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

The First Proposals plan is heavily reliant on the delivery of a handful of strategic developments, particularly large and complex sites which, on average, would take 5-8 years for the first home to be delivered. To ensure that housing delivery does not stall, and the affordability crisis worsened as a result, a pipeline of smaller developments which can deliver homes quickly will be needed in the short-to-medium term.

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. To prevent stagnation and the further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.
Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the 'open countryside'. But it is not logical to treat all sites equally in policy terms. Whilst sites within sensitive valued landscapes and the green belt should receive a high level of protection, the sensitive development of some sites on the edge of a village would cause no significant harm. Such a pragmatic approach is often taken at appeal. For example, rounding off development where there is a defensible physical boundary or allowing a high-quality scheme with extensive landscaping where it would soften an existing harsh area of built form can be acceptable in certain locations.
A carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built up areas should not perpetuate unfettered incremental growth.

Land adjacent to 61 Waresley Rd, Gamlingay (59336)

New site submitted through call for sites pro-forma.

Land off Rampton Rd, Cottenham (new site 59407)

New site submitted through call for sites proforma

Introduction

Walsingham Planning is submitting this representation on behalf of R. Cambridge Propco Limited, the owners of the Cambridge Bar Hill Hotel and Golf Course, Bar Hill, CB23, 8EU.

From the outset, we note that our client fully supports the Local Plan’s vision of planning for enough homes to meet Greater Cambridge’s needs, with a strong mix of housing types and tenures. We also note that the Local Plan First Proposals aims to deliver 1,771 new homes per year, which is 550 more homes per year than under the current policy context, and this is an ambitious strategy, which is to be supported. However, in order to secure this uplift in housing delivery, it is clear that the new Local Plan must be underpinned by a range of housing allocations which are deliverable in both the short and longer-term.

Development Strategy

Draft Policy S/DS sets out the proposed Development Strategy to deliver the vision, which includes provision for 44,400 new homes. The Strategy explains that the proposal is to utilise existing planning permissions alongside “a limited number of new sites in the most sustainable locations”. Indeed, it is clear from the schedule in the draft policy that the vast majority of the Council’s housing growth it to be accommodated on just 13 sites. Whilst concentrating housing development in a limited number of locations may have the benefit of creating sustainable new hubs of development, it also bears risks in terms of the deliverability of the strategy. For example, if there are any unforeseen delays on any of the major projects, it will have a significant detrimental impact on the ability to meet Greater Cambridge’s housing needs.

This is a real risk and one that is recognised in the National Planning Policy Framework (NPPF). We note that paragraph 60 of the NPPF states that:

“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed”.

Furthermore, paragraph 68 explains that:

“Planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability, and likely economic viability”.

More specifically, paragraph 68 notes that planning policies should identify specific deliverable sites for years 1 – 5 of the plan period; and specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan. At present the emerging Local Plan is only at the ‘First Proposals’ stage, but no information is currently provided to explain which of the proposed site allocations will be deliverable within the first five years of the plan period, and which will represent medium and longer-term opportunities.

Finally, we note the contents of paragraph 69 of the NPPF, which is clear that:

“Small and medium-sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly”.

This is a key point, and it is our view that the proposals put forward in the emerging Local Plan document are currently over-reliant on the delivery of a limited number of strategic sites. For example, of the 11,596 additional homes required, 11,200 (i.e. 97% of the total additional requirement) are planned to be provided on just 6 sites.

We note that one proposed new allocation at North East Cambridge (ref. S/NEC), which is to deliver a substantial 3,900 new dwellings, is on the site of an existing waste water treatment works. The draft policy for this allocation explains that delivery of a new mixed-use development on this site is reliant on the relocation of the existing works, a process which is being led by Anglian Water. The proposed development is also reliant on the successful implementation of the North East Cambridge Trip Budget, which has been calculated to ensure that there are no additional vehicle trips on Milton Road at peak times and subsequently no result in queuing on the A14 at Milton Interchange. It is clear, therefore, that there are significant hurdles that will need to be overcome before any scheme can progress on this site, and the timescales for development are currently very much unknown.

Similarly, 2,750 new homes are proposed on the Cambridge Airport site (Policy S/CE). However, it is clear from the policy wording that this is another long-term opportunity, as it is reliant on the closure and relocation of the airport, which is currently not anticipated to take place before 2030.

The Development Strategy also relies upon the faster delivery of housing at planned new settlements in Northstowe and Waterbeach, which will bring forward 1,500 additional new homes before 2041. However, whilst some acceleration of development may be possible at these new settlements, the additional new homes – that were previously expected after 2041 – are not likely to be available until towards the end of the plan period.

It is clear, therefore, that the emerging Local Plan relies upon its existing allocations – which have not yet been built-out - combined with a limited selection of new strategic sites, but each with its own constraints.

It is our firm view that the Local Plan should make provision for a wider range of sites, and include more small and medium-scale opportunities, to ensure a more fluid supply of housing land and ensure that there are also sites dedicated to deliver housing growth in the shorter term.

Alternative site at Bar Hill

With this in mind, it is relevant that we recently submitted our client’s site (the Bar Hill golf course) to the ‘call for sites’ exercise (ref. 56476). The site has not yet been assessed and so was not taken into account in the formulation of the First Proposals document, but we consider that it offers strong potential as a future allocation to provide an additional option to support housing growth in the Greater Cambridge area in a sustainable location.

Full details about the site can be found in our call for sites submission, and so we do not seek to reiterate all of the site specific information here. However, in summary we believe that this site has strong potential to provide a sustainable urban extension at Bar Hill (delivering around 300 homes, with complementary facilities). It should be noted that this site is available for the use proposed, and the site owner is already progressing a pre-application enquiry with the Council in relation to the prospects for the site.

The site comprises the existing golf course, with its associated fairways, roughs and bunker, alongside two ornamental lakes. There are also three storage barns located in the north of the site, which would be removed as part of any development. The site lies directly adjacent to the established settlement of Bar Hill (a minor rural centre) and has good potential to form a natural sustainable urban extension to the settlement. Indeed, the urban area of Bar Hill already extends in the direction of the golf course. The site is also bounded by the A14, which has recently been upgraded through junction improvements, and this also forms an urbanised edge to the site, on its northern boundary.

It is relevant that Bar Hill is well-served by a range of shops, services and community facilities, including a Tesco Extra store, public house, Post Office, primary school and village hall. The local centre, anchored by Tesco, is located off Saxon Way, within easy walking distance of the hotel and golf course. A new residential development on the land would thus be sustainably and accessibly located with regards to the main facilities of the settlement. It is also notable that there are two bus stops on Crafts Way (known as ‘Hollytrees’ and ‘Acorn Avenue’), which are both adjacent to - and within easy walking distance of - the golf course land, and which provide access to bus services to Cambridge, Swavesey and the centre of Bar Hill. The site would therefore be well-served by public transport.

The site is subject to few physical, heritage or environmental constraints. The site is not located within a Conservation Area and there are no listed buildings within the vicinity of the site. A stream does bisect the site along its northern extent (close to the lakes), and the land along its banks does fall within Flood Zone 2 / 3. The land within the higher flood risk areas would remain clear of residential development. The majority of the golf course, however, lies within Flood Zone 1 and is thus within the lowest area of risk of flooding from coastal and fluvial sources.

It is recognised that the entire extent of the golf course lies within the designated Green Belt. However, we note from the recent Greater Cambridge Green Belt Assessment (2021) that the land does not contribute strongly to the purposes of the Green Belt designation in this location. The Assessment identifies three purposes of the Cambridge Green Belt, and the site scores as follows:

- Purpose 1 – Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre: Limited / No contribution;
- Purpose 2 – Maintain and enhance the quality of its setting: Moderate contribution; and
- Purpose 3 – Prevent communities in the environs of Cambridge from merging into one another and with the city: Moderate contribution.

The Assessment concludes that the release of this land from the Green Belt would have a ‘moderate / high’ level of harm on the Cambridge Green Belt. The Assessment explains that this would mean that:

“Release of land results in a loss of strong contribution to one of the Green Belt purposes, but would constitute a negligible impact on adjacent Green Belt land"; or

"Release of land results in a loss of relatively limited contribution to one of the Green Belt purposes, and would constitute a moderate impact on adjacent Green Belt land”.

The assessment does not therefore rule out the release of this land from the Green Belt. In particular, it is highly relevant that the site performs much better in the assessment that most plots, with the harm rating for the vast majority of the Green belt land assessed as being ‘high’ or ‘very high’. The site is one of a very small number of plots that attained a ‘low’ to ‘moderate high’ harm rating in the recent assessment.

Moreover, it is relevant that as part of a development on this land, the vision is to retain the majority of the golf course site as ‘open land’. It is envisaged that the north-west section of the golf course (to the north of Crafts Way and The Fairway) could be developed to provide a new neighbourhood within Bar Hill, which would function as a sustainable urban extension to the settlement. Meanwhile, the retained area of land would have the potential to act as a strategic reserve for future housing allocations or might be converted to form a new country park / area of public open space / allotments / recreation or sporting use, with possible focus on planting and habitat creation which would deliver substantial biodiversity net gain over the existing use of the land as a manicured golf course. Certainly, any development on this land, has the potential benefit of opening up the southern / eastern areas of the land for public access, delivering significant new areas of public open space for the Bar Hill / north Cambridge communities on either a temporary or permanent basis.

The proposed residential element of the scheme would include a mix of housing styles, sizes and types, and could include apartments as well as detached and semi-detached dwellings, to cater for the full range of local housing needs. There would also be scope to provide some self / custom-build plots, and the scheme would of course include affordable housing provision. There is scope to provide some form of community building / local shop, to service the local community’s needs, and – subject to further market testing – additional complementary uses could be added. There is scope to provide these uses along the main spine through the development, or around a new village square.

Conclusion

In summary, whilst our client supports the vision of the Local Plan First Proposals document, it is our view that the Development Strategy requires further amendments in order to deliver the housing growth planned.

The Local Plan, as currently drafted, places an over-reliance on a limited number of strategic sites, and it is our view that it would be preferential to include a broader range of small and medium-sized sites, which are less constrained; that are available now; and that can ensure a supply of deliverable housing land in the short-term. Moreover, this strategy would also ensure that there is more choice and flexibility in the plan, so that if a problem arises with one of the larger strategic sites, housing delivery can continue on alternative sites.

To this end, we would encourage the Greater Cambridge Shared Planning Unit to seriously consider our client’s site at Bar Hill golf course, which can provide a sustainable urban extension to an existing settlement in a sustainable location, and which can deliver around 300 homes, in addition to community facilities and new publicly-accessible green infrastructure. We consider that this site would complement the draft Development Strategy, and provide a medium-scale site which is deliverable within the Local Plan period.

N Wilbraham Rd, Six Mile Bottom (new site 59380)

New site submitted through call for sites proforma.

0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).

0.2 This response concerns a site of 1.86 hectares, identified as Land South of Cambridge Road, Milton, whose red-line boundary is provided in Appendix A (“the Site”). The Site lies to the north of the A14 and adjoins the village of Milton. The Site has recently been used by Balfour Beatty as an offices and storage compound for the A14 Improvement Works since 2018, and photos of the Site (from Google Streetview), are provided in Appendix B. Balfour Beatty has now completed the relevant works on the A14 and has vacated the Site.

0.3 In terms of the broader context, U+I have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document).

0.4 In order to deliver the comprehensive redevelopment envisaged in the NEC AAP, a number of existing industrial /non-conforming uses (to residential) will need to either be re-accommodated within a mixed use, higher density, development superblock within NEC AAP or, more likely, be relocated from areas such as Cowley Road Industrial Estate to another location close to the north-eastern edge of Cambridge.

0.5 A Commercial Advice and Relocation Strategy has been commissioned by GCSP to consider this matter in greater detail, and its findings are expected imminently. It is unfortunate that this has not been made available to comment upon during this consultation process.

0.6 Notwithstanding this, it is considered that the Site has significant potential to accommodate the existing, important, businesses in the NEC AAP that will be displaced as a consequence of the major residential-led mixed use development that will be brought forward, following the decommissioning and relocation of the Waste Water Treatment Works.

0.7 Pre-Application Advice was sought from GCSP in respect of a series of development scenarios for the Site, as provided in Appendix C. The purpose of this was to explain the flexibility of the Site, and the attitude towards development of U+I to support those businesses that play a vital role in the wider economy and have a demonstrable need to be on the North-Eastern edge of Cambridge on a site that has excellent connectivity to the strategic highways network and pedestrian/cycle connectivity into Cambridge via the Jane Costen bridge.

0.8 A series of preliminary technical documents were also provided to support the pre-application request and can also be found in Appendix C.

0.9 The Site is currently located within the Green Belt, and this representation requests that it is released and allocated to accommodate commercial/employment uses for those business displaced from the NEC AAP

1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing OBJECT

1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.

1.3 It is essential that any increase to housing is supported by a commensurate increase in the level of jobs (and vice versa), in order to maintain to maintain an appropriate balance of locating homes close to opportunities to work, within or on the edge of Cambridge, where it is accessible to public transport and/or good pedestrian / cycle / micro-mobility connections. 1.4 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.

1.5 It is essential that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

Policy S/DS: Development Strategy OBJECT

1.6 Whilst we broadly, partially, support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land (noting that it has already been identified for homes and jobs growth) we object on the basis that it does not identify the Site as a suitable ‘receptor’ site for displaced commercial uses from NEC AAP.

1.7 Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release the Site, which is related to the specific need to provide land for existing businesses that will displaced by the NEC AAP.

1.8 Paragraph 141 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identified previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

1.9 Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport.

1.10 The Site is ideally located to NEC AAP, being on the fringe of it, well connected to the strategic highway network and will be extremely well connected to NEC AAP via existing pedestrian and cycle routes across the Jane Costen bridge, that will lead directly into St John’s Innovation Park and the wider NEC area beyond it. Therefore, the release of the Site from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that will support active travel.

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

1.11 The successful delivery of the redevelopment of NEC is a key part of the development strategy for emerging GCLP. However, the redevelopment of NEC 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 identified in emerging GCLP for relocated businesses from NEC, whether temporary or permanent.

1.12 It is requested that the Site should be allocated in emerging GCLP as a suitable relocation site for some businesses that will be displaced from the NEC AAP. This outcome would represent the exceptional circumstances to justify the release of land from the Green Belt.

1.13 It is considered that, taking into account the current Green Belt status of the Site, land could be suitable for a range of potential industrial uses (or other uses that would be deemed ‘non-conforming’ to the residential uses within the NEC AAP). The Site is ideal for this type of end-use – there are no existing residential receptors within close proximity (the nearest residential property in Milton is 125m away, but this would separated by the intervening existing Industrial Park and Tesco), and the nearest new residential receptor in NEC AAP will be over 100m away and separated by the A14 (and therefore any residential edge of NEC AAP will be protected by new acoustic barriers on the southern edge of the A14).

Policy S/NEC: North-East Cambridge SUPPORT

1.14 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process. 1.15 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC. 1.16 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP. Policy BG/BG: Biodiversity and Geodiversity OBJECT 1.17 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).

1.18 The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so: • Post-development biodiversity value of the onsite habitat; • the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development; • the biodiversity value of any biodiversity credits purchased for the development;

1.19 Whilst U+I recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).

1.20 GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.

1.21 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments
SUPPORT


1.22 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy J/NE: New Employment Development Proposals
SUPPORT

1.23 We broadly support the intent of the policy but consider that GCSP should be taking a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area.

1.24 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries
SUPPORT

HELAA Site Assessment – Land South of Milton, North of the A14 (Site Ref. 47943)

1.25 U&I’s comments and suggested amendments to the site assessment are as follows: – Proposed Development – refers to Residential, Market and affordable housing, Specialist/other forms of housing, Office, Research and Development. We would request this be amended to B2/B8/sui generis uses applicable to other uses currently in NEC AAP i.e. those that might be considered non-conforming to residential; – Flood Risk – it is considered that this should be categorised as ‘green’.
The Site lies within Flood Zone 1, and any planning application would need to be accompanied by a site-specific Flood Risk Assessment, demonstrating how any localised flood risk arising from the proposed development could be adequately mitigated. Furthermore, the proposed use would be considered less vulnerable in flood risk terms.

– Landscape and Townscape: the Site lies between the existing urban edge of Milton (with Tesco to the north, the industrial park to the east, and separated from NEC AAP by the A14. The northern edge of NEC AAP (opposite the Site) has been considered acceptable (in Landscape / Townscape assessment) for new development of 3-6 storeys. It therefore seems perverse that the Site can be assessed as ‘Red’ in Landscape and Townscape terms and would request this be
changed to Green. The intended uses for the Site would be industrial / storage / sui generis uses, that are likely to be typically 1-2 storeys in height. The Site also benefits from landscaping on its boundaries, to help soften the impact of any new development.

– Site Access – we would request that this is changed to ‘Green’, given that the assessment notes that the proposed site is acceptable in principle subject to detailed design. There are potential access constraints, but these could be overcome through development.

- Noise, Vibration, Odour and Light Pollution – we would request that this is changed to ‘Green’, given that the assessment notes that ‘the proposed site will be affected by road traffic noise from nearby main roads but is acceptable in principle subject to appropriate detailed design considerations and mitigation. The proposed site will be affected by noise from nearby industrial/commercial activities but is acceptable in principle subject to appropriate detailed design considerations and mitigation. The site is capable of being developed to provide healthy internal and external environments in regard to noise / vibration/ odour/ Light Pollution after careful site layout, design and mitigation. Furthermore, the proposed use for industrial / storage / sui generis would be less sensitive (than for a residential use, for instance).

– Strategic Highways Impact: The good accessibility of the Site by sustainable modes of transport and future improvements to public transport, walking and cycling, would provide employees with an alternative to the car for journeys to work and reduce traffic impacts from the promoted development. If the Site is to be used as a ‘receptor’ site for existing industrial uses in NEC AAP, such uses will already be making a contribution to the strategic network (in terms of existing trips) and therefore the proposed use of this Site will have a negligible impact.

– Green Belt: The Site is currently located within the Green Belt. The Site has been assessed as having ‘moderate high’ Green Belt value. In comparative terms, this performs well in the context of other Green Belt sites in the north of Cambridge. Notwithstanding this, in terms of the five spatial ‘Purposes’ of Green Belt, namely: (a) to check the unrestricted sprawl of large built-up areas; (b) to prevent neighbouring towns merging into one another; (c) to assist in safeguarding the countryside from encroachment; (d) to preserve the setting and special character of historic towns; and (e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

1.26 It is considered that only (b) and (e) would potentially be relevant here. In terms of (b) the Site lies in between the urban edge of Milton, and the northern edge of Cambridge. Theoretical coalescence between Milton and Cambridge has already, in effect, taken place by the presence of the industrial park, and its relationship to the north of Cambridge. However, this is physically separated by the permanent presence of the A14. The same would be true if the Site is developed. In terms of (e), it is considered applicable, albeit in the opposite manner of how (e) is intended. The release of land from the Green Belt here will assist in urban regeneration, by providing a receptor site that aids relocation of existing sites and facilitates NEC’s delivery.

1.27 It is considered that the Site provides lower value in Green Belt terms than has been assessed and its release would provide significant benefits insofar as providing a receptor site for important commercial/employment uses that would be displaced by the wider regeneration taking place at NEC.

Land south of Haden Way, Willingham (new site 59431)

New site submitted through call for sites proforma.