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

Allocations in the rest of the rural area: Allocates sites for homes or employment in or adjoining villages and we agree with this approach. Land at St Peters Road (site ref: 40543) is not included in the site allocations and provides an opportunity to create a well-located extension to Caxton with efficiently designed homes. This site is connected to the core of the village by public footpath 44/6, which provides a direct pedestrian link to Ermine Street, connecting to the immediate vicinity of two bus stops and public house/restaurant, a distance of around 100m. Therefore, development of this site would not be an isolated development in the countryside but would be well connected.

For councils to fulfil their obligations in line with the Self-Build and Custom Housebuilding Act 2015, they need to recognise that smaller sites in rural areas can significantly contribute to meeting the demand for self-build and custom housebuilding, whilst also contributing to the sustainability and vitality of rural villages. The current approach to delivering serviced plots is to allocate sites within larger housing developments and this is not proving to be a successful strategy; the demand for serviced plots is not being met. The proposed policy makes no reference to meeting the self-build and custom housebuilding demand and therefore the demand will not be met under this policy. Smaller sites offering serviced plots are more likely to be delivered and built out within a shorter time frame when compared to sites within larger new build housing developments. By allocating smaller rural sites for self-build and custom-build development, sensitively designed dwellings can be built which will not only meet the demand but also enhance the setting of the village. Allocating smaller rural sites for this type of housing will also provide economic benefits through the construction jobs created and from owner/occupiers using local services and facilities. The Land at St Peters Street (site ref: 40543) provides excellent opportunities for self-build and custom build houses which would see the council meeting the demand for this type of housing as well as meet the needs for local housing, whilst fulfilling their obligations.

As set out in paragraph 69 of the National Planning Policy Framework 2021 (NPPF) medium sites such as Land at St Peters Road, Caxton will make an important contribution to meeting the housing requirement of the area and can be built out quickly. There is significant demand for housing within Caxton given its proximity to Cambourne and Cambridge.

The NPPF 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. With development already approved and being built out for Camborne West, approximately ¾ of a mile north of the site, with improved sustainable transport connections, Land at St Peters Road, Caxton (site ref: 40543) will also be a sustainable location as well as providing an opportunity to deliver self-build housing contributing to the unmet existing demand.

The Land at St Peters Road (site ref: 40543) is ideally placed in relation to Caxton and given its proximity to Cambourne lends itself to be a highly sustainable location for future growth in Cambridgeshire along with the proposed new railway station at Cambourne as part of the Cambridge to Oxford Arc and this site is suitable, deliverable and developable. 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.

LVA believe the Local Plan should not be restrictive in terms of providing new housing in villages and instead encourage the Council to utilise this process to permit proportionate, blended growth of open market led developments to provide a wide range of living opportunities in rural areas and settlements through the form of allocations. Associated policies should be worded to allow for Infill Villages to grow and allocations should be made within the Local Plan to compliment this. Paragraph 78 of the NPPF requires that “…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…”.

The allocation of additional developable sites in suitable locations especially in the rural areas will ensure the required levels of growth are delivered in the plan period whilst providing flexibility and certainty in the event that the large-scale extensions do not come forward as expected.

If the Local Plan is to be drafted to restrict development in Infill Villages such as Caxton for example, it could inevitability impede suitable, developable and deliverable sites in sustainable villages such as Land off Ermine Street, Caxton from being developed. The Local Plan must have a mechanism in place to deliver growth in villages where there is no ability or appetite to do so through community led planning (for example Neighbourhood Plans where there is no requirement for their production).

As such, LVA believe Land off Ermine Street, Caxton, located on the northern edge of the settlement of Caxton to the east of Ermine Street extending to 1.5ha, should be allocated for development through the Local Plan process. LVA consider the site represents a logical opportunity for development in the rural areas.

For background, LVA is an investor and planning project manager in UK land and property, with a concentration of projects around the south of the UK. We focus on forming responsible alliances with all stakeholders, including Local Planning Authorities to create developments which add value to communities. We believe our approach of creating working ‘alliances’ leads to better development. LVA are acting on behalf of the Caxton LVA LLP who own Land off Ermine Street, Caxton.

In terms of the suitability for development, Land off Ermine Street. Caxton has been subject to an outline planning application submitted in May 2018 for up to 30 dwellings. The application was refused on 14 August 2018 (Ref: S/1849/18/OL), however it is important to note that there is no demonstration from the refusal of permission and consultee responses provided of an adverse impact which would arise from the grant of planning permission. There are no technical constraints that would prohibit the site from being developed.

The village of Caxton lacks recent development and opportunities would be very limited due to the tight settlement boundary. Due to the concentration of development focusing on Ermine Street; the majority of businesses and services in the village are within close proximity to the street. This village area comprises of:
• A restaurant and bar;
• The village hall;
• Two children’s equipped play areas;
• Informal open space;
• Allotments;
• A church;

Caxton Gibbet, is approximately 1 mile north of Caxton’s northern boundary; and is situated off the A1198 and A428. This includes a Costcutter convenience store, petrol station, car wash and ATM, McDonalds, Subway and Costa. There is also a pet store (Cambridgeshire Hunt) and soft play centre (Giggles and Wiggles) for young children located 1.1miles south of Caxton, outside the settlement boundary. Caxton provides a frequency of busses daily to Cambridge and to St. Neots (with the common exception of Sundays). This is above and beyond the frequency of services in larger settlements.

It is also important to consider the interrelationships between villages and their surrounding settlements. The sustainability of each village is also influenced by the surrounding settlements and their connectivity. Caxton benefits from its close location to Cambourne which is easily accessible by all modes of transport within a short distance. Cambourne is the largest town within the South Cambridgeshire district, comprising the villages of Lower, Great and Upper Cambourne, with an approximate population of 12,000 people and 4,250 homes. Services and facilities currently present within Cambourne include:

• Local centre with supermarket, shops and a number of eateries;
• Community facilities (including sports centre, multiple pavilions, Multi Use
• Games Area and youth club);
• Public houses;
• A nursery and pre-school;
• Four primary schools;
• One secondary school;
• A business park;
• Increased number of bus services;
• Cycle-ways within Cambourne;
• Services (including fire station, police station, GP, dentist, pharmacy, vet
• and library)
• Public open space (including a variety of recreational spaces); and
• Landscaping and recreational uses present within the area.

Cambourne is confirmed to see continued growth more specifically on its western side in the direction towards Caxton. Once developed, the site off Ermine Street, Caxton will be approximately 0.4km from the first phase of the West Cambourne development which will provide:
• 2,350 new houses (including affordable housing);
• Two Primary Schools;
• One Secondary School;
• Retail uses;
• Indoor community facilities;
• Two sports pavilions;
• Office/ light industry;
• Open space; and
• Improved accessibility (including linkages to existing PROWs leading directly to Caxton and LVA’s site itself).

Further, Cambourne is also due to be served by a new rail station which will be situated on the central section of the proposed East West Rail Oxford–Cambridge line.

In conclusion, LVA consider that the village of Caxton is an appropriate and sustainable location for new housing over the plan period, and that the Local Plan should not restrict growth in such a location. The allocation of a site/s in Caxton would be appropriate. Land off Ermine Street, Caxton can be considered a suitable, developable and deliverable site (this has been demonstrated through planning application Ref: S/1849/18/OL) that in LVA’s view should be allocated for housing development within the Local Plan. LVA strongly endorses a plan-led approach to development and would welcome the opportunity to work with the Councils and the Local Plan process to achieve high quality development on the site. Land off Ermine Street, Caxton is suitable, available, and immediately developable.

See cover letter for details - The Councils’ own evidence suggests that housing in the rural area can help support delivery of a range of smaller sites within the area and support the vitality of the villages. Some growth in centres such as Comberton should therefore be included in the Plan to help sustain the village and form part of a robust strategy. The land east of Bush Close Comberton has safe access, the overall harm of Green Belt release should be categorised as Low harm, and it would support the vitality of the village. It should therefore be allocated.

Re: Rest of the Rural Area (Section 2.6).

The site (HELAA ref. 40283) to the south of High Street, Hauxton is a sustainable site in a sustainable location and is suitable, available and achievable.

Impington:
I question the proposed scale of any new developments on the edge of Cambridge due to changes in commuting habits precipitated by the covid pandemic. The proportion of people who will permanently work from home, full-time, or at least part-time has increased hugely, thereby reducing the need for additional homes close to the city centre; I think the numbers should be reconsidered.
I do object to proposals for larger scale developments to the West side of Impington (NIAB land).
This land is greenbelt land and should be protected as such.
This is a large-scale development, very out of scale and different in character from Impington.
It would cause a huge increase in traffic through a quiet, residential area which has historical significance, once being Chivers orchards has a special character with an abundance of old fruit trees.
Increased pressure on a GP practice already struggling with too great patient numbers.
Increased pressure on the water drainage system, on land already prone to flooding and down-stream from the large development of Darwin Green which is likely to cause greatly increased pressure as it is.

I do not object to development of site S/RRA/H/1, as long as it is a small development, to provide additional housing whilst maintaining the character of Impington and keeping it as a separate entity from Cambridge city and Milton.
I do not object to the development of the small area of land North of Primrose lane.

The following allocations should be added:
1) Land North Of 26 - 46 Elbourn Way Bassingbourn (which is currently the subject of planning application 21/00543/OUT) should be allocated for 33 dwellings as part of this policy. The planning application has demonstrated that there are to technical grounds on which the development could not take place and the development would be capable of delivering appropriate mitigation through landscaping design. The development would also provide biodiversity and open space benefits to the village.
Please refer to the planning application documents submitted for application 21/00543/OUT and the relevant consultation responses thereto.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.
2) Land west of Oakington Road, Girton (c. 2.83 hectares) should be allocated for the development of c.40 dwellings together with associated public open space. The documents attached demonstrate that the development would be acceptable in planning terms and the land is available immediately for development.
Supporting documents are enclosed which relate to flood risk and Green Belt/visual impacts from the development of the site. A masterplan is also included. This information was submitted with the Call for Sites evidence.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.
3) Land at and to the rear of 30 and 32 New Road, Over (which is currently the subject of a pending appeal - Council ref: 20/03254/OUT is suitable for an allocation of 44 new homes plus public open space. The planning application has demonstrated that there are to technical grounds on which the development could not take place and the development would be capable of delivering appropriate mitigation through landscaping design. The development would also provide biodiversity and open space benefits to the village.
The land is under a Promotion Agreement with Abbey Properties Cambridgeshire Limited who, as set out within this submission, have undertaken initial work to confirm that the site is suitable for development.

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

We do not object to any of the specific allocations proposed within the First Proposals.

However what we do object to is:
● In general, allocations that would impact the Green Belt in any way
● A set of specific site proposals that have been rejected by SCDC, but would cause untold harm if they were ever to be incorporated as part of this or any future local plan.
In relation to the second point above, the specific site proposals we refer to are those with site references / JDI numbers as follows:

● 40041 – Kings Gate site, Villa Road, Impington
● 40232 – Land west of South Road, Impington
● 40236 – Land north-east of Villa Road, Impington
● 40239 – Kingsgate Land off Villa Road, Impington

Each of these site proposals would cause significant damage to the local community and environment and none offer anything that cannot be far better achieved at other site locations (as the First Proposals appear to correctly recognise). Main concerns common to these sites include:
● All lie wholly (or at least 98% or more) on Green Belt land
● All would result in material damage to the Landscape and Townscape, resulting in a Red flag for this criterion in the HELAA report in all 4 cases. As noted by the HELAA report, this area of Green Belt land is “typical” of the “Fen Edge” character, and there is no getting away from the fact that a development of any of these sites would cause this to be lost.
● All would result in a huge relative increase in traffic volumes on currently quiet residential roads (potentially through the South Road play area (destroying green open space) or Villa Road – both areas where small children play). The HELAA report recognises this through assigning Red or Amber flags for Site Access in all 4 cases.
● All would add further pressure on water and drainage in an area already prone to flooding (as the HELAA report notes, with Red or Amber flags)
● All would contribute to increased traffic load on the A14 North bypass (a strategic highway that is already over capacity No matter what arguments land-owners put forward, it is clear that large new developments of the type proposed in these areas cannot possibly lead to a net zero increase on traffic on the Strategic Highways, therefore these sites would appear to be worthy of automatic disqualification (all other issues, of which there are a lot, put aside)
● All would place more pressure on existing facilities such as the local GP and schools
● Two of the four site proposals are for 450 and 700 new houses (40232 and 40239 respectively). These large scale developments would be totally out of keeping with the rest of the village.

This policy allocates sites for homes or employment in or adjoining villages and we agree with this approach. Land at 92 Old North Road, Longstowe (site ref: 40422) is not included in the site allocations and would be a suitable site for self-build and /or custom build housing. Allocating serviced plots on a smaller rural site are more likely to be delivered and built out. For councils to fulfil their obligations in line with the Self-Build and Custom Housebuilding Act 2015, they need to recognise that smaller sites in rural areas can significantly contribute to meeting the demand for self-build and custom housebuilding, whilst also contributing to the sustainability and vitality of rural villages. The current approach to delivering serviced plots is to allocate sites within larger housing developments and this is not proving to be a successful strategy; the demand for serviced plots is not being met. The proposed policy makes no reference to meeting the self-build and custom housebuilding demand and therefore the demand will not be met under this policy. By allocating smaller sites within rural areas, this type of housing will not only be delivered but provide economic benefits through the construction jobs created and from owner/occupiers using local services and facilities.

Policy S/RRA sets out the proposed policy for new site allocations in the rest of the rural area. The First Proposals document states that policy S/RRA will allocate sites for homes or employment that support the overall development strategy within the rural area. There are a total of just four new housing sites proposed to be allocated to the rest of the rural area, excluding the rural southern cluster, demonstrating the restrictions of the proposed development strategy to development in the rural area.

Fowlmere is located only 3.2 miles from Melbourn, which is recognised as a well-functioning place for residents and employment. Paragraph 8.68 of Greater Cambridge Employment Land and Economic Development Evidence Study (2020) states:

“…the villages are able to play an ongoing role in ensuring viable and available industrial floorspace to meet the needs of the city and the wider Greater Cambridge area. Industrial demand for those locations with good connectivity and / or proximity to Cambridge is anticipated to remain moderately strong in the medium term.”

As set out within the accompanying Vision Document, Land West of London Road is located within 20 minutes of a range of local services and facilities to support daily needs. Fowlmere village centre is located less than a five minute walk away, with the facilities, education and employment opportunities of Foxton, Melbourn and Cambridge all easily reachable by bike or public transport. As demonstrated in the accompanying Vision Document, the proposed development would also provide electric vehicle charging points with each dwelling, promoting the use of electric vehicles.

Land West Side of London Road, Fowlmere - Introduction
Wates Developments Ltd. are promoting Land West of London Road, Fowlmere. This Site was submitted to the Greater Cambridge Shared Planning Service (GCSP) as a component of their Housing and Economic Land Availability Assessment in February 2020.

The GCSP assessed the site against a range of criteria and allocated an overall amber rating in terms of suitability and a green rating in terms of availability and achievability.

We disagree with this amber rating and we have reassessed the Site on receipt of site specific technical evidence, which reassessed the site as having an overall green rating.

Wates are promoting two parcels of land which combine to form the full site, with the Manor Farm access providing the division. The full site is being promoted for approximately 145 dwellings.

Site Description
The land that is being promoted, is approximately 10.33ha in size and is bound to the north by the Manor Farm Business Park, to the east and south by the B1368 and to the west by agricultural land. The site is of a Greenfield nature.

As noted, the site has been identified through the Greater Cambridge Housing and Economic Land Availability Assessment as a potential site for development and allocated the reference 40116.

The site’s location within Fowlmere provides a location with access to key amenities such as a Primary School and Bus Services, whilst nearby towns and villages such as Shepreth, Melbourn and Royston provide a full range of required jobs, services, leisure and cultural facilities.

The site is proposed to include considerable provision of public open space to enhance the quality of the site for new and existing Fowlmere residents. This is considered to be a key benefit to the future scheme and also meets the Councils’ aspirations to delivery high quality open space to new and existing residents of Greater Cambridge.

Landscape and Design
A Preliminary Landscape Review of the Site has been undertaken by SLR Consulting Ltd.
The Review confirms that the topography of the site is broadly flat, ranging in elevation between approximately 20m and 25m AOD. The Site is surrounded by areas of built development, including derelict land and disused buildings and Butts residential area and employment site to the south, residential development properties along London Road to the east and London Road to the south along with further residential properties and caravan park. The western boundary of the site is defined by a tree belt which creates a defined physical barrier between the Site and the open agricultural land further to the west. The Site represents a logical location for accommodating development.

The adopted Local Plan identifies land at the eastern edge of the Site, along London Road, as “Important Countryside Frontage”. As demonstrated in the accompanying Vision Document, Land West of London Road and the proposed development responds positively to the Important Countryside Frontage designated along London Road. The development of the Site provides an opportunity to create a gateway into the settlement, providing a transition between the wider settlement and the village. The delivery of a village park will reinstate the countryside frontage, framing the edge of the settlement and aligns with the principle of the designation. The mature tree boundary along the Site’s eastern edge also provides a clear segregation between the settlement and the wider countryside.

The preliminary landscape review concluded that the landscape of the site is of low value to the north of the Manor Farm access. Furthermore, the visual appraisal concluded that the site is visually enclosed but that there is the potential for sensitive views from residents and walkers to the east and south.

The concept masterplan as shown in the accompanying Vision Document has been landscape-led. As recommended by the Landscape Review, the masterplan proposes large swathes of the Site to provide publically accessible open space in the form of a village park and provide a gateway to Fowlmere.

Highways/Access
The Site and proposed development is also supported by an Initial Transport Appraisal, undertaken by i-Transport LLP.

The Site has a long frontage onto London Road (that becomes High Street at its northern end), which is subject to a 30mph speed limit. The Appraisal demonstrates that access to both the northern and southern parcels is readily achievable in highway design terms from High Street and London Road respectively.

With regards to traffic impacts, a development of 145 dwellings is likely to generate approximately 70 two-way vehicle movements in the network peak hours. This will likely be split between travel southbound on London Road towards Royston and northbound via Cambridge Road to Cambridge. This level of traffic generation should not have a noticeable impact and should be well below a level that could reasonably be considered severe.
The proposed development is therefore considered to be acceptable in highways terms.

Flooding and Drainage
The Site sits entirety within Flood Zone 1, demonstrating that it has a less than 0.1% chance of flooding in any year. The flood risk from surface water on the site is predominantly very low.

The Concept Masterplan proposes areas of sustainable drainage systems, which will be multifunctional, providing both biodiversity and amenity benefits as supported by the Draft Local Plan and supporting evidence base.

Ecology
There is a considerable buffer of over 1km between the Site and Fowlmere Watercress Beds SSSI, whilst the village of Fowlmere separates the Site and the Hummocky Fields SSSI to the west.

The presence of Priority Grassland, Wetland and Woodland Habitats are recorded in the wider area surrounding Fowlmere, however no Priority Habitats are located on or in close proximity to the Site.

It is not anticipated that residential development would have a detrimental impact on any designated site or those within regional or local protection.

Heritage
Whilst it is acknowledged that there are a number of heritage assets within Fowlmere, some of which are in proximity to the Site, being in proximity to the setting of a heritage asset does not necessarily cause harm to it.
The Site and proposed development is supported by a Heritage Briefing Note, prepared by Orion Heritage Ltd.
The Note acknowledges the proximity of the Site to the aforementioned Conservation Area, however states that, through the potential loss of the rural frontage to the London Road, is likely to be impacted.

The United Reformed Church, located opposite the Site, is also acknowledged, although as set out in the accompanying Heritage Note, its significance as a landmark building is reduced by the fabric concerned being a later addition, with significance from setting deriving principally from neighbouring buildings rather than its rural interface.

Orion Heritage conclude that in respect of all heritage assets, the development of the Site would result in a less than substantial range as a worst case scenario, which could be further mitigated through sensitive design and layout.

Arboriculture
The Site and proposed development is supported by an Arboricultural Technical Note, produced by SJA Trees.
The Technical Note acknowledges that there are some existing Tree Protection Orders (TPO) on the Site. These TPOs are shown to date back to 1975 and focus on Elm and Horse Chestnut trees. It should be noted that these orders were enacted prior to death of many Elm trees from Dutch Elm Disease, therefore no Elm trees remain on the Site. The remaining Horse Chestnut trees are suffering from lead miner infestations and are of reduced quality and value.

The non-protected mature trees on the site are Ash and Sycamores, although these trees are considered individually unremarkable and of moderate quality at best.

The Technical Note concludes that few protected trees remain and “those that do are generally of limited value or quality”. Development of this site is considered acceptable in arboricultural terms.

Mitigating the effects of Climate Change
Land West of London Road, Fowlmere will positively contribute to carbon offsetting in a number of ways. As demonstrated through the accompanying Vision Document, the proposed development will deliver an attractive open space in the form of a village park, which will provide existing and future residents of Fowlmere with a destination for amenity and leisure. The residential elements of the scheme will deliver low carbon housing and benefit from electric charging points, promoting the use of electric vehicles. In accordance with the aspirations of the Greater Cambridge emerging Local Plan, low water consumption will also be promoted to reduce water usage and positively contribute to water recycling where possible.

Evolving Masterplan
Following the design suggestions offered through the technical assessments, a preliminary masterplan has been produced. This masterplan seeks to maintain and enhance the existing green frontage alongside the London Road and proposes generous swathes of the southern parcel as accessible public open space.

As the design criteria suggests, the majority of the northern parcel will see provisions for residential development, whilst felicitous residential development is proposed on the southern parcel. A range of popular community features are outlined such as allotments, orchard planting, a children’s play area and a village park. These features will complement the aforementioned generous allocation of public open space.

The masterplan proposes two options for development of the Site, both of which are underlined by the principles of a healthy and sustainable community and promote the concept of a 20-minute neighbourhood.

Summary
This site is considered to be suitable, deliverable and achievable, and there are no known significant constraints that should prevent the development of the site.

With appropriate master-planning and design, the site is capable of delivering a sensitively designed but comprehensive and well-connected sustainable development that could contribute to the local development needs of the emerging Greater Cambridge Shared Planning area.

Housing Employment Land Availability Assessment (HELAA) 2021

The Site (which collectively includes both the northern and southern parcels) has been assessed through the Housing and Economic Land Availability Assessment (HELAA) process (identified as 40116). The northern parcel was also assessed individually within the HELAA, under the reference Site 40252.

The assessments differed in their ratings attached to Landscape & Townscape and Transport & Roads. Regarding the former, the two parcels in unison were afforded an Amber rating, whilst the single parcel was granted a Green rating. With regards to Landscape & Townscape, the collective site was allocated an Amber rating whilst the northern parcel assessed solely was given a Red rating. This Red rating resulted in the overall suitability for development of the individual parcel to also be deemed Red.

We raise concerns with regards to both of these assessments and ratings, which we consider to be inaccurate.
Despite the Site’s positive assessment, it is noted that the Site has not been subject to any further independent assessment as it was “not considered to represent a reasonable option as it would not provide a sustainable location to allocate development”, this is because, according to the Councils, Fowlmere as a whole is not considered suitable for accommodating development. As a result of adopting such an approach that applies a blanket inflexible principle, the Council are at risk of not identifying appropriate sites for development.
This argument originates back to Greater Cambridge assessing Fowlmere as not being located either on an existing or proposed public transport route or in close enough proximity to allow active transport to Cambridge or a market town outside the district to warrant a further assessment.

We disagree with this conclusion and strongly recommend the Councils to reassess Fowlmere in terms of its sustainable location and proximity to good public transport links, therefore re-categorising Fowlmere as a Group Village that benefits from good public transport links, warranting those sites that were assessed positively to be reassessed independently through the Sustainability Appraisal.

The previous spatial options considered and consulted upon included a ‘Dispersal: Villages’ option which sought to spread new homes and jobs out to the villages surrounding Cambridge. The Sustainability Appraisal indicated that the Dispersal:Villages spatial option performed relatively well against the various SA Objectives, including the same as the Preferred Option for a number of objectives (SA objectives 1, 3, 9, 10 and 14).

In addition, the Development Strategy Topic Paper indicates that the Dispersal: Villages spatial option was broadly supported by the public via the response to the First Conversation consultation, where it was the fourth most popular location. As set out in the Development Strategy Topic Paper, further consultation undertaken by the Councils also noted the opportunities associated with growth to existing villages include:
• The benefits of development for sustaining villages and schools and enhancing amenities including shops, healthcare provision and community facilities; and
• The need to provide affordable homes suitable for elderly and younger residents to continue living in villages.

The development of land at Boxworth End, Swavesey that is being promoted by Axis could deliver on both of these opportunities. The development would deliver c. 70 high quality market and affordable dwellings, including a mix of smaller and larger homes to suit a range of occupiers, from first time buyers and young families to older residents and those looking to downsize. Development in the location proposed, on the edge of Swavesey village, would also provide an additional population that would help to sustain existing local services and facilities and that would be sustainably located to promote the use of sustainable and active travel methods to access these amenities. Unlike all the other land being promoted in Swavesey, this site comprises a contained agricultural field that is already bound by existing development on three sides meaning that any further development forms a natural and small extension to the village boundary, and would not strictly result in further encroachment into open countryside. The majority of the site comprises open grazing land which is generally of limited ecological value. Features of ecological value, such as the existing pond and woodland will be retained and enhanced. In terms of the preferred growth strategy set out in the First Proposals Plan, the Councilshave proceeded with a blended strategy, considered to “meet a variety of needs and respond
to the opportunities provided by the sources of land supply”. The Councils propose to focus
a small number of new sites and allocations principally:
• within the Cambridge urban area;
• edge of Cambridge, outside of Green Belt;
• edge of Cambridge, Green Belt;
• new settlements;
• some development in the defined ‘Rural Southern Cluster’ (between the M11 and
the A1307); and
• limited development in the ‘Rest of the Rural Area’.

The land being promoted by Axis, comprising land east of Boxworth End, Swavesey, falls within the ‘Rest of Rural Area’ as defined by the Council. This follows the Dispersal: Villages option previously considered.
Our client’s site is not currently allocated for development in the consultation document.

However, the defined wider ‘Rest of Rural Area’, under Policy S/RRA, does comprise the allocation of a small number of new sites for housing and employment at villages that have good public transport access. This includes two new employment allocations proposed within close proximity of Swavesey village including land at Buckingway Business Park (Site BBP) and land to the south of A14 Services (Site SAS), both allocated to provide new
industrial and warehousing use. This provides direct employment opportunity for Swavesey
village, within easy commuting distance on foot, by bike or by bus.
Under Policy S/RRA there are only four sites allocated to provide new housing:
• Moor Lane, Melbourn – capacity for 20 homes.
• Land at Highfields – capacity for 64 homes, based on lapsed planning permission
so some uncertainty with regards to deliverability.
• Mansel Farm – capacity for 20 homes. The site is located in the green belt but in close
proximity to Cambridgeshire Guided Busway stop which provides the exceptional
circumstances for the sites release.
• Land west of Cambridge Road, Melbourn – capacity to provide 2.5ha employment land, albeit the deliverability of the employment site is yet to be confirmed, as well as capacity for 120 homes within a minor rural centre.
In total, these allocations provide for only 224 dwellings during the plan period. This equates to 2% of the additional housing need (11,640 dwellings) identified in the Plan.

We support that the ‘Dispersal: Villages’ option and the allocation of sustainable sites within or on the edge of villages and adjoining the settlement boundaries of villages within the rest of the rural area should form part of the overall development strategy. As above, we consider that the Plan needs to provide greater flexibility and resilience in its housing allocations, to ensure the Councils can meet the identified housing need at all stages of the plan period. It is therefore appropriate to allocate further small-medium size sites in sustainable locations to ensure consistent delivery across the plan period by not concentrating all development in a specific area or an over reliance on large strategic sites.
The allocation of land east of Boxworth Road comprises an appropriate and sustainable approach, noting the ability of the site to connect to existing public transport and active travel routes, make use of existing services and employment opportunities in and around Swavesey minor rural centre and provide a mix of housing for the local market. This approach is supported under Paragraph 79 of the NPPF, which requires planning policies to identify opportunities for villages to grow and thrive, especially where this will support local services.

Paragraph 69 of the NPPF acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that these can often be built-out relatively quickly.

We also note the recommendations of the report prepared by Lichfields, on behalf of the Land Promoters and Developers Federation and the Home Builders Federation – ‘Feeding GCLP First Proposals Plan – Promotion of Land at Boxworth End, Swavesey

the Pipeline: Assessing how many permissions are needed for housebuilders to increase the supply of homes’ (November 2021). The report seeks to explore how the delivery target for new homes (300,000 net additional homes per annum across England) could be achieved at a national level, including the important role that implementable planning permissions on medium to large sites of 50-250+ homes can play in order to meet the targets overall. The report concludes:
“To meet ambitions for 300,000 net additional homes per annum, the country will need to increase delivery by 59,200 homes per annum. This in turn illustratively necessitates between 474 to 1,385 additional implementable planning permissions on medium to large sites (50-250+ homes) making their way into the housebuilding sector”.
“This represents each district in England granting planning permission for the following,
over and above what they usually would:
a) 4-5 additional and new medium size sites each year or 4-5 additional and new large size sites which will deliver over the next five or more years; or
b) One or two additional and new medium size sites each year or one or two additional and new large size sites which will deliver over the next five or more years plus 12 or 13 new smaller sites each year”.

It is therefore considered that small and medium sized sites can make a significant contribution towards the housing need in Greater Cambridge during the plan period, and can help to fill the ‘gaps’ in the housing trajectory where housing provision falls short of the identified need and 10% buffer.

4.0 Policy S/RRA – Land adjoining 107 Boxworth End,
Swavesey
DETAILED COMMENTS ON HELAA ASSESSMENT IN ATTACHED DOCUMENT

VJF supports the principle of policy S/RRA in allocating sites for homes and employment in the
rural area. The Local Plan should seek to allocate a component of its housing needs towards
growth at existing villages. Sustainable development in rural areas makes an important
contribution to ensuring the vitality of villages and supporting existing rural services and facilities.
This approach is supported by the National Planning Policy Framework (NPPF), which at
paragraph 79 states 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.

Notwithstanding this clear direction in national policy, the emerging Local Plan makes very few
additional allocations in the rural area and VJF objects to this approach. This approach threatens
the vitality of villages within the rural area and stifles opportunities for further growth and
supporting local services. The allocation of additional small to medium sized sites in the rural
area will also help to ensure that the housing supply for the Local Plan is balanced and robust,
reducing the reliance on strategic sites and the limited allocations in villages. As such, the
Development Strategy should include for further allocations in the rural area to ensure that a
sound spatial strategy is developed and delivered.

To fully support the rural area and develop a sound spatial strategy with a mixture of deliverable
and suitable rural allocations, Land at Papworth should be identified as an allocation for
residential development. The site represents a sustainable location for development which will
help to meet the housing needs of Greater Cambridge in the next Local Plan period. The land is
available, achievable and suitable and the development proposals will bring a number of tangible
social, economic and environmental benefits to support the delivery of a sound and sustainable
spatial strategy as part of the Local Plan, including:
● The opportunity to deliver a substantial amount of affordable housing to help meet the needs
of Papworth and the wider District, including the potential to possibly deliver an element of
custom and self-build;
● Locating residential development in a sustainable location, within close proximity to existing
and proposed services, facilities, infrastructure and employment opportunities.
● A landowner who wishes to work with the local community in order to shape a proposal which
meets the needs of and can provide wider benefits to the village;
● Delivery of a substantial amount of open space which would be accessible to new and
existing residents and would provide connectivity with the allocated recreation ground
extension;
● Supporting Papworth’s economy, including local shops and services;
● Enhancing biodiversity levels across the site. The site is predominantly agricultural land and
can currently be considered to be of low ecological value. The proposals present an
opportunity to deliver a biodiversity net gain of at least 20%; and
● An informed position through the submitted Village Assessment to help shape how best the
development can bring the widest and far reaching benefits to the village and local
community

We strongly support the statement in the Development Strategy Topic paper that “Our (the Councils’) evidence suggests that housing in the rest of the rural area outside the southern cluster can help support delivery of a range of smaller sites within the area, and support the vitality of our villages”. Having reached this conclusion, to provide opportunities for villages to grow and thrive as required by the NPPF (Paragraph 79) and as stated in representations on the Vision and development, additional sites in sustainable village locations need to be included as part of a rounded strategy. The approach to identifying new rural allocations (Key criteria and Relative factors) is supported. This does make it critical that the ratings in the Housing and Employment Land Availability Assessment (HELAA) are robust. The recognition that some villages in the Green Belt have the best access, which may constitute exceptional circumstances to release sites from the Green Belt reflects the policy in the NPPF (paragraph 142) that when “..reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account”, and is also welcomed. This does then need to be translated into the allocation of additional sites at villages.

St John’s College has put forward a number of sites which we continue to contend would deliver on these opportunities, but one site in particular sits squarely within the stated policy direction. Cockerton Road, Girton (40555) has an amber assessment and importantly is well located in terms of the opportunities to cycle and use the bus to work and to services, as well as being less than 1 hectare in size and thereby contributing towards the national planning policy requirement for at least 10% of the housing requirement to be accommodated on sites no larger than 1 hectare. The Citi 6 bus service links Girton to Cambridge with the nearest stop being on High Street at the end of Cockerton Road – a 2 minute walk from the site. The Citi 6 provides twice hourly buses taking 20 minutes to the centre of Cambridge (Emmanuel Street) and thereby linking on to other services. The Citi 5 bus service links Girton Corner to Cambridge and also provides twice hourly buses to the centre of Cambridge (Emmanuel Street). The site/Girton also provides safe, convenient cycle links into Cambridge for work, leisure and services, with the city centre (Bridge Street) being a 17 minute cycle journey from the site. The “negligible impacts to the settlement character” of development as categorised in the SHLAA, the contribution it would make towards the national planning policy requirement for at least 10% of the housing requirement to be accommodated on sites no larger than 1 hectare, the contribution it would make to supporting the vitality of the village and the accessibility credentials of the site constitute the exceptional circumstances required to release the site from the Green Belt and allocate it for residential development.

Great Shelford has one site identified for growth.

The supporting maps that form part of the evidence base are incorrect. Figure 43 indicates that the Mingle Lane site in great Shelford is an existing commitment to be carried forward in the GCLP. The site has not been allocated in any previous development plan and is proposed by the authority as a new site to be released from the Green Belt.

GSTA is concerned that the Council has incorrectly logged this site as an historic allocation to be brought forward. This should be rectified immediately. The consultation and evidence base that justifies identifying this site for allocation in the GCLP is misleading.

As a result, there is no express policy text to comment upon for a proposed new allocation at Mingle Lane, Great Shelford. The scale and policy criteria are not stated. Further consultation is required to enable any comments to be lodged against any specific policy proposal for Mingle Land, Great Shelford.

Setting these errors aside, clear evidence is required to show why this site should be identified for release from the Green Belt ahead of other sites at the village edge. The 2021 Green Belt review that has been undertaken for Great Shelford related growth does not support the overall conclusions that Mingle Lane is the most sustainable choice.

In the August 2021 Green Belt Study, release of the Mingle Lane site for development is concluded to cause Moderate/High harm to the GB. This mirrors the previous 2015 Inner Green belt study results. Mingle Lane has consistently been considered perform a strong GB function.

This is in stark contrast to the GSTA site at Cambridge Road (HELAA Site 40413) which has consistently been considered to a neutral/low performing GB role in the 2015 Inner GB study and in the August 2021 update. The latest study continues to support the principle that the release of Cambridge Road site for development would cause the least harm to the Cambridge Green Belt.

HELAA response: Site 40413
A key difference between land off Cambridge Road (ref 40413) and the proposed allocation at Mingle Lane (ref 45545) in the site assessment and selection criteria is the fact that the Cambridge Road Site Access criteria scored ‘red’.

“Site Access- ‘Red’ If over 100 dwellings two points of access are required to accord with the advice of the Cambridgeshire Fire and Rescue. If over 100 dwellings two points of access are required to accord with the advice of the Cambridgeshire Fire and Rescue.”

The HELAA concluded that development off Cambridge Road would have access concerns arising from the uncertainty for achieving a fire access/secondary access for the site. At the Call for Sites stage, copy emails were submitted to the Council to state that the fire officer had no concerns in this regard. This information has not been represented fully in the HELAA.

In many respects the two sites scored similarly. However, in relation to landscape and townscape and historic environment, the Cambridge Road Site scored better. Critically, the proposed Mingle Lane allocation has negative impacts on the conservation area and cemetery.

In relation to accessibility to services and facilities, Mingle Lane site was closer to the Primary School, closer to the village centre and closer to Rapid Public Transport. Whilst this is not disputed, the category only looks inwards to Great Shelford village and does not give any weight to what services are offered across the city border in relation to overall accessibility and connectivity.

The change for the Cambridge Road site to a maximum 100 units to overcome emergency vehicle access concerns will also positively respond to the other HELAA concern that a higher level of development would create a high-density development, unsympathetic to the settlement pattern. The previous density and form conveyed in the previously submitted indicative schemes has been reviewed and we agree that a scheme for up to 100 units would better reflect the site context whilst still constituting an efficient use of land.

HELAA updates: Site 40413
The proposed change to ‘up to 100 units’ for Cambridge Road negates any access concerns going forward and the RAG should be updated to ‘GREEN’. This change will also serve to allay any potential concerns the authority may have on density considerations at the same time. Similarly, this section should now have a RAG rating of GREEN.

We also note that in the HELAA, under the section Green Belt Study, Cambridge Road site states “Parcel ID: TR5; GS25
Very High; Low
This is also incorrect and Very High should be deleted. Site GS25 clearly scored Low in the study.

Having made these updates, the site would clearly score better than Mingle Lane in all aspects other than a narrow accessibility point – being proximity to village services. Whilst this is factually correct, the site submissions to date demonstrate clearly that the Cambridge Road site is locationally more sustainable overall, having regard to the wider context within which the village is located. This includes access to key employment sites and main centre uses. To ignore the immediate surrounding area has artificially skewed the assessment.

Proximity to jobs and main centre uses is a strong positive for Cambridge Road to provide a more sustainable strategy.

There is no clear site selection process contained within the evidence base to justify a Mingle Lane Site allocation rather than another site at Great Shelford and specifically Cambridge Road.

Key Worker Housing:
This is the First Proposals draft and is capable of change. A key consideration for Cambridge Road, is the option to consider specific housing tenure for the site including key worker housing. This type of development was put forward in the Call for Sites 2019 but no further assessment of sites to meet this demand is included within the plan.

Site 40413 is the most connected to the Addenbrookes hub and can offer a wider range of housing tenures.

The First Proposals does not openly address other housing requirements through the draft sites or policies, relying heavily on the lager strategic sites to provide a housing mix to cover key worker and specialist housing. The trajectory assumptions and delivery rates does not positively support the early delivery of key worker housing. As the bulk of the strategic growth is proposed to be located in the ‘towns’ being the former new settlements of Northstowe, Waterbeach and Cambourne, this is not locationally favourable to key workers, for example healthworkers operating shift patterns in the city.

Changes required:
The HELAA should be updated for Site 40413 to change the scale of development to “up to 100 units” as a maximum scale of residential development. The access and density considerations should be updated to reflect this change and shown as Green (which overcomes the negative issues raised).
The Green Belt section should delete ‘Very High; Low’ and just state ‘Low’.

With these changes implemented, the site selection for Great Shelford must be revisited to re-evaluate the alternatives on a fair basis. We consider this would demonstrate that the land at Cambridge Road is the most sustainable option for extending Gt Shelford. It categorically should produce a different outcome, acknowledging that the benefits of developing Mingle Lane should no longer outweigh the GB or heritage impacts when assessed against the alternative options on offer.

In summary, the updated evidence base and necessary re-assessment can only reasonably be considered to support land at Cambridge Road as the most sustainable option for locating additional growth at Great Shelford.

Please see supplementary comments lodged to the Green Belt Study under section GP/GB.

It is requested that the development strategy for the rest of the rural area includes an additional employment at land off Butt Lane in Milton, as promoted by EDBF, with the following policy requirements:

• Site Area of 13.80 Ha (Approx. 3.3 Ha for new Police Station and approx. 10.5 Ha for promoted Class E, Class B2 and Class B8 uses).
• Proposed Employment Uses: including Commercial/Office Use (Class E), Class B2 (General Industrial) or Class B8 (Storage or Distribution), and ancillary uses.
• Retain and enhance existing trees and hedgerows at site boundaries
• Vehicular access from Butt Lane
• Pedestrian and cycle connection to Milton Park & Ride
• Pedestrian and cycle connections to future public transport projects e.g. Waterbeach to Cambridge Project or walking and cycling routes to/from North East Cambridge

It is anticipated that the allocation would be suitable for employment uses displaced from North East Cambridge, and that is expressed in the specified mix of uses.

OBJECT

The Proposed Submission version of the North East Cambridge AAP is currently being reported through various committees of Cambridge City Council and South Cambridgeshire District Council, in advance of public consultation in early 2022.

It is noted that a number of amendments have been made to the AAP, including a 25% reduction in the amount of new commercial (office) floorspace to be provided across the North East Cambridge area and an associated reduction in the number of jobs to be provided from 20,000 to 15,000 jobs. It is intended that there would be no net loss in the quantum of existing industrial (Class B2 and B8) floorspace as a result of the regeneration of the North East Cambridge area. Although it is acknowledged in the AAP that some existing businesses within North East Cambridge would need to relocate as part of the redevelopment.

The Councils intend to support those existing businesses that will be displaced from North East Cambridge, including help to find alternative sites. However, finding alternative sites is likely to be difficult, partly because of the number of businesses that are likely to be displaced either permanently or for a temporary period, and partly because some business will want to remain close to the edge of Cambridge to be close to customers and employees.

The successful delivery of the redevelopment of North East Cambridge is a key part of the development strategy for the emerging GCLP, including in terms of meeting housing needs. However, the redevelopment of North East Cambridge is reliant in part on the timely relocation of existing business from land to be redeveloped by other uses. It is considered that the relocation process would be made easier if additional land was specifically identified in the emerging GCLP for relocated businesses from North East Cambridge, whether temporary or permanent.

It is requested that the remaining land off Butt Lane in Milton owned by EDBF, and adjacent to the new Police Station for Cambridgeshire Constabulary and Milton Park & Ride, be allocated in the emerging GCLP as a suitable relocation site for some businesses that will be displaced from North East Cambridge area as well as for general employment purposes. This outcome would represent the exceptional circumstances to justify the release of land from the Green Belt.

It is considered that, taking into account the neighbouring uses and the current Green Belt status of the site, the land off Butt Lane could be suitable for commercial offices, high quality industrial, or other compatible uses. There may also be an opportunity to deliver an EV charging station in conjunction with the existing and proposed uses e.g. Park & Ride, Police Station, office, and industrial uses.

EDBF’s representations to the assessment of the land off Butt Lane in Milton in the HELAA (Site Ref. 40365) request that the assessment takes into account the approved new Police Station on part of the site (App Ref. S/20/04010/FUL). EDBF’s representations also comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed.

Requested Change

It is requested that the development strategy for the rest of the rural area includes an additional employment at land off Butt Lane in Milton, as promoted by EDBF, with the following policy requirements:

• Site Area of 13.80 Ha (Approx. 3.3 Ha for new Police Station and approx. 10.5 Ha for promoted Class E, Class B2 and Class B8 uses).
• Proposed Employment Uses: including Commercial/Office Use (Class E), Class B2 (General Industrial) or Class B8 (Storage or Distribution), and ancillary uses.
• Retain and enhance existing trees and hedgerows at site boundaries
• Vehicular access from Butt Lane
• Pedestrian and cycle connection to Milton Park & Ride
• Pedestrian and cycle connections to future public transport projects e.g. Waterbeach to Cambridge Project or walking and cycling routes to/from North East Cambridge

It is anticipated that the allocation would be suitable for employment uses displaced from North East Cambridge, and that is expressed in the specified mix of uses.

Policy S/RRA sets out the proposed policy for new site allocations in the rest of the rural area. The First Proposals document states that policy S/RRA will allocate sites for homes or employment that support the overall development strategy within the rural area. There are a total of just four new housing sites proposed to be allocated to the rest of the rural area, excluding the rural southern cluster, demonstrating the restrictions of the proposed development strategy to development in the rural area.
It is noted that two of these sites are located in Melbourn as follows:
• S/RRA/ML – The Moor, Moor Lane, Melbourn – 1 hectare, approximately 20 dwellings
• S/RRA/CR – Land to the west of Cambridge Road, Melbourn – 6.5 hectares, approximately 120 dwellings and 2.5 hectares of employment land.
It is therefore recognised that Melbourn is a suitable location for additional rural development. Land to the East side of Cambridge Road, Melbourn is located within walking distance of Melbourn Science Park, which provides employment opportunities within key knowledge-intensive industries.
The Site benefits from access to existing pedestrian linkages into the settlement and future improved cycle links. It is considered that development within this location will encourage future occupiers to adopt sustainable modes of transport, including walking, thereby contributing to supporting healthy lifestyles.
Land to the south of the Site is being promoted by Miller Homes under HELAA Site reference 47903, which offers an opportunity for Land to the East Side of Cambridge Road and Site 47903 to form an integrated and comprehensive sustainable extension to the north of Melbourn.
With appropriate masterplanning and design, the site is capable of delivering a sensitively designed scheme that could contribute to the local development needs of Greater Cambridge.
It is clear from the Development Strategy Topic Paper (2021) that no independent assessment of the Sites in the rural areas has been undertaken and Land East of Cambridge Road was not subject to a Site Visit (Page 166). This is not a robust approach. A site cannot be adequately assessed relying on desk-based information without a site visit. If Council Officers were to have undertaken a physical site visit it is considered that the suitability of the Site for a sustainable residential development would have been recognised, including its relationship with the settlement, rather than dismissing it in the absence of a proper assessment.
It is therefore urged that the approach to assessing the sites in the rural areas is reconsidered and that proper site assessments are undertaken to include a physical site visit. This would demonstrate that the Site is sustainably located within close proximity to the services and facilities within Melbourn and provides a suitable location to accommodate an appropriate level of future growth. The Councils have acknowledged that development to the north side of Melbourn is suitable through the proposed allocation of ‘Land to the West of Cambridge Road, Melbourn’ for 120 dwellings. It is therefore considered an oversight that Land to the East Side of Cambridge Road, Melbourn, which is located in close proximity to this proposed allocation, has not also been assessed. Proper assessment of the Site would demonstrate its suitability for inclusion within the Development Strategy.

Land to the East Side of Cambridge Road, Melbourn
Introduction
Wates Developments Ltd. are actively promoting Land to the East Side of Cambridge Road, Melbourn.
This Site was submitted to the Greater Cambridge Shared Planning Service (GCSP) as a component of their Housing and Economic Land Availability Assessment in February 2020.
As set out in the preceding Section, Greater Cambridge assessed the Site as having an overall red rating in respect of site access, and landscape and townscape and therefore concluded that the Site was not suitable for accommodating development.
As mentioned, we fundamentally object to this red rating and we have undertaken an independent assessment adopting the Councils’ methodology, however have based the assessment on site specific technical surveys. Site assessments should be given greater weight than desktop assessments as they provide site-specific details whereby desktop analysis is likely to be generalised.
We strongly recommend that Greater Cambridge revisit this Site assessment to ensure it is based on sound technical evidence and therefore can be relied upon to determine the suitability of sites to be included for allocation within the emerging Local Plan.
Site Description
The greenfield Site lies on the edge of Melbourn, to the east of Cambridge Road and is approximately 18.43ha in size and is boarded to the north by the Cambridge Road, to the west and south by agricultural land and to the east by Kingsway Golf Centre and RSPB Fowlmere.
Land East side of Cambridge Road, Melbourn lies along this A10 cycle route and is within walking distance of local amenities including jobs, services and facilities within Melbourn’s village centre.
Melbourn also lies in proximity to Meldreth train station, which provides frequent services between the settlement and Cambridge City.
Land East side of Cambridge Road also lies within close proximity to Melbourn Science Park, which includes 9 business units providing employment for a number of companies engaged in pharmaceuticals, biochemistry and mechanical engineering. It is also noted that the Science Park was granted consent for an extension in 2018 for a new office and technology research facilities (S/2941/18/FL) and the relevant conditions are currently being discharged. This highlights the site’s accessibility to employment opportunities in key knowledge-intensive industries, and its ability to contribute to South Cambridgeshire’s important role in retaining itself as a world leader in research and knowledge based industry.
The Councils’ recognise that Melbourn is a sustainable location for growth given that it is one of the few rural settlements proposed to have rural growth attributed to it. The proposed allocation for 120 dwellings to the west of Cambridge Road (Policy S/RRA/CR) is in close proximity to the Site. Opposite this proposed allocation and immediately to the south of the Site extending to the existing settlement edge is land that is being promoted by Miller Homes ‘Land South of Cambridge Road, Melbourn’ (HELAA Site reference 47903). The Site therefore also needs to be considered in the context of future development in the village and the opportunity for an integrated and comprehensive sustainable extension to the north of Melbourn should be recognised.
Flooding/Drainage
The site lies entirely within Flood Zone 1 and a future scheme is proposed to include Sustainable Drainage Systems.
These sustainable drainage systems will be multifunctional, providing both biodiversity and amenity benefits as supported by the Draft Local Plan and supporting evidence base.
Highways/Access
The Site benefits from a circa. 250m frontage onto Cambridge Road, which benefits from a flat alignment with wide verges between the site and carriageway offering good visibility splays, and can provide appropriate access points adjoining the Cambridge Road. This could include a main point of access with multiple options for the location of an additional emergency access, or alternatively two simple priority junctions.
The site also benefits from pedestrian linkages to facilities and services within Melbourn. In addition, the site lies in proximity to Meldreth train station, which provides connectivity to Cambridge City to the north.
The traffic impact of the proposed development will be subject to a detailed Transport Assessment, which will determine whether or not improvements to the signals in Melbourn are needed.
The site’s position on the edge of Melbourn provides a sustainable location for new development with local public transport connections and pedestrian and cycle links, as well as proximity to nearby local amenities including jobs, services and facilities within the village centre. The Site also lies along the Melbourn Greenway, which will enhance linkages between Melbourn and Cambridge, providing a green active travel into and out of the city for walkers, cyclists and horse riders.
Ecology and Biodiversity
The site does not contain any Priority Grassland, Wetland or Woodland Habitats although the existence of these habitats is acknowledged in close/medium proximity to the site.
It is acknowledged that the rear of the site is neighboured to the west by the Fowlmere Watercress Beds SSSI.
The proposed development will provide extensive areas of open space, which will be multifunctional, delivering amenity benefits together with biodiversity net gains. As shown on the Melbourn Framework Plan, a significant proportion of the Site will be retained as green infrastructure.
The proposed development will include large areas of retained open space and landscaping, creating a landscaped buffer between Melbourn and the wider countryside. A variety of green infrastructure will be provided such as new hedgerow and tree planting, green corridors, a central neighbourhood green, naturalistic ecological parkland and natural play space.
As noted, above, the Masterplan framework provides open space through naturalistic ecological parkland, natural play space, green corridors, proposed footpaths, the existing public right of way and the SuDS. There is also an opportunity for the adjoining parcel of land to the south-east to be utilised to provide a further allocation of open space. This could create an additional amenity for new and existing Melbourn residents such as a village park. It is anticipated that the quantum of additional land for open space could be established and secured through the evolution of the masterplan.
It is considered that any impacts on surrounding regional or locally designated sites would be suitably mitigated through adopting a sensitive design and layout.
Landscape
The site falls within Landscape Character Area 3C Rhee Tributaries Lowland Farmlands. This landscape is classed has having only moderate strength with few distinguishing features, therefore it is unlikely that development would have a significant adverse impact to the wide and local landscape character.
It is noted that the Councils have incorrectly identified the Site’s Landscape Character Area.
Any impacts to the Landscape Character Area would be appropriately mitigated through sensitive design and layout.
Summary
The Site offers an opportunity to accommodate comprehensive development to meet the affordable and market housing demand within Melbourn and is capable of delivering a sensitively designed but comprehensive and well-connected sustainable development that could contribute to the local development needs of Greater Cambridge.
The Site is able to accommodate suitable points of access and any perceived landscape impact could be satisfactorily mitigated through sensitive design. The proposed development will encourage future occupiers to adopt sustainable modes of transport, and the residential elements of the scheme will deliver low carbon housing and benefit from electric charging points, promoting the use of electric vehicles. Low water consumption will also be promoted to reduce water usage and positively contribute to water recycling where possible, in accordance with Greater Cambridge’s aspirations.

The Councils’ were incorrect in their assessment that the Site is not suitable for accommodating development and the inclusion of the Site as a residential allocation within the Greater Cambridge Local Plan should be reconsidered.

Housing Employment Land Availability Assessment (HELAA) 2021
The Site has been assessed through the Housing and Economic Land Availability Assessment (HELAA) process (identified as 47757).

The Councils’ assessment, however considered that the Site was not acceptable for accommodating development and, as a result was not subject to any further independent assessment. On the basis that this conclusion was made on incorrect evidence, we strongly recommend that Land to the East Side of Cambridge Road is reassessed accordingly.

Peterhouse supports the principle of policy S/RRA in allocating sites for homes and employment
in the rural area. The Local Plan should seek to allocate a component of its housing needs
towards growth at existing villages. Sustainable development in rural areas makes an important
contribution to ensuring the vitality of villages and supporting existing rural services and facilities.
This approach is supported by the National Planning Policy Framework (NPPF), which at
paragraph 79 states 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.

Notwithstanding this clear direction in national policy, the emerging Local Plan makes very few
additional allocations in the rural area and Peterhouse objects to this approach. This approach
threatens the vitality of villages within the rural area and stifles opportunities for further growth
and supporting local services. The allocation of additional small to medium sized sites in the rural
area will also help to ensure that the housing supply for the Local Plan is balanced and robust,
reducing the reliance on strategic sites and the limited allocations in villages. As such, the
Development Strategy should include for further allocations in the rural area to ensure that a
sound spatial strategy is developed and delivered.

To fully support the rural area and develop a sound spatial strategy with a mixture of deliverable
and suitable rural allocations, Land to the south of Hattons Road, Longstanton should be
identified as an allocation for residential development. The site is considered to represent a
sustainable location for development which will help to meet the housing needs of Greater
Cambridge in the next Local Plan period. The land is considered to be available, achievable and
suitable and the development proposals will bring a number of tangible social, economic and
environmental benefits to support the delivery of a sound and sustainable spatial strategy as part
of the Local Plan, including:
● The opportunity to deliver a substantial amount of affordable housing to help meet the needs
of Longstanton and the wider District, including the potential to possibly deliver an element of
custom and self-build;
● Locating residential development in a sustainable location, within close proximity to existing
and proposed services, facilities, infrastructure and employment opportunities. The site is
located approximately 150m from the village High Street, located adjacent to allocations for
employment development and an extension to the recreation ground and is well within cycling
distance of the Longstanton Park and Ride. The site is therefore well placed for future
residents to be able to walk and cycle, rather than travel by private car, to meet their daily
needs;
● A landowner who wishes to work with the community in order to shape a proposal which
meets the needs of and can provide wider benefits to the village;
● Delivery of a substantial amount of open space which would be accessible to new and
existing residents and would provide connectivity with the allocated recreation ground
extension;
● Supporting Longstanton’s economy, including local shops and services; and
● Enhancing biodiversity levels across the site. The site is predominantly agricultural land and
can currently be considered to be of low ecological value. The The proposals present an
opportunity to deliver a biodiversity net gain of at least 10%.

As set out in our comments on Policy S/DS, we do not consider that the Plan contains sufficient small and medium site allocations, nor does it comply with paragraph 79 of the NPPF, which states that housing should be located where it will enhance or maintain the vitality of rural communities, to promote sustainable development in rural areas. It is clear that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Paragraph E.9 of Appendix E to the Sustainability Appraisal states that ‘The Councils’ evidence shows that Greater Cambridge’s villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of Greater Cambridge’s villages.’ As set out in our comments on the SA, we dispute that the SA provides an accurate and consistent assessment of the options, with many unjustified assumptions made in relation to villages which result in an artificially negative outcome.

Paragraphs E.24 and E.25 of Appendix E to the SA state that the better served villages have been subject to site specific sustainability appraisal, identified as sites at Rural Centres, Minor Rural Centres and Group Villages. It confirms that sites at other villages were not considered as reasonable options, as they would not provide sustainable locations to allocate development.

Whilst we do not dispute this to be the case for the majority of Infill villages, there are some Infill Villages which do benefit from a greater level of facilities and services, and public transport than others, such as Shepreth, which is also located outside of the Green Belt.

Shepreth is the only Infill Village which benefits from a train station and is the location of one of only seven stations within Greater Cambridge. In addition, the settlement already benefits from a number of other facilities, services and employment opportunities. Despite its status as an Infill Village, development within Shepreth would be consistent with the stated influences of the preferred spatial strategy, including reducing climate impacts through compact development located to connect homes and jobs where active and sustainable travel can be maximised, as well as making the best use of existing and committed key sustainable transport infrastructure. It would also support a rural community to thrive and sustain services.

The land at Frog End, Shepreth (Site Reference: 40085) has been promoted by Scott Properties throughout the emerging Plan process, and represents a unique opportunity to deliver a residential-led development outside of the Green Belt and within close proximity to the train station, of a quantum which would be capable of providing significant community benefits and open space. This would include employment use, incorporating smaller units at affordable rates to support Small and Medium Enterprises, as well as start-up businesses, sustainably located to maximise the connectivity the site provides through additional pedestrian and cycle links, as shown in the accompanying Framework Masterplan. The site also provides the opportunity to include further community benefits, working closely with the Parish to ensure those reflect the needs and aspirations of the local community. There is sufficient flexibility owing to the size of the site for this to include sports, leisure, recreational and/or retail uses.

A variety of housing including older persons’ accommodation, self-build properties, as well as key worker housing would also respond to local needs in an area with excellent accessibility into Cambridge.

The site was assessed within the HELAA (reference 40085), scoring a ‘red’ for suitability and ‘green’ for availability and achievability. This is due to the site scoring ‘red’ in relation to Townscape and Landscape, noting a TPO on site, with the assessment concluding that:
‘Development would significantly alter and harm the existing character of this small rural village and could effectively double the size of Shepreth. It would be an encroachment into the countryside, incongruous and an urbanisation of the rural landscape.’

We question how the conclusions have been arrived at, in the absence of any landscape studies forming part of the Plan’s evidence base. This is particularly considering many of the sites assessed within the HELAA are greenfield, edge of settlement locations, which do not receive the same commentary in relation to encroachment into the countryside and urbanisation of the rural landscape. The site is also not within the Green Belt, therefore we consider the site to have received an unduly negative assessment against this criterion.

Further, we would highlight that development of this quantum within Shepreth, which benefits from one of only seven train stations within Greater Cambridge, would enhance the sustainability of the settlement, capable of providing benefits in addition to housing which smaller scale development would be unable to provide. As previously referenced, this includes additional community benefits which could take the form of sports, leisure, recreation and/or retail, in addition to a broad range of housing and employment uses which would respond to many different needs within the area.

The site scored ‘amber’ against a number of criteria within the assessment, which we consider to be unjustified. In relation to flood risk, the site scores ‘amber’ despite being wholly within Flood Zone 1, and with negligible areas of low risk surface water flooding, which could be suitably addressed through a sustainable urban drainage system. As such, the site should receive a ‘green’ score against this criterion.

The site scores ‘amber’ in respect of Biodiversity and Geodiversity, with the assessment incorrectly stating that the site is within a SSSI. Part of the site’s south-western boundary is adjacent to the southern part of L-Moor, Shepreth SSSI, and the assessment notes that close consultation would be required with Natural England, including assessment of increased visitor pressure on the SSSI. The assessment also confirms that there are no priority habitats within the site, although notes the presence of hedges and wooded boundaries that are likely to have ecological value. The assessment confirms that development of the site may have a detrimental impact on a designated site, or those with a regional or local protection but that impact could be reasonably mitigated or compensated.

As shown in the Framework Masterplan accompanying these representations, a considerable landscape buffer would be included between the site’s boundary with the SSSI, and the proposed areas of built form. Further, additional sizeable areas of open space would be included, providing additional and alternative recreational opportunities to the SSSI, which could reduce recreational pressure on the protected areas. The Framework Masterplan also shows proposed diverted public rights of way around the edge of L-Moor Shepreth SSSI, resulting from discussions with the Wildlife Trust, who have confirmed that directing footpaths to the edge of the SSSI (currently through the centre) would be beneficial. Scott Properties are committed to working with the Wildlife Trust to protect and enhance the SSSI, an opportunity which is unique to the land at Frog End.

In addition, and in accordance with the provisions of the Environment Act 2021, the site could deliver a biodiversity net gain in excess of 10%, which would include the retention and enhancement of the boundary features. Owing to the significant biodiversity benefits that could be delivered on this site, owing in part to its location and size, it is considered that the site should be scored ‘green’.

The site is located within 750m of the train station, which provides access into the centre of Cambridge within 12 minutes. This equates to a walking time of approximately 10 minutes, or a cycle time of three minutes, and highlights how the suitability of the land at Frog End as a location for growth.

Shepreth is closely associated with the neighbouring villages of Foxton, Barrington, Meldreth and Melbourn, all of which provide additional services and facilities accessible on foot from the site via the existing public right of way network, or by cycling. Despite this, the site scores ‘amber’ in relation to Accessibility to Services and Facilities, which we consider is inaccurate and should be ‘green’.

As demonstrated within the accompanying Access Drawing, safe and suitable vehicular access into the site can be achieved from Frog End to the south. The HELAA recognises that the proposed site is acceptable in principle, subject to detailed design, yet scores ‘amber’ in relation to both Site Access and Transport and Roads. The accompanying Masterplan Concept Layout also demonstrates that multiple footpaths and cycle links could be provided through the site, providing recreational opportunities and providing sustainable transport options. As such, it is considered the site should score ‘green’ for these elements.

As shown within the accompanying Framework Masterplan, the site’s proximity to the railway has been factored into the design, with proposed open space and landscaping providing a considerable buffer between the proposed built form and the railway line. In addition, there are no issues on site in relation to light pollution or odour. As such, appropriate and effective mitigation can be provided on the site, therefore a score of ‘green’ is appropriate.

In light of the above, it is considered that Shepreth should be considered as a sustainable location for growth, in accordance with the aims of the Plan and the NPPF. The site represents a unique opportunity to deliver significant benefits through new housing, employment and community facilities, owing to its location and size, which would not be achievable on a smaller site or with a smaller quantum of development.

The proposed Policy S/RRA: Site allocations in the rest of the rural area “allocates sites for homes or employment that support the overall development strategy within the rural area, excluding the rural southern cluster”.

The supporting text adds that:
“For employment, we considered the evidence from our Greater Cambridge Employment Land Review & Economic Development Evidence Base (2020) to understand the locational demand of different sectors. We then reviewed site opportunities to identify the preferred list of sites. The site selection was informed by the Housing & Employment Land Availability Assessment, and taking into account sustainable travel opportunities alongside the likely travel requirements of the proposed uses. We identified land that could respond to the need for local warehousing and distribution with good access to the highway network. We also identified some small-scale opportunities in accessible locations which could add the mix and types of land available.”

The J25 Bar Hill site is not allocated for development. Instead, the GCLP makes two allocations within the rest of the rural area that include an element of light industrial, warehousing and/or distribution uses (Use Classes B2 and B8). This list does not include Classes E(g)(i) Offices to carry out any operational or administrative functions, E(g) (ii) Research and development of products or processes; and E(g) (iii) Light Industrial processes. It also does not include allocations for replacement of existing floorspace (e.g. S/RRA/OHD Old Highways Depot, Twenty Pence Lane, Cottenham).
• S/RRA/SAS Land to the south of the A14 Services: 18.2ha suitable for Class B2 (General Industrial) and Class B8 (Storage or Distribution) providing a range of small and medium sized units.
• S/RRA/CR Land at Buckingway Business Park, Swavesey: 2.1ha for Class B2 (General Industrial) or Class B8 (Storage or Distribution). B8 use would be limited to small to medium sized premises.

Based on the above, the GCLP would be providing up to 20.3ha (based on our assessment in Appendix 1, the developable area is much less) of Class B2/B8 floorspace within the Rest of the Rural Area. There are no further allocations for Class B2/B8 floorspace in the emerging GCLP1.

Moreover, and as detailed in our response to Policy S/JH (New jobs and homes), the ELEDES’s storage and distribution uses floorspace need projections are a significant underestimate. Instead, we have identified a requirement for allocating additional land of 69.0 ha to 85.5 ha for storage and distribution uses which is suitable, available and deliverable across the Plan period to 2041. Considering the developable supply position in Greater Cambridge, this results in a shortfall of strategic logistics land of 55.0 ha to 71.5 ha.

J25 Bar Hill has capacity to deliver around 60 ha of developable floorspace and as evidenced by Appendices 3 and 4 of this Representation, is suitable, available and achievable, contrary to the conclusions of the Greater Cambridge’s HELAA Site Assessment ref.40248 (Appendix 2).

The site’s assessment is summarised at Appendix 3. As evidenced, the site is suitable, available and achievable and would help to meet Greater Cambridge’s employment need over the plan period to 2041, in accordance with the requirements of the NPPF.

The allocation of J25 Bar Hill for a sustainable leading-edge employment park development with business and logistics capability and capacity of around 60ha to meet the identified shortfall of employment land across the Plan period would fully align with emerging Policy S/DS and NPPF Paragraphs 11 and 83. Further and as recognised on pg. 36 of the supporting text of the GCLP “providing a healthy supply of land for business use should also help ensure land is affordable for all business sectors, including those which cannot afford higher cost space.”

Some of the clear planning benefits of allocating this site, over any others, include:

1 Strategic highways access: J25 Bar Hill is located just off Junction 25 of the recently upgraded A14, a key nodal point on the strategic road network, connecting the site with the Midlands ‘Golden Triangle’, London, the Freeports of Felixstowe and Harwich International and the existing employment provision in Greater Cambridge. The locational opportunity provided by the converging of many strategic roads around Cambridge for accommodating such strategic development on large sites would help meet local, regional and national employment need.

2 Minimal impact on the local highway network: given the location just off the strategic road network, it would not be necessary for larger delivery vehicles to use the local highway network, which would be required for comparable allocations on the edge of large settlements like Cambridge, contributing towards decreasing congestion, improving air quality and, overall, tackling the climate crisis.

3 Site size: the site has the capacity to deliver around 60 ha of developable space, contributing to meeting the identified employment shortfall of 55.0 ha to 71.5 ha across the Plan period. A single and large allocation is sustainable and offers the capability and flexibility of a range of unit sizes to respond to the spatial needs of different sectors, including the fast-growing and rapidly innovating logistics sector. This may not be possible for a series of smaller allocations. Further the site size offers the opportunity for extensive landscaping and greening with FPCR’s Biodiversity and Geodiversity Technical Appraisal (Appendix 4(iii)) identifying capability of achieving a c.12-20% biodiversity net gain.

4 Proximity to existing and new settlements: the site is close to new and proposed settlements of Northstowe (6,345 new homes across the Plan period), Cambourne West (2,590 homes), Cambourne (1,950 homes), Bourn Airfield (2,460 homes), Darwin Green (478 homes) and Eddington (3,142 homes). It is also in close proximity to the Waterbeach New Town. On this basis, the site will contribute to minimising workforce travel distances and maximise accessibility by sustainable transport opportunities such as bus or more active modes of transport such as cycling and/or walking. In addition, providing logistics facilities close to urban centres enables the use of electric fleet (which currently have specific distance limitations) and cargo bikes for last mile deliveries. These contribute towards decreasing congestion, improving air quality and, overall, tackling the climate crisis and contributes to the recently introduced Net Zero Strategy: Build Back Greener.

5 Opportunity for economic cluster on A14: there are a number of comparable existing businesses along the A14 including Bar Hill and Trafalgar Way which is identified as an important advance manufacturing cluster in the north of Greater Cambridge. In addition, the two emerging employment allocations ‘S/RRA/SAS Land to the south of the A14 Services’ and ‘S/RRA/CR Land at Buckingway Business Park, Swavesey’ prove that Greater Cambridge recognise the dynamics of this location along the A14. The allocation of J25 Bar Hill would help to exploit agglomeration benefits and complement the employment and business space offer along the A14 Corridor.

6 No major environmental and heritage constraints: the site is outside of the Green Belt and as detailed at Table 2 above there are no major environmental or heritage constraints that we would anticipate preventing the delivery of this site. Critically, at FPCR’s Landscape and Townscape Appraisal (Appendix 4(ii)), the site has been assessed as ‘Green’ in Landscape and Townscape terms instead of ‘Red’ in the HELAA.

We would therefore recommend that Policy S/RRA (Allocations in the Rest of the Rural Area) is amended to include a new allocation for the J25 Bar Hill site for a major leading-edge employment park development with business and logistics capability and capacity.

It is unclear why so little development is distributed to rural settlements beyond the Green Belt. There are settlements such as Meldreth that offer scope to deliver highly sustainable development due to its infrastructure connectivity and imbalance of jobs to homes, that have been completely overlooked. Sites such as Bury Farm that constitute a bad neighbour use, that are sustainably located and offer the potential to create highly sustainable patterns of development should be positively supported through positive land use allocations.

This policy is considered to only illustrate further the lack of distribution in housing 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. The residential allocations propose a total of 104 homes and the mixed use allocation 120 homes. This is considered to be a small additional contribution to housing allocations in the entirety of the rural area. As such further consideration should be given to the delivery of housing in Willingham.

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

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

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

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

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

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

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

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

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

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

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

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

Comberton is a Minor Rural Centre, recognised within the South Cambridgeshire Local Plan as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire.

Scott Properties has promoted the land to the west of South Street, Comberton (Site Reference: 40310) through the emerging Plan process for residential development. The site received a ‘red’ score for suitability, and a ‘green’ score for both availability and achievability.

The site scores ‘red’ against Site Access, with the assessment concluding that there is no possibility of creating a safe access. This conclusion is disputed. As shown within the Masterplan Concept Layout accompanying the submission, Scott Properties has identified a number of potential access points into the site, which would provide safe and suitable access onto a public highway. As such, we consider this should be amended to ‘amber’ to reflect the situation.

It also scores ‘red’ against Strategic Highways Impact. We would reiterate our earlier comments on this part of the site assessment, which draws arbitrary zones that assume all traffic will use the specified junction. Further, Comberton is also located within the north-western corner of Zone 8, within close proximity to Zones 9 and 10 which are noted as having capacity for growth. Additionally, we note from Appendix 2 to the HELAA that a ‘red’ score does not rule out sites at this stage, as development proposals within these zones will need to demonstrate no net increase in vehicle trips on the strategic road network. A red score, regardless of whether this is possible, has acted to rule out sites from consideration for allocation by scoring them ‘red’ for suitability. As such, we consider the sites in the zones identified as having no capacity for growth should be scored ‘amber’ to reflect that this should not rule out development at this stage.

In relation to Flood Risk, the site is located wholly within Flood Zone 1, with only a small proportion of the site area at risk from surface water flooding. Given the limited extent of the area affected, and the ability to effectively mitigate any risk through a sustainable urban drainage strategy, we consider this assessment should be amended to ‘green’.

The site scores ‘amber’ in relation to Landscape and Townscape. We question why views from neighbouring properties into the site warrants a score of ‘amber’, particularly when this is the case for the majority of sites close to a settlement edge and has not been noted in respect of any other site regardless of its proximity to other properties. The inclusion of landscape buffers is also provided as a mitigation measure, although we question what evidence exists to support the requirement for a 15m buffer between the site and existing properties, particularly when development of the site would require minimum back-to-back distances and good design principles to be observed. Given there would be a design solution to mitigate any potential concerns around the site’s relationship to surrounding uses, we consider that the site should be scored ‘green’.

In relation to Biodiversity and Geodiversity, the site scores ‘amber’, noting the requirement for an assessment of increased visitor pressure on the Eversden and Wimpole Woods SAC, which is a considerable distance from the site. The assessment notes that the site may have a detrimental impact on a designated site, but any impact could be reasonably mitigated or compensated. As such, we are unclear why the assessment does not score ‘green’ given there is a satisfactory solution should any mitigation be required (which the assessment assumes but is not confirmed).

The site scores ‘amber’ in relation to Historic Environment, being located within 100m of both a Listed Asset and a Conservation Area. It is clear from the Village Inset Map for Comberton that the main Conservation Area is physically separated from the site by considerable intervening built form.
The secondary Conservation Area, located to the east of South Street and to the south-east of the site is also separated from the site by intervening vegetation, which visually separates the site from this area. The closest listed building is also adjacent to South Street to the east of the site, and is separated from the site by built form and a considerable landscaping which screens the asset from the site.

As such, we question how the site could have any impact on either, and the assessment should be amended to ‘green’ to more accurately reflect the situation.

We would highlight the site’s ‘green’ score in relation to Accessibility to Facilities and Services. Development of the site would fully accord with the Council’s objectives to located development where climate change could be mitigated, close to existing facilities, services and public transport.

The Green Belt assessment concluded the harm rating to be ‘moderate’ for the site (parcel CO10), one of the lower scoring parcels surrounding the settlement.

We believe that Fulbourn is an excellent location for sustainable development.
The land west of Station Road is centrally located and has potential to deliver up to 150 homes within Fulbourn, with excellent links to the sustainable transport network via the Fulbourn Greenway.

Evidence from the CPIER (2018) report identified the east side of the city (of which Fulbourn is on) as offering significant scope for housing and commercial development. Such development would have the advantage of being close to the principal centres of employment and the existing rail infrastructure whilst also opening up opportunities for new transport links to connect the main centres of employment more effectively'.

The land west of Station Road is located within close proximity to shops, services, and facilities including a primary school, together with regular bus services to major employment locations such as Capital Park, Tesco, Biomedical Campus/Addenbrookes Hospital, the railway station area, and the historic city centre and should not be discounted for development. Development of the land west of Station Road would allow for the sustainable growth of Fulbourn as a rural centre and should be included within the plan.




It is clear that policy S/RRA/H/3 (Fulbourn and Ida Darwin Hospitals) are an excellent location for development. Therefore, it seems illogical that available land, so close to this location, such as the land west of Station Road, should be overlooked by this plan. The land west of Station Road has enviable links to the proposed Fulbourn Greenway and would provide an excellent expansion site within the centre of the village. We suggest that the land west of Station Road should be included as an additional allocation within the rural area.

Please see enclosed representations which comment on Policy J/NE and Policy S/JH.

POLICY CONTEXT FOR SUBMITTING ADDITIONAL INFORMATION IN RESPECT OF HEYDON END SITE, REF 47352

The proposed selection of sites from the Call for Sites proposals includes only 4% from the Rest of the Rural Area. This is despite the National Planning Policy guidance calling for 10% of sites to be local small scale sites. The fact that none of the “approved” sites are from what are currently infill villages shows that this Local Plan has not taken any opportunity to actually change the way that smaller villages are treated to make them sustainable.

In Heydon, there is the perfect example of such an opportunity to explore a more rural focussed development proposal, and a well documented appetite from the residents for some small scale development, with smaller properties on a site which will not impact on the village street scene, or broader landscape and which has environmental benefits.

The proposal for around eight small houses at Heydon End (47352) is such a site. It includes setting aside a significant portion of the site for tree planting, for screening, biodiversity enhancement, a community facility in an existing barn, it is well planned for solar and ground source heat pump renewable energy self -sufficiency, and provides an excellent platform for other sustainable innovations.



NEW INFORMATION;
SURVEYS OF LOCAL RESIDENTS ATTITUDE TO DEVELOPMENTS SHOWS CONSIDERABLE SUPPORT FOR SMALL SCALE DEVELOPMENT AT HEYDON

There have been two surveys of residents attitude to development carried out by the Heydon Parish Council. The first was in February 2021 asking about attitudes to the six Call for Sites proposals at Heydon, the second was in November 2021 asking about attitudes to more general development issues, in a Parish Plan format.

The results of the February questionnaire are available on the Heydon Parish Council website at heydonparishcouncil.com
The most important table is reproduced below, with the scores for positive or negative attitudes to individual sites in the Call for Sites proposals at Heydon. I have added a column showing the proportion of responses which were neutral, positive or very positive.

“HEYDON PARISH COUNCIL HEYDON QUESTIONNAIRE FEBRUARY 2021 Question 1 Of the five sites put forward, are there any specific locations that you think are suitable for new homes/development (1-5 being very negative to the proposed development, 3 being neutral and 5 being very positive) ?”


SCORE
1
2
3
4
5 %3+4+5/
ALL SCORES (POSITIVITY INDICATOR)
Heydon Golf Course 1 45 1 2%
Heydon Golf Course 2 44 1 2%
Land south of Heydon Lane 32 11 3 3 13%
Land west of Fowlmere Road 30 8 4 1 12%
Land West of Chishill Road 33 7 3 3 13%

HEYDON END
29

3
9
3
6
36%



As can be seen, the proportion of neutral, positive or very positive scores was 36% for Heydon End (47352), whereas the average for the other proposals was 8%. Clearly, Heydon End (47352)would be selected as the most well supported proposal, with what is in fact a very high level of support for a residential development in any village, which is normally met with almost unqualified opposition as you will know from many such proposals.

Comments about Heydon End in the questionnaire incuded -
“Heydon End as it is the smallest of the proposed developments –most suitable
“Of all the six proposed developments only Heydon End appears to have any merit.”
“ This is the smallest of the proposed developments and as such would have the least impact on the village. Heydon End should be within the village envelope-only feasible site which could provide a small development. Edge of village with least impact on village infrastructure”

None of the other sites had any positive comments, and Heydon End (47352) stands out as having received significant positive sentiment.
In November 2021 a Parish Plan has was prepared for Heydon, with possible development as one of the aspects included in a questionnaire.
Important findings relating to development proposals are given in Q.15 Type of Residential Development Desirable or Acceptable.
Q15 -% OF RESPONDENTS SUPPORTING TYPES OF DEVELOPMENT
NO DEVELOPMENT 28%
SMALLER MARET HOUSING 42%
PREMIUM HOUSING 13%
AFFORDABLE LOCAL HOUSING 43%
LOCAL AUTHORITY/HOUSING ASSOCIATION 16%
SELF-BUILD PLOTS 33%
MIXTURE 20%

Only just over a quarter of respondents were against any development, nearly a half would support smaller market housing. This is remarkable degree of support for this type of development in a small village. And this is precisely what the Heydon End (47352)proposal would, uniquely, provide.











A further important table is given below;
Q16 – ACCEPTABLE SCALE OF RESIDENTIAL DEVELOPMENT,
% SUPPPORT FOR SCALE OF DEVELOPMENT
NONE 20%
INFILL/LINEAR 68%
SMALL (UP TO 8 HOUSES) 32%
LARGE (UP TO 20 HOUSES) 7%

The opposition to any development was only a fifth of respondents, and whilst two thirds were content with the existing infill policy, this does of course, and a third who would be happy to have smaller scale developments of up to 8 houses, which is of course just the type of development proposed at Heydon End.(47352)
So we have situation where nearly half of the village would like smaller houses, around a third would like developments of up to 8 houses, (from the Parish Plan|), and around a third are supportive of Heydon End (47352) proposals quite specifically from the February Questionnaire. This suggest that the site would be very acceptable to local residents.
HELAA ASSESSMENT BY GREATER CAMBRIDGE PLANNING PARTNERSHIP – CORRECTIONS AND FURTHER INFORMATION
The HELAA Assessment for site reference 47352 has no red flags except relating to Accessibility to Services and Facilities used in the HELAA.
Note that the Adopted Development Plan Policies issue assessment is amber, on the grounds that the site is “Primarily outside the Development Framework”. So the fact that some of the site lies outside the Development Framework does not render the assessment red, should mean for this HELAA assessment that the Accessibility to Services and Facilities standards is the same as for approving Infill


Sites, which do not require these exacting accessibility distances, . This would of course mean that the Accessibility to Services and Facilities assessment would be amber.
The Historic Environment Assessment is amber on the grounds that part of the property is within 100m of a listed asset and 100 m of a conservation area. Note that the actual area within the property that is proposed for development on this site is greater than 100m from listed assets and the conservation area. The existing house at the front of the property is the only part near to the assets and conservation area, and this is not proposed to be changed, hence there will be no effective change to the impact on the historic setting by the proposed development.

Accessibility to Services and Facilites assessment is given as red, but it is worth noting the actual distances to these facilities.
-The nearest school is at Chrishall, only 1,400 m away, with another at Barley only 3,000m away
-Distance to Healthcare Service at Barley is only 3000 m away.
-Distance to Rural Centre at Royston is 6,000 m away.
-Distance to Employment Opportunities with the King William pub and restaurant only 400 m away and Wood Green Animal Shelter site is only 300 m away, hence the assessment that Employment opportunities are “Greater than 1,800 m” is categorically incorrect.
-Distance to Public Transport is of course very low since there is regular bus service that passes by the property and a bus shelter in the village of Heydon.

So the conclusion that overall there is inadequate access to key local services, transport and employment opportunities is incorrect in that ignores a school barely outside the required distance, a health centre very close by, employment opportunities close by, and transport close by. There is also very active local church with community functions.



Contamination and Ground Stability Issues states that there is potential for historic contamination. The site has been an low intensity agriculture, and now a paddock, so has had low key land use with no contamination history, and nothing specific is given in this assessment to justify and potential for historic contamination.


Constraints to development issue state that a Public Right of Way is on or crosses the site. This is completely wrong. The map used for the HELAA assessment is the planning map used by South Cambridgeshire District Council, and this seems to indicate about 6m of footpath crossing the very south east end of the site. However the Cambridgeshire County Council definitive map shows that the actual line of the footpath is outside the property. If the HELAA assessment had looked at the actual line of the footpath, they would have seen that it passes southeast of pond feature shown on the map, and that the boundary of the site is lies to the northwest of the pond feature. This is also confirmed by the land registry boundary of the site, showing that the boundary of the site does not include the area shown as pond with a footpath. It should be noted that the shaded area shown as pond on the definitive map is no longer a pond. Also the fence line of the site is northwest of the footpath and has always been there. So there is no constraint relating to a footpath or other right of way.

SUMMARY
My consultation response is that the exclusion of current infill villages from any call for sites approvals shows a lack of bold thinking about how to sensitively and sustainably help to give new life to any of the smaller villages. There should be some opportunities taken to treat infill villages differently from the current approach. At the very least, there should be some pilot test schemes to try out something new.


As I have explained above the Call for Sites proposal for Heydon End, reference 47352, and at page 404 in HELAA appendix 4b, provides just such a perfect opportunity to embrace small scale local development. Not only is the site good for this purpose in itself, but also there is sufficient support for this type of development, and Heydon End specifically shown in the two Parish Council surveys. And there is sufficient new information, correction, and clarification provided to the HELAA assessment for Heydon End to be reconsidered and approved for the next stage of consideration.

1. Introduction
This representation is made by Hertfordshire County Council (HCC) Growth & Infrastructure Unit, in relation to the Greater Cambridge Partnership (GCP) Local Plan First Proposals Consultation. The comments within this representation reflect the interests of the following services that are provided by HCC, along with other relevant areas within the Environment & Infrastructure Department (excluding HCC Property): Highways & Transport (HCC as Highways Authority and Network & Travel Planning)

2. Highways and Transport
HCC would be keen to ensure the sites of ‘Land to the West of Cambridge Road’ and ‘The Moor Lane, Melbourn’ are fully integrated into the proposed Melbourn Greenway and A505 Walking and Cycling bridge, to facilitate an active travel link between these sites, Cambridge to the north and Royston to the south. HCC would want to support the proposed bus network improvements suggested, to better facilitate cross border routes and trips. HCC are pleased that work on these improvements seems to be ongoing, and we are committed to working with the Greater Cambridge Partnership to deliver these important sustainable transport links.

Rest of the rural area
33. CPRE does not support development S/RRA/H Land at Highfields (phase 2), Caldecote. On its own as a
village development this would have made sense. However, given the proximity of the nearby major
development at Bourn Airfield, CPRE considers this will eventually lead to coalescence and a continuous
urban sprawl alongside the A428 from Caldecote to Cambourne.
34. CPRE is concerned by proposal S/RRA/CR Land to the west of Cambridge Road, Melbourn. At first sight,
there is logic to this proposal but it could further industrialise the centre of this historic village which has
already been badly visually affected by the existing Science Park.
35. CPRE would not support further development at the Cambridge Services site close to the A14 as proposed
by S/RRA/SAS, Land to the south of the A14 Services. There is no natural barrier to prevent further
expansion into the wide-open landscape at this location which has already been damaged by the necessary
but unfortunate location of the services. Such development will lead to further, unsightly, road freight
driven sprawl.
36. For similar reasons, and the potential for additional traffic through the centres of Swavesey and Over, CPRE
would not support the further expansion proposed by S/RRA/BBP, Land at Buckingway Business Park,
Swavesey.
37. CPRE would like to see some form of development protection given to the nearby, former private, outdoor,
laboratory of the late Dr Norman Moore at Boxworth End, Swavesey. Dr Moore was one of the UK’s most
significant conservation scientists of the 20th century. He founded the former Monks Wood Research
Station and established the link between wildlife mortality and widely-used pesticides. The site itself has
some local value as habitat and a landscape amenity. However, its overwhelming significance is as a site of
scientific study, in particular of ecology and wildlife conservation. This small site was created and studied
minutely by a scientist who led the world in his chosen fields - the ecology of hedges and the chemistry of
certain pesticides. Boxworth End could show future generations how these issues were first confronted.
CPRE’s ongoing national campaign, supported by Lord Deben, to protect and enhance hedgerows nationally
attracted a lot of support at a day in Parliament recently, demonstrating just how important hedgerows are
to the future health of the countryside and at what level this is recognised.
38. CPRE is not in favour of proposal S/RRA/SNR, Land to the north of St Neots Road, Dry Drayton. This small
land parcel forms a green buffer between St Neots Road and the A428 and development would create
further coalescence along the A428.
6
39. CPRE would support the redevelopment proposed by S/RRA/OHD Old Highways Depot, Twenty Pence Lane,
Cottenham, providing it was limited to employment Class E(g)(i) (offices to carry out any operational or
administrative functions) and/or E(g)(ii) (Research and development of products or processes). CPRE would
strongly oppose development of this site for Class B8, storage and distribution use. Cottenham already
endures significant disturbance from HGV traffic arising from the industrial site further north along Twenty
Pence Road.

Rest of the rural area
33. CPRE does not support development S/RRA/H Land at Highfields (phase 2), Caldecote. On its own as a
village development this would have made sense. However, given the proximity of the nearby major
development at Bourn Airfield, CPRE considers this will eventually lead to coalescence and a continuous
urban sprawl alongside the A428 from Caldecote to Cambourne.
34. CPRE is concerned by proposal S/RRA/CR Land to the west of Cambridge Road, Melbourn. At first sight,
there is logic to this proposal but it could further industrialise the centre of this historic village which has
already been badly visually affected by the existing Science Park.
35. CPRE would not support further development at the Cambridge Services site close to the A14 as proposed
by S/RRA/SAS, Land to the south of the A14 Services. There is no natural barrier to prevent further
expansion into the wide-open landscape at this location which has already been damaged by the necessary
but unfortunate location of the services. Such development will lead to further, unsightly, road freight
driven sprawl.
36. For similar reasons, and the potential for additional traffic through the centres of Swavesey and Over, CPRE
would not support the further expansion proposed by S/RRA/BBP, Land at Buckingway Business Park,
Swavesey.
37. CPRE would like to see some form of development protection given to the nearby, former private, outdoor,
laboratory of the late Dr Norman Moore at Boxworth End, Swavesey. Dr Moore was one of the UK’s most
significant conservation scientists of the 20th century. He founded the former Monks Wood Research
Station and established the link between wildlife mortality and widely-used pesticides. The site itself has
some local value as habitat and a landscape amenity. However, its overwhelming significance is as a site of
scientific study, in particular of ecology and wildlife conservation. This small site was created and studied
minutely by a scientist who led the world in his chosen fields - the ecology of hedges and the chemistry of
certain pesticides. Boxworth End could show future generations how these issues were first confronted.
CPRE’s ongoing national campaign, supported by Lord Deben, to protect and enhance hedgerows nationally
attracted a lot of support at a day in Parliament recently, demonstrating just how important hedgerows are
to the future health of the countryside and at what level this is recognised.
38. CPRE is not in favour of proposal S/RRA/SNR, Land to the north of St Neots Road, Dry Drayton. This small
land parcel forms a green buffer between St Neots Road and the A428 and development would create
further coalescence along the A428.
6
39. CPRE would support the redevelopment proposed by S/RRA/OHD Old Highways Depot, Twenty Pence Lane,
Cottenham, providing it was limited to employment Class E(g)(i) (offices to carry out any operational or
administrative functions) and/or E(g)(ii) (Research and development of products or processes). CPRE would
strongly oppose development of this site for Class B8, storage and distribution use. Cottenham already
endures significant disturbance from HGV traffic arising from the industrial site further north along Twenty
Pence Road.

Rest of the rural area
33. CPRE does not support development S/RRA/H Land at Highfields (phase 2), Caldecote. On its own as a
village development this would have made sense. However, given the proximity of the nearby major
development at Bourn Airfield, CPRE considers this will eventually lead to coalescence and a continuous
urban sprawl alongside the A428 from Caldecote to Cambourne.
34. CPRE is concerned by proposal S/RRA/CR Land to the west of Cambridge Road, Melbourn. At first sight,
there is logic to this proposal but it could further industrialise the centre of this historic village which has
already been badly visually affected by the existing Science Park.
35. CPRE would not support further development at the Cambridge Services site close to the A14 as proposed
by S/RRA/SAS, Land to the south of the A14 Services. There is no natural barrier to prevent further
expansion into the wide-open landscape at this location which has already been damaged by the necessary
but unfortunate location of the services. Such development will lead to further, unsightly, road freight
driven sprawl.
36. For similar reasons, and the potential for additional traffic through the centres of Swavesey and Over, CPRE
would not support the further expansion proposed by S/RRA/BBP, Land at Buckingway Business Park,
Swavesey.
37. CPRE would like to see some form of development protection given to the nearby, former private, outdoor,
laboratory of the late Dr Norman Moore at Boxworth End, Swavesey. Dr Moore was one of the UK’s most
significant conservation scientists of the 20th century. He founded the former Monks Wood Research
Station and established the link between wildlife mortality and widely-used pesticides. The site itself has
some local value as habitat and a landscape amenity. However, its overwhelming significance is as a site of
scientific study, in particular of ecology and wildlife conservation. This small site was created and studied
minutely by a scientist who led the world in his chosen fields - the ecology of hedges and the chemistry of
certain pesticides. Boxworth End could show future generations how these issues were first confronted.
CPRE’s ongoing national campaign, supported by Lord Deben, to protect and enhance hedgerows nationally
attracted a lot of support at a day in Parliament recently, demonstrating just how important hedgerows are
to the future health of the countryside and at what level this is recognised.
38. CPRE is not in favour of proposal S/RRA/SNR, Land to the north of St Neots Road, Dry Drayton. This small
land parcel forms a green buffer between St Neots Road and the A428 and development would create
further coalescence along the A428.
6
39. CPRE would support the redevelopment proposed by S/RRA/OHD Old Highways Depot, Twenty Pence Lane,
Cottenham, providing it was limited to employment Class E(g)(i) (offices to carry out any operational or
administrative functions) and/or E(g)(ii) (Research and development of products or processes). CPRE would
strongly oppose development of this site for Class B8, storage and distribution use. Cottenham already
endures significant disturbance from HGV traffic arising from the industrial site further north along Twenty
Pence Road.

Rest of the rural area
33. CPRE does not support development S/RRA/H Land at Highfields (phase 2), Caldecote. On its own as a
village development this would have made sense. However, given the proximity of the nearby major
development at Bourn Airfield, CPRE considers this will eventually lead to coalescence and a continuous
urban sprawl alongside the A428 from Caldecote to Cambourne.
34. CPRE is concerned by proposal S/RRA/CR Land to the west of Cambridge Road, Melbourn. At first sight,
there is logic to this proposal but it could further industrialise the centre of this historic village which has
already been badly visually affected by the existing Science Park.
35. CPRE would not support further development at the Cambridge Services site close to the A14 as proposed
by S/RRA/SAS, Land to the south of the A14 Services. There is no natural barrier to prevent further
expansion into the wide-open landscape at this location which has already been damaged by the necessary
but unfortunate location of the services. Such development will lead to further, unsightly, road freight
driven sprawl.
36. For similar reasons, and the potential for additional traffic through the centres of Swavesey and Over, CPRE
would not support the further expansion proposed by S/RRA/BBP, Land at Buckingway Business Park,
Swavesey.
37. CPRE would like to see some form of development protection given to the nearby, former private, outdoor,
laboratory of the late Dr Norman Moore at Boxworth End, Swavesey. Dr Moore was one of the UK’s most
significant conservation scientists of the 20th century. He founded the former Monks Wood Research
Station and established the link between wildlife mortality and widely-used pesticides. The site itself has
some local value as habitat and a landscape amenity. However, its overwhelming significance is as a site of
scientific study, in particular of ecology and wildlife conservation. This small site was created and studied
minutely by a scientist who led the world in his chosen fields - the ecology of hedges and the chemistry of
certain pesticides. Boxworth End could show future generations how these issues were first confronted.
CPRE’s ongoing national campaign, supported by Lord Deben, to protect and enhance hedgerows nationally
attracted a lot of support at a day in Parliament recently, demonstrating just how important hedgerows are
to the future health of the countryside and at what level this is recognised.
38. CPRE is not in favour of proposal S/RRA/SNR, Land to the north of St Neots Road, Dry Drayton. This small
land parcel forms a green buffer between St Neots Road and the A428 and development would create
further coalescence along the A428.
6
39. CPRE would support the redevelopment proposed by S/RRA/OHD Old Highways Depot, Twenty Pence Lane,
Cottenham, providing it was limited to employment Class E(g)(i) (offices to carry out any operational or
administrative functions) and/or E(g)(ii) (Research and development of products or processes). CPRE would
strongly oppose development of this site for Class B8, storage and distribution use. Cottenham already
endures significant disturbance from HGV traffic arising from the industrial site further north along Twenty
Pence Road.