of these landscape buffers can be informed by a detailed landscape and visual assessment. This could be sensitively designed to respond to the key characteristics of the host LCT 3 “Woodland and traditional orchards often define the edge of settlements”.

Conclusions

Contrary to the SHLAA assessment the site does not fall within the 4C: Hatley Wooded Claylands. It forms part of the LCT 3 and more specifically its 3C: Rhee Tributaries Lowland Farmlands. Whilst the site and local area include certain characteristics of the host LCT and LCA these are not considered to be a major constraint. The level topography of the River Rhee and its tributaries and “Predominantly medium to large rectilinear fields organised in a haphazard pattern with pockets of regularity” are more likely to be able to absorb development better than small scale fields and traditionally managed orchard sites around the settlements.

LCA specific landscape sensitives include “Small scale fields often found at the edge of villages” but these are not present within or immediately around the site. Similarly, the “Distinctive linear features including Ermine Street Roman road, Wimpole Hall Avenue...” would not be affected by the development of the site in a way that would compromise their function as landmarks or contribution to the local landscape. The strongly linear Cambridge – Hitchin railway line and A10 are modern features.

Whilst the description of the host LCT states that: “The Lowland Farmlands is an intensively farmed LCT. It maintains a tranquil and rural character due to the dispersed hierarchy of settlements from large villages to outlying farmsteads” the rural character of the site is compromised by the proximity and strongly linear form of the railway line and the A10, and adjacent commercial use associated with the Bury Lane garden centre, with the landscape perceived as relatively busy. Its relative sense of tranquillity is reduced, when compared to other parts of the LCT where movement and noise is less frequent or evident.

The SHLAA assessment specifically refers to “...remarkable views across it from both the A10 and Royston Road and allows for a full experience of the NCA87 character type of spacious and strong rural character with rolling hills beyond.” Contrary to this statement, views are generally short range and largely inward looking, and unremarkable being affected by major transport corridors and foreshortened by the railway embankment and vegetation. The railway line, the A10 and Royston Road curtail views.

The Greater Cambridge Landscape Character Assessment was published in early 2021, but it fails to recognise the presence of two solar farms and substation, which lie in a very close proximity to the site and are an established feature of the local area. The south eastern settlement edge of Melbourn is also affected by the presence of various light industrial facilities, which cover a relatively large area, when compared to the overall extent of the village. These factors, collectively, act to refine the characteristics of the landscape around the south western edge of Melbourn whereby the key characteristics of the host LCT and LCA are less evident or augmented by the aforementioned features.

It transpires that the site has the potential to accommodate the development, and with a strong and sympathetically designed landscape proposals, any potential landscape character and visual effects could be successfully mitigated. Therefore, the level of harm would be considerably lower than that alleged in the Council’s SHLAA assessment

All other site-specific assessments were considered to be either green or amber indicating they could be resolved through the planning application process although it is worth considering the following update on the highways position which has progressed since out previous representations.

Highways

The current junction between A10 and Royston Road has been the location of several accidents in recent years which resulted in injuries. This junction remains a poor arrangement for the highway user.

WSP have an in-principle agreement with County Highways to deliver a new four arm roundabout to serve Melbourn and the proposed land parcel to the west of the A10. This arrangement will make the junction safer for vehicles accessing and exiting Royston Road and slow down all traffic on the A10.

This arrangement now also includes a signalised pedestrian crossing to allow safe pedestrian access to the western site and existing PRoW across the A10 when walking/cycling from the village. Cycle links and footpath links to both villages would be upgraded. The crossing would also introduce two new bus stops to allow ease of access from both proposed business sites.

Conclusion

The site is in a strategic location offering good access to the local and regional highway network and lies on major economic corridors including the A10 and the Thameslink rail route.

It is well connected to existing employment centres by road and public transport, as well as local employment areas in Melbourn including the Saxon Way business park and the high tech Melbourn Science Park. The site is close to the existing local services and community within Melbourn itself.

The site can deliver a scheme for employment use with a Roadside services scheme to serve the A10 and associated battery storage to serve on site development.

The design and master planning of the site take’s the opportunity to locate these uses in the most suitable parts of the site, whilst taking into account the constraints and opportunities of the site. The development will secure improvements to the existing junction between the A10 and Royston Road, through the provision of a roundabout, in place of the existing priority junction.

Endurance Estates and the consultant team consider the site represents a compelling opportunity to achieve sustainable development. Endurance Estates looks forward to continuing engagement with South Cambridgeshire District Council to bring this site forward for development

S/RRA/SAS
Support Policy requirement to ensure that strong landscaping is provided to help the site fit into the surrounding rural countryside character.

Notwithstanding our comment above, whilst this is a good location for a regional distribution centre it cannot meet the aspiration that “last mile delivery” in Cambridge can be carried out by sustainable modes of transport (smaller electric vehicles, cargo bikes, etc). This would not be possible from this location.

S/RRA/OHD
Support policy requirement to ensure enhanced landscaping on its open boundaries and avoidance of any impact on the settings of the Grade 1 listed church and conservation area.

• The proposed development strategy involves growth in only a very limited selection of the settlements in Greater Cambridge.
• Papworth Everard will have excellent public transport accessibility following the delivery of several committed transport infrastructure projects. It is therefore a settlement where housing and employment growth should be being allocated in order to:
> Help the village thrive;
> Support the local economy;
> Help meet the emerging local plan’s housing requirement, which should be increased to the higher jobs and homes scenario (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes);
> Provide greater choice in terms of the location, size, type and tenure of housing that the plan can offer; and
> Provide greater flexibility and resilience in the Councils’ housing/development strategy.

It is considered that the growth of the more sustainable villages should be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Foxton falls within this category.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The promoted development at Station Road, Foxton would support the existing services and facilities in the village.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire. It is requested that land st Station Road, Foxton is allocated to meet the requirement for a mix of sites including those that are easily deliverable.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Foxton is a sustainable location in transport terms, and additional development in this location would be consistent with Paragraph 104.

As District and County Councillors we would like to object to the inclusion of the site S/RRA/MF Land at Mansell Farm in Oakington. There is significant opposition from both residents and the Oakington and Parish Council to the inclusion of this site. In summary we do not believe that the justification of the site being in close proximity to the Guided Busway provides the exceptional circumstances which warrant a release of land in the Greenbelt. We will provide further comments as an attached document.

Pigeon has set out in response to earlier points in this submission, the view that the overall quantity of housing allocations should be increased. We have also reasoned that some existing housing needs (for the affordable or elderly persons markets for example) can best be met in the places where those communities’ needs already exist. Pigeon has supported the overall objective of reducing reliance on private motor vehicle commuting.
An important tool in addressing all of these objectives would be to increase the amount of housing allocated in those parts of the RRA where there are significant, thriving communities and where there is the opportunity for residents to travel to and from Cambridge city by active or public transport.
It is noted that the Council has recognised the potential benefits of this approach in places like Melbourn and Oakington. Other settlements should also be considered to see what medium sized sites can be identified to contribute
• increased numbers overall
• early delivery
• meet local needs
• provide active/public transport choices for new residents
• contribute to local infrastructure provision such as the provision of public open space

build on the success, social and economic capital of thriving communities

There are settlements in the rural area that are underperforming relative to the village context and locational advantages.

Croxton is one of those settlements where the existing village is severed, split by the existing A428 which currently separates the employment area from homes and other commercial premises. It is a small village that sits within a key transport corridor. Its character will permanently change when the A428 is realigned, diverting the through traffic onto the new dual carriageway. There is a clear and unique opportunity to utilise the area that will be bound between the old and new A428 to create an expanded and better integrated settlement which could take on the form of a new garden village building on the established core.

The HELAA concluded that development in this location (site 40288) would have significant landscape and visual impacts on the historic landscape to the south and general impacts on views from the north and east. It is not clear whether the HELAA has considered the site in the context of the A428 Improvement Scheme that will fundamentally alter the rural landscape in this location and specifically, permanently change the views form the north and east. There is a clear opportunity to take advantage of this committed infrastructure change in a positive way. The Plan should recognise the possibilities for increasing the C2C corridor to St Neots and maximising the modal shift options that the section of the de-trunked A428 can offer post 2025/26 between Croxton and Cambourne.

The historic parkland landscape to the south would be largely unchanged in visual terms, but the consequential improvements through the change to the existing A428 as a local road would serve to better connect the village and potentially allow its historic characteristics to be better managed. Currently the two parts of the village are severed and inward looking away from the existing A428.

The functionality of the village could be improved through additional development and its sustainability credentials could be significantly enhanced through the inclusion of specific services and local amenities including school provision and expanding the existing employment opportunities currently on offer in the two existing commercial locations.

It is in the unique position of being able to support and complement the wider multi-modal strategies that are being considered for this corridor, capitalising on the opportunities to change the role of the current A428 carriageway once the new dual carriageway has been delivered.

The landscape impacts are not insurmountable; nor is the perceived negative impact on the landscape particularly different to the conclusions drawn in the HELAA for the majority of the 19 site options put forward in the First Proposals.

The HELAA should properly reflect planned infrastructure changes within its site assessments including at Site 40288.

As set out in our comments to the development strategy, the Local Plan as currently drafted will fail to deliver any meaningful growth to rural villages and therefore fail to sustain their local facilities and services which are key to maintaining the sustainability of these areas.

In order to resolve this issue we consider that some growth should be allocated to all settlements or a flexible policy should be adopted to allow a certain level of development on the edge of all villages according to their position in the settlement hierarchy. This could be achieved either through policy criteria allowing a certain level of growth adjacent to rural settlements, or by drawing settlement boundaries more loosely so that they include small sites promoted for development on the outskirts of villages. In this way, it would be possible allow suitable sites adjoining existing built-up areas to come forward under Policy S/SB.

In light of the clear need to identify suitable and deliverable sites that can come forward to meet rural housing needs, we are pleased to promote our client’s site at Land off Whitecroft Road, Meldreth.

The site has now been submitted using the required site submission form (ref. RMCNVRWF) and I am pleased to enclose the following documentation for your information and review:

- Location Plan prepared by KJ Architects
- Layout Plan prepared by KJ Architects
- Transport Technical Note prepared by KMC Transport Planning

Site Description

The site comprises a strip of disused land totaling approximately 0.7ha (with a further 0.15ha forming the access road) that is located to the rear of existing properties at 19, 19a, 19b, 19c, 21 and 21a Whitecroft Road. These existing properties are arranged with numbers 19 and 21 fronting Whitecroft Road and the remaining properties located off two parallel private access drives that run between numbers 19 and 21. One drive serves numbers 21 and 21a and the other serves numbers 19, 19a, 19b and 19c.

The site is located on the western edge of Meldreth within walking distance of the railway station, primary school, shop and other key facilities. To the north of the site is Cam Valley Orchards and Farm Shop, to the north-east are the existing dwellings described above and a recent residential development at Melrose, to the south is an area of scrub/woodland and to the south-west is agricultural land.

The site is in Flood Zone 1 (i.e. Low Risk), it is not subject to any statutory environmental or heritage designations and it is located outside of the Green Belt. There is an existing public footpath at the far end of the site that runs between Chiswick Road and the railway line.

The Proposed Development

The proposal is for a distinctive development of 5 individual family homes with an emphasis on design and quality. As a local company who are currently developing land adjoining the site, Artisan has a unique understanding of the site, the sustainability of the local area and the local need for high quality family homes. Our client is bringing forward their proposed development to help meet this need and is also committed to ensuring environmental enhancements through the provision of an ecological enhancement area on site and the design of environmentally sustainable homes, including electric vehicle charging points and dedicated home office spaces. It is on this basis that we are promoting the site for allocation in the emerging Local Plan. The dwellings could also be delivered as custom build properties should there be an identified need in the local area.

The indicative proposal shown on the enclosed layout plan comprises:

- Housing: a sensitively designed residential development comprising 5 dwellings with a single dwelling located at the end of the proposed access road to terminate the existing vista and 4 dwellings located in a courtyard arrangement behind. The proposed dwellings would be designed to a high quality, reflecting local vernacular architecture and delivering environmentally sustainable homes.

- Access: would be achieved to Whitecroft Road by combining the two existing private drives to form a single 6m wide shared access road. The proposed access design is shown on the plans produced by KMC Transport Planning would provide clear highways benefits through the tidying up of the existing private drives and the provision of footways along White Croft Road to connect into the existing.

- Ecological Enhancement Area: a c.1,300m² area would be delivered to the rear of the suite to provide native grassland and woodland habitat. There is also the potential to deliver an informal connection from this point to the existing public footpath that adjoins the site. This would provide an additional public benefit in creating a new walking route.

The site is located outside of the currently defined development framework for Meldreth, but it is well contained such that its development would not encroach on the wider countryside beyond the immediate setting of the village. Nor would it extend the built form of the village any further west than the existing dwellings along Chiswick End and it would be seen in the context of the existing residential development at Melrose and recently approved development located to the north of the site.

The site is also well enclosed in views from the surrounding countryside with a mature tree belt and woodland to the south. The Council’s adopted Design Guide SPD identifies Meldreth as within the Chalklands character area where there is a mostly well-treed character to villages, which are often not visible in the wider landscape, despite adjoining open arable fields. The proposed development would help enhance this characteristic through the provision of an ecological enhancement area with significant tree planting to the south-west of the site.

Meldreth is identified as a Group Village in the emerging Local Plan, but should be considered to be significantly more sustainable as a location for growth compared to other group villages on account of its train station and proximity to Melbourn which provides easy access to additional services and employment opportunities (see enclosed Transport Technical Note). The site is in walking distance of the station and all key facilities in Meldreth and Melbourne, such that it is a highly sustainable location for development.

Emerging Policy S/SH defines Meldreth as a Group Village where, within the settlement boundary, schemes of 8 dwellings will be permitted. As set out in our comments on this policy, this approach will fail to deliver any meaningful growth to support existing facilities and services in Meldreth as the current settlement boundary (or development framework) is drawn so tightly that there is little to no room for natural expansion. This is demonstrated by the fact that recent developments (including 9 dwellings approved to the north of the site and our client’s adjoining development for 2 dwellings) have been approved outside the settlement boundary. In this context it is necessary to either allocate sites for development or to allow for flexible growth on the edge of the village. Our client’s site represents a highly sustainable and unconstrained location and we consider that it should be allocated for the proposed level of growth or at the very least included within the settlement boundary so as to allow development to come forward under Policy S/SB.

As mentioned above insufficient housing development has been proposed within the rural villages (Minor Rural Centres and the Group Villages): those villages (such as Bassingbourn, Over and Girton) require growth in order to make them sustainable and such growth can provide quantitative improvements through the delivery of benefits such as affordable housing, new open space and biodiversity gains.

Re S/RRA/MF. This site should not be developed:
(1) There is a Bronze Age barrow on this site (please see attached photo.) We believe this feature has been recorded by English Heritage. This is in addition to untouched ridge and furrow features.
(2) The land is currently unimproved meadow, which is both a nationally endangered habitat (97% lost since the 30s) and an effective carbon sink, which would emit considerable carbon if disturbed. Developing this site is counter to policy CC/CS.

Section 2.6: Rest of Rural Area / Policy S/RRA: Allocations in the Rest of the Rural Area

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The the promoted development by Hawkswren in Orwell would support the existing services and facilities in the village, including the school, convenience store, post office, public house, mobile library, community centre, and existing and future bus services.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire. It is requested that small/medium sized sites, including that promoted by Hawkswren at land off Leaden Hill, Orwell is allocated for residential purposes.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable. The good range of services and facilities within Orwell are all accessible by walking and cycling. Orwell is on existing bus routes, with regular services to Cambridge and a limited service to Royston. The Greater Cambridge Partnership’s Making Connections project proposes a more frequent rural bus service for Orwell and as a result some additional growth should be provided to Orwell.

Paragraph 62 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 12 affordable dwellings in Orwell for those with a local connection to the village. This identified need would not be met without allocations in the village. The promoted development by Hawkswren in Orwell would include housing and affordable housing to meet local needs of the village.

For all these reasons, small and medium scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Orwell, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages which would not be met via other means.

Hawkswren promoted the land off Leaden Hill, Orwell as a potential allocation in emerging GCLP that was assessed in the HELAA under Site Ref. 47890. The representations to the assessments in the HELAA comment on the potential constraints identified with the promoted developments and explain how those constraints would be addressed. As set out in the call for site submissions and the supporting technical work for the site, there are no significant constraints at the site promoted by Hawkswren at Leaden Hill in Orwell. For example, the site is outside the Green Belt. The site is not at risk to flooding and there are no designated heritage assets nearby. The trees and hedgerows on the site would be retained. An acceptable access can be provided to serve the development and importantly the proposals would not prejudice highway safety at this location. The promoted development would also include biodiversity enhancement measures.

For all these reasons it is requested that the site promoted by Hawkswren in Orwell is allocated allocated for residential development in emerging GCLP:

• land off Leaden Hill – for approximately 8 self/custom build and 5 affordable units to meet need/ demand locally

The call for sites submissions were accompanied by Supporting Documents (prepared by Twenty-Nine Architecture Ltd) which included an Indicative Masterplan Concept Plan for the promoted developments. An updated Site Plan for 13 units accompanies the submission.

Requested Change

It is requested that the development strategy for the rest of the rural area includes an additional allocation in Orwell.

It is requested that land off Leaden Hill, Orwell is allocated with the following policy requirements:

• Site Area of 0.8 Ha
• Capacity for 8 self/custom build dwellings and 5 affordable dwellings
• Delivery of open space and landscaping
• Main access from Leaden Hill
• Improvements to carriageway on Leaden Hill
• Development should address the following constraints:
o Retain and enhance existing trees and hedgerows at site
o Upgrade existing access road.

Please see attached representation