Sustainability Appraisal

Gamlingay Neighbourhood Plan Strategic Environmental Assessment evidence supports the principle that SCDC must lower the reliance on the private car- as there are significantly higher carbon dioxide emissions in SCDC area (2016) than the rest of East of England and England in general ( S Cambs 4, East of England 2.3 , England 1.9).

There is a plan to take greenbelt behind mingle Lane Stapleford and replace with 100 houses.Greenbelt requires exceptional circumstances to be given over to building land,In the area we require 100 new houses in a timespan of 20 years, thats 5 houses per year. How can green belt be taken when this is clearly NOT exceptional circumstances.
How can anybody consider removing greenbelt when all other opportunities have not been researched, This is not exceptional and needs revisiting.

The MWPA welcomes the inclusion of minerals as an objective, albeit noting the negative and uncertain result for most options considered. The MWPA would encourage the consideration of “Sustainable resource use” or “Waste minimisation” when considering objectives for future local plans.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Hastingwood Developments that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Hastingwood Developments’ representations to the Sustainability Appraisal are: SA1 Housing; and, SA2 Access to Services and Facilities; and SA8 Efficient Use of Land.

Hastingwood Developments’ representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Hastingwood Developments representations to Policy S/DS, there are no housing allocations made in most villages, including Meldreth, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 36 affordable dwellings in Meldreth will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Hastingwood Developments has requested that land at Bury Farm End in Meldreth is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Hastingwood Developments’ representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Meldreth is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 36 affordable dwellings in Meldreth. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Meldreth, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). A ‘mixed significant negative and minor positive effect’ score is also identified for efficient use of land objective (SA8). As set out above there is an identified need for 36 affordable dwellings in Meldreth, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Meldreth, will not be met by the development strategy or the strategy for rural areas. Meldreth contains a good range of services and facilities, including a primary school and special education needs school, convenience store, public house, railway station and bus services. The accessibility to services and facilities is good for Meldreth, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities. The land promoted by Hastingwood Developments at Bury Farm End in Meldreth is part previously developed land and occupied by existing agricultural buildings for a turkey factory. The redevelopment of this site for residential development would result in efficient use of land, but the decision to not allocate this site in emerging GCLP has ignored the opportunity to provide a positive outcome for this sustainability objective.

It is requested that land at Bury End Farm in Meldreth is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by CEMEX that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to the CEMEX representations are: SA1 Housing; and SA2 Access to Services and Facilities.

The CEMEX representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the CEMEX representations to Policy S/DS, there are no housing allocations made in most villages, including Orwell, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 12 affordable dwellings in Orwell will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. CEMEX has requested that land west of Malton Road in Orwell is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in the CEMEX representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Orwell is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 12 affordable dwellings in Orwell. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Orwell, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 12 affordable dwellings in Orwell, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Orwell, will not be met by the development strategy or the strategy for rural areas. Orwell contains a primary school, village store including a post office, a public house, a hairdresser, a village hall, church hall, recreation facilities, a mobile library service, businesses, and a bus service which is due to be improved. The accessibility to services and facilities is good for Orwell, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land west of Malton Road in Orwell is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Mr Meadows that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Mr Meadows representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

Mr Meadows representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Mr Meadows representations to Policy S/DS for off Cottenham Road in Histon, there are no new housing allocations made in most villages, and in Histon an existing allocation for 25 dwellings is carried forward, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 58 affordable dwellings in Histon will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Mr Meadows has requested that land r/o 113 Cottenham Road in Histon is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Mr Meadows representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Histon is an example where there are no opportunities within the boundary to accommodate major developments, other than those already allocated, that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 58 affordable dwellings in Histon. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Histon, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 58 affordable dwellings in Histon, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Histon, will not be met by the development strategy or the strategy for rural areas. Histon is defined as a Rural Centre in the settlement hierarchy. It contains supermarkets and other small convenience stores and shops, a post office, doctor’s surgery and pharmacy, dentist, library, public houses and restaurants, banks, primary and secondary schools, and village halls, and a business park and other small businesses. Histon is connected to the Cambridgeshire Guided Busway, there are frequent bus services, and there are existing on and off-road cycle routes within the village. The accessibility to services and facilities is very good for Histon, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land r/o 113 Cottenham Road in Histon is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Shelford Investments that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Shelford Investments representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

Shelford Investments representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Shelford Investments representations to Policy S/DS, there are no housing allocations made in most villages, including Great Shelford, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 47 affordable dwellings in Great Shelford will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Shelford Investments has requested that land off Cabbage Moor in Great Shelford is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Shelford Investments representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Great Shelford is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings, and the Green Belt restricts development outside the settlement boundary. As set out above there is an identified need for 47 affordable dwellings in Great Shelford. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Great Shelford, will not be met by the currently defined settlement boundaries.

• Table 5.20: Policy S/RSC: Village Allocations in the Rural Southern Cluster: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect / uncertain’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 47 affordable dwellings in Great Shelford, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Great Shelford, will not be met by the development strategy or the strategy for rural southern cluster. Great Shelford contains a good range of services and facilities, including a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants. There are additional services and facilities located in Trumpington. Great Shelford Station, the proposed Cambridge South Station, Trumpington Park & Ride, Cambridgeshire Guided Busway, the proposed Cambridge South East project, and existing bus services along Shelford Road are all available within or close to Great Shelford. The accessibility to services and facilities is excellent for Great Shelford and for land off Cabbage Moor, but this is not reflected in the assessment for this sustainability related objective, and additional development in this location would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land off Cabbage Moor in Great Shelford is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by RO Group that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The housing related sustainability objective SA1: Housing is relevant to the RO Group representations. The representations and requested amendments to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the RO Group representations to Policy S/DS, there are no housing allocations made in most villages, including Great Chishill, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 9 affordable dwellings in Great Chishill and Little Chishill will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. RO Group has requested that land south of Hall Lane in Great Chishill is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in the CEMEX representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Great Chishill is an example where small infill development of up to 2 dwellings does not provide affordable housing and there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 9 affordable dwellings in Great Chishill and Little Chishill. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Great Chishill, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1 As set out above there is an identified need for 9 affordable dwellings in Great Chishill, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Great Chishill, will not be met by the development strategy or the strategy for rural areas.

It is requested that land south of Hall Lane in Great Chishill is allocated in emerging GCLP for housing and affordable housing, in order to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Mr Francis that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Mr Francis’ representations to the Sustainability Appraisal are: SA1 Housing; and SA2 Access to Services and Facilities.

Mr Francis’ representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Mr Francis’ representations to Policy S/DS, there are no housing allocations made in most villages, including fen Ditton, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 12 affordable dwellings in Fen Ditton will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Mr Francis has requested that land off Ditton Lane in Fen Ditton is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Mr Francis’ representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Fen Ditton is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 12 affordable dwellings in Fen Ditton. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fen Ditton, will not be met by the currently defined settlement boundaries.

It is requested that land off Ditton Lane in Fen Ditton is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Cambridge District Oddfellows that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to the Cambridge District Oddfellows representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

The Cambridge District Oddfellows representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.5: Policy S/SH: Settlement Hierarchy. It is claimed that the preferred option for the settlement hierarchy would deliver sustainable patterns of development. A ‘significant positive effect’ score is identified for the housing sustainability objective (SA1) and the access to services and facilities sustainability objective (SA2). As set out in the Cambridge District Oddfellows representations to Policy S/DS: Development Strategy and Section 2.6: Rest of Rural Area, there are no housing allocations made in most villages, including Cottenham, and as such there cannot be significant positive effect for those villages in the settlement hierarchy where no additional housing or affordable housing is planned during the plan period to 2041. It is not clear how the decision to reclassify Cottenham as a Minor Rural Centre has been taken into account in the assessment for Policy S/SH because it is not mentioned. Cottenham has a good range of services and facilities including a supermarket and convenience stores, post office, doctors surgeries, dentist, library, public houses, restaurant/takeaway, bank, primary school and secondary school, village hall and meeting spaces. There is a currently a good bus service from Cottenham, which is due to be improved with more frequent services and better connections as part of Greater Cambridge Partnership’s Making Connections project. Therefore, Cottenham as a Rural Centre and as location for additional development would have positive effects for the accessibility to services sustainability objective, but the decision to reclassify the village as a Minor Rural Centre and not make any allocations cannot have the same positive effect. The decision to reclassify Cottenham as a Minor Rural Centre is not supported by any evidence and has not been informed by any assessment against sustainability objectives.
• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out in the Cambridge District Oddfellows representations to Policy S/RRA, it is acknowledged that most of the current need for affordable housing would be met by recent planning permissions, but there will be future affordable housing needs that arise in the future and sustainable villages such as Cottenham should seek to meet district-wide affordable housing needs too. It appears that the Cottenham Community Land Trust is having difficulty bringing forward a scheme because no site is available or identified. It must be a negative outcome for the housing related sustainability objective if future affordable housing needs of the district and villages, including Cottenham, will not be met by the development strategy or the strategy for rural areas. As set out above, Cottenham contains a good range of services and facilities and bus services that due to be improved, reflecting its current status as a Rural Centre. The accessibility to services and facilities is good for Cottenham, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land at Two Mill Field and land north of Oakington Road in Cottenham are allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by KG Moss Will Trust/Moss Family that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to KG Moss Will Trust/Moss Family representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

KG Moss Will Trust/Moss Family representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in KG Moss Will Trust/Moss Family’s representations to Policy S/DS for land off Home End and land at Court Meadows House off Balsham Road in Fulbourn, there are no new housing allocations made in most villages, and the existing and recent major developments in Fulbourn would only partially meet identified affordable housing needs but unmet needs would remain. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 65 affordable dwellings in Fulbourn will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. KG Moss Will Trust/Moss Family has requested that land off Home End and land at Court Meadows House off Balsham Road (as amended) in Fulbourn are allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in KG Moss Will Trust/Moss Family’s representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Fulbourn is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 65 affordable dwellings in Fulbourn. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fulbourn, will only be partially met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 68 affordable dwellings in Fulbourn, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fulbourn, will not be met by the development strategy or the strategy for rural areas. Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. It contains a good range of services and facilities, including a primary school, doctor’s surgery, pharmacy, library, post office, supermarket and other small convenience stores, village hall, and outdoor recreation and play facilities. There are regular bus services to Cambridge, Haverhill, and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The walking and cycling routes and bus services in Fulbourn are due to be improved in the future by Greater Cambridge Partnership projects. The accessibility to services and facilities is very good for Fulbourn, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested by KG Moss Will Trust/Moss Family that land off Home End and land at Court Meadows House off Balsham Road in Fulbourn are allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

The site was assessed in the SA against a series of sustainability objectives and compared against other reasonable alternative site options – see Table 4.21 in SA. In summary, the site scores well against sustainability objectives and when compared against alternative site options. There are three sustainability objectives where negative effects are identified, which are as follows: access to services and facilities; efficient use of land; and mineral resources. In summary, the access to services score appears incorrect when Great Shelford and Stapleford are classified as Rural Centres and contain a good range of services and facilities. The efficient use of land score is partly derived from the quantum of development included in the preferred allocation. The mineral resources issue will need to be assessed, but it is unlikely that the site would be suitable for mineral extraction because of the close proximity of residential areas.

Mrs Johnson’s comments on the findings of the SA for Site Ref: OS216 / Policy S/RSC/HW are as follows:

• SA Objective 1: Housing – A minor positive effect is identified. There is an identified need for affordable housing in Stapleford and Great Shelford for those with a local connection to the villages. The promoted development would deliver housing and affordable housing.
• SA Objective 2: Access to Services and Facilities – A significant negative effect/minor negative effect is identified. Stapleford and Great Shelford are classified as a Rural Centre in the settlement hierarchy. They contain a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses, and restaurants. Shelford Station is located close to the site. There are bus routes on Hinton Way, Mingle Lane, Station Road and Cambridge Road, all of which are close to the site. There are cycle routes through Stapleford and Great Shelford into Cambridge. It is requested that the score is changed to ‘significant positive effect likely’
• SA Objective 3: Social Inclusion and Equalities – A negligible effect is identified. No comments.
• SA Objective 4: Health – A Minor positive effect/negligible effect is identified. No comments.
• SA Objective 5: Biodiversity and Geodiversity – A minor negative effect is identified. An ecological assessment would need to be undertaken. The existing trees and hedgerows at the site boundary would be retained. The promoted development would retain any ecological interest on the site and deliver ecological enhancements and green infrastructure.
• SA Objective 6: Landscape and Townscape. A negligible effect is identified. A landscape and visual impact assessment would need to be undertaken. The promoted development would include strategic landscaping on the northern and eastern boundaries and the setting back of dwellings from the village edge to address landscape and visual impacts. The route for the Cambridge South East Transport project, located to the north east of the site, should be taken into account in the assessment. The promoted development would also include other landscaping, green infrastructure and open space that would assist with landscape and visual impacts.
• SA Objective 7: Historic Environment: A minor negative effect is identified. The access to the site is within Stapleford Conservation Area. The Church of St Andrew (Grade II*) is located to the south east of the site. An assessment of the impact of development at the site on these heritage assets will need to be undertaken. It would be possible to avoid harm to the setting of these heritage assets by careful design and layout and providing open space on the eastern boundary of the site. An archaeological assessment will need to be undertaken to determine whether any archaeological assets exist on site, and what if any mitigation measures are required to protect those assets.
• SA Objective 8: Efficient Use of Land – A significant negative effect is identified. The quantum of development is limited by the availability of a single point of access to the site. The promoted development will need to include strategic landscaping, open space, and other green infrastructure, and it is likely that once these factors have been incorporated into the design and layout that land available for built development would be brought forward at suitable densities appropriate to the village.
• SA Objective 9: Minerals: A significant negative effect likely identified. An assessment of the mineral resource at the site will need to be undertaken to determine whether mineral extraction is a realistic and viable option. It is unlikely that the site would be suitable for mineral extraction because of the close proximity of residential areas, and the need for substantial buffers to be provided at mineral extraction sites to protect residential amenity.
• SA Objective 10: Water – A negligible effect identified. The promoted development would need to meet water conservation standards.
• SA Objective 11: Adaptation to Climate Change – A minor negative effect identified. The promoted development would need to meet climate change adaptation requirements.
• SA Objective 12: Climate Change Mitigation – A significant positive effect/minor positive effect identified. The promoted development would need to incorporate climate change mitigation measures.
• SA Objective 13: Air Quality – A minor negative effect is identified. The promoted development is accessible by sustainable modes of transport, and there are realistic alternatives to the car for most journeys from the site to reduce potential increases in traffic and associated impacts on air quality. The phasing out of petrol and diesel vehicles and the requirement for new residential developments to include electric vehicle charging points should help to improve air quality.
• SA Objective 14: Economy – A negligible effect is identified. No comments.
• SA Objective 15: Employment – A minor positive effect is identified. No comments

It is requested that the above comments are taken into account when the SA is updated.

These representations are submitted by Pegasus Group on behalf of Clarendon Land and Development Ltd who has land interests in land west of Long Lane, Fowlmere (LPA ref: 40327). We have previously submitted responses to the Call for Sites exercise (March 2019) and Regulation 18 Consultation (February 2020). These representations should be read in conjunction with these previous comments.

The Sustainability Appraisal (SA) for the Local Plan First Proposals (Oct 2021) is flawed as it is based on the preconceived judgement that development in villages is unsustainable due to car dependency. It is acknowledged in the SA that affordability is a key issue in Greater Cambridge (Chapter 3) but this does not form a key measure to rate sustainability.

The SA is an unwieldy document and difficult to understand the methodology and processes used. It is a 473-page document with numerous tables and colour coding and symbols which are not easily referenced.

Spatial Option 5 refers to the total development need of Greater Cambridge being dispersed to villages which results in:
• 40% located in rural centres
• 40% located to minor rural centres
• 17% located in group villages
• 3% located in infill villages.

This option was deemed unsustainable in the SA. It is clear that this level of growth solely directed at rural areas would cause sustainability issues and impact the area. However, this option should not be discounted on this skewed assessment alone. A sensible approach would be a blend of all options which results in some growth in villages not the entire growth for the whole District. It is unclear if the SA has assessed this blend of options or if it has discounted growth in villages based on this assessment.

The SA concludes that development may help to support viability of existing services and facilities at these villages and will improve access to these services. This point is reiterated in the Framework and it is important to ensure that these services and facilities have an adequate customer base to safeguard their survival. If modest development is not allowed in these communities, these services will fail and disappear during the plan period. The SA supports growth in more rural locations which is likely to help support services and facilities and may even help provide new facilities or build a business case for improved public transport. This would help to achieve the social, inclusion and equality objective of the SA. However, this objective is not carried through to the proposed Development Strategy within the Local Plan and no explanation is provided as to how the services and facilities in these communities are likely to survive with no housing or economic growth.

In its assessment of villages, the SA is unclear as to why all sites put forward as part of the Call for Sites exercise are not listed and assessed (Table 4.23). The ranking used and assessment of points is unclear and very confusing. There is no weighting of factors. It is considered that the impact on housing delivery in these areas, the impact on affordability and the benefit to the vitality of these communities are considerable and should be assessed as such. It is considered that these factors are not given enough significance in the planning balance.

The SA is a lengthy and unwieldy document but is concluded in paragraph 6.2 very simply by stating that "the proposed direction of the Local Plan performs well in sustainable terms." This brief conclusion of a document which runs to 473 pages is not considered adequate to summarise such a complex document and subject and has not provided a full analysis of all the differing factors which relate to a complicated spatial strategy with a multitude of development options.

The inclusion of North East Cambridge area Action Plan (NECAAP) in the Local Plan and the recent announcement of its Regulation 19 Proposed Submission appears premature (S. Kelly report to JLPAG). The AAP is predicated on the proposed relocation of Cambridge Waste Water Treatment Plant (CWWTPR), for which the Development Consent Order (DCO) process is still in the pre-application stage. Given that the CWWTP DCO application is unlikely to be submitted until late 2022 or early 2023, the proposed Regulation 19 submission of the Area Action Plan and its inclusion here in the Local Plan is premature. Resources are being used inappropriately and prematurely when the consultation on CWWTPR is not scheduled until February 2022 and the councils are deferring any formal public consultation on NECAAP until after the DCO.

The single driver behind Anglian Water (AW) pursuing a relocation of the CWWTP is the request from the joint Councils for AW to test a viable alternative site to fulfil the Councils’ vision for North East Cambridge as represented  in the area action plan NECAAP, adopted by Council into the emerging Greater Cambridge Local Plan First Proposals Policy S/NEC . Both plans have been developed with the assumption CWWTP will relocate, but neither are dependent on it (S Kelly Nov 2021).  Despite this, neither the SA nor SEA in either plan identify or assess the significant effects the relocation will have on the site identified by AW as a ‘viable’ alternative within the Greater Cambridge area.  

The existing CWWTP underwent extensive investment in 2016, at the time it was described by the Environment Journal (2016) as being  future proofed for decades to come and to have secured its position as the eastern region’s green energy generating giant; it has capacity to absorb the  housing targets of both the existing and emerging Local Plan including Waterbeach Newtown.  This fact, that there is no operational need for CWWTP to relocate even with the ambitious housing targets of these Local Plans, has meant AW are dependent on external funding,  in this case £227m of public money via HIFF.  Joint Councils supported the HIFF application and thus the principle of relocation of the CWWTP to enable the fulfilment of the vision for NECAAP, however this was before AW undertook identifying and concluded on a ‘viable’ site selection.

The site identified by AW is an area subject to the emerging Local Plan in the Cambridge Green Belt;  identified in the supporting Green Belt Study (2021) as an area of high sensitivity where development would have ‘very high harm’ to Green Belt purpose.  This ‘very high harm’ is attributed to the area not least because of the openness of the Green Belt but also the contribution three adjacent Conservation Areas, historical assets and medieval villages within them make to the Historical Setting of Cambridge. Significant Green Infrastructure also identified in the emerging Local Plan will be impacted by the relocation including: the River Cam Corridor; SSSI sites;  registered Historical House and Gardens; extensive PRoW network ; National Trust Wicken Fen Vision.

Since the site selection for relocation by AW there has been no public consultation on the consequences or environmental effects of the Councils pursuing NECAAP /S/NEC  in the context of the relocation to Honey Hill, nor has any alternative vision for NECAAP been presented in the emerging Local Plan First Proposals. This is despite it being clear the relocation as proposed will be contrary to numerous Policies laid out in the emerging Local Plan First Proposals and in the case of densification the CPIER report (2018), which informs the high growth objectives of the emerging Local Plan, stating that to sustain high economic growth, development needs to be sensitive to maintaining one of the key attractions to Cambridge, that is the pleasant environment. The latter not only being the Historic City Centre but its setting including the historic Green Belt (the first nationally to be established) and the necklace of villages within it.

The assessment of the effects of NECAAP/S/NEC Policy have been deferred to AW and the DCO planning process with the assertion that as the relocation is a separate planning process   ‘it is therefore not a project or proposal within the scope of the emerging Greater Cambridge Local Plan or AAP to influence.’  (S Kelly Nov 2021). This position seems quite extraordinary ; including NECAAP/S/NEC in the Local Plan First Proposals but excluding sufficient or significant information about the effects of the fulfilment of the Policy for effective public consultation at Reg 18 in itself is contrary to the principals and regulations of the SA/SEA, will influence the Consultation and could be construed as effecting bias. This anomaly is further exacerbated given that neither the emerging Local Plan nor NECAAP are dependent on the relocation (S Kelly Nov 2021).

If it is regulatory to exclude reference / identification of the site selected for relocation or subjecting the full effect of NECAAP to the SA/SEA within the emerging Local Plan, it is recommended in the interest of an informed and fair public consultation NECAAP is excluded from the Local Plan until after the outcome of the DCO is known and that an alternative is presented in the emerging Local Plan that can be subject to SA/SEA and an informed, evidence based public consultation at Reg 18.


Refs:
S Kelly Nov 2021 : NECAAP : Proposed Submission (Reg 19) Report to Joint Local Planning Advisory Group
Environmental Journal July 2026 : https://environmentjournal.online/articles/cambridges-water-recycling-centre-looks-future/

These documents are very sound. The problem is that many of the above policies don’t fully meet these documents statements.

The single driver behind Anglian Water (AW) pursuing a relocation of the CWWTP is the request from the joint Councils for AW to test a viable alternative site to fulfil the Councils’ vision for North East Cambridge as represented in the area action plan NECAAP, adopted by Council into the emerging Greater Cambridge Local Plan First Proposals Policy S/NEC. Both plans have been developed with the assumption CWWTP will relocate, but neither are dependent on it (S Kelly Nov 2021). Despite this, neither the SA nor SEA in either plan identify or assess the significant effects the relocation will have on the site identified by AW as a ‘viable’ alternative within the Greater Cambridge area.
The existing CWWTP underwent extensive investment in 2016, at the time it was described by the Environment Journal (2016) as being future proofed for decades to come and to have secured its position as the eastern region’s green energy generating giant; it has capacity to absorb the housing targets of both the existing and emerging Local Plan including Waterbeach Newtown. This fact, that there is no operational need for CWWTP to relocate even with the ambitious housing targets of these Local Plans, has meant AW are dependent on external funding, in this case £227m of public money via HIFF. Joint Councils supported the HIFF application and thus the principle of relocation of the CWWTP to enable the fulfilment of the vision for NECAAP, however this was before AW undertook identifying and concluded on a ‘viable’ site selection.
The site identified by AW is an area subject to the emerging Local Plan in the Cambridge Green Belt; identified in the supporting Green Belt Study (2021) as an area of high sensitivity where development would have ‘very high harm’ to Green Belt purpose. This ‘very high harm’ is attributed to the area not least because of the openness of the Green Belt but also the contribution three adjacent Conservation Areas, historical assets, and medieval villages within them make to the Historical Setting of Cambridge. Significant Green Infrastructure also identified in the emerging Local Plan will be impacted by the relocation including: the River Cam Corridor; SSSI sites; registered Historical House and Gardens; extensive PRoW network; National Trust Wicken Fen Vision.
Since the site selection for relocation by AW there has been no public consultation on the consequences or environmental effects of the Councils pursuing NECAAP /S/NEC in the context of the relocation to Honey Hill, nor has any alternative vision for NECAAP been presented in the emerging Local Plan First Proposals.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Dudley Developments that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils.

Dudley Development’s representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Dudley Developments representations to Policy S/DS, there is the over reliance on the existing new settlements and planned new neighbourhoods to meet the housing requirements. The key parts of the development strategy for emerging GCLP is the delivery of extensions to Cambourne, the planned new settlements at Northstowe, Waterbeach and Bourn Airfield, and the new communities on the edge of Cambridge at North East Cambridge and Cambridge East. These are all complex developments that also require the delivery of transport and community infrastructure. The predicted housing delivery rates at these developments are challenging. Most of these developments will provide less affordable housing than required by policy, at least in the initial phases, to reflect the amount of infrastructure that is needed. The proposed redevelopments at North East Cambridge and Cambridge East are complex and involves the relocation of the existing uses. The Sustainability Appraisal and the assessment of the development strategy simply assume that delivery of these developments will be as predicted without any delays and that the delivery of less affordable housing is acceptable. An alternative approach to address these housing related matters should have been recommended in the Sustainability Appraisal to improve sustainability outcomes e.g. additional small allocations in sustainable locations that deliver affordable housing such as on the edge of Cambridge. Small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge, including at Cherry Hinton on land within the Green Belt, because such sites can also deliver affordable housing to meet identified needs.

The promoted development by Dudley Developments at land off Limekiln Road in Cambridge was assessed in the SA against a series of sustainability objectives and compared against other edge of Cambridge Green Belt site options – see Table 4.19 in SA (Site Ref. 40528 Land North of Cherry Hinton Caravan Club, Limekiln Road, Cambridge). The assessment of the site has not fully taken into account what is proposed in the promoted development or the submitted Vision Document and technical reports prepared for the site.

Dudley Development’s comments on the findings of the SA for the site are as follows:

• SA Objective 1: Housing – A minor positive effect is identified. The promoted development for 14 dwellings, would be required to include a proportion of affordable housing, making a contribution towards the identified affordable housing needs of Cambridge.
• SA Objective 2: Access to Services and Facilities – A significant positive effect likely/minor positive effect is identified. The promoted development at land off Limekiln Road in Cambridge is accessible by sustainable modes of transport. Queen Edith's Way and Cherry Hinton Road are on bus routes. The Greater Cambridge Partnership’s Making Connections project identifies Cherry Hinton as a key location on a bus corridor, with improved bus links to Addenbrooke’s and Cambridge Station. There is a dedicated cycle path on Cherry Hinton Road. The Greater Cambridge Partnership’s proposed Fulbourn Greenway project, which includes new dedicated walking and cycling routes and improvements, passes through Cherry Hinton. It is requested that the assessment score for access to services and facilities is changed to ‘significant positive effect likely’ only.
• SA Objective 3: Social Inclusion and Equalities – A negligible effect is identified. No comments.
• SA Objective 4: Health – A minor positive effect/negligible effect is identified. Cherry Hinton contains doctor’s surgeries, leisure centres for residents to improve their health and fitness, and walking and cycling facilities for active travel.
• SA Objective 5: Biodiversity and Geodiversity – A significant negative effect likely is identified. A Preliminary Ecological Appraisal is submitted with the representations to the HELAA site assessment (Site Ref. 40528).The promoted development includes open space. There are parks and open spaces in the local area. The site is close to Cherry Hinton Chalk Pits SSSI. It is noted that Policy BG/BG: Biodiversity and Geodiversity of emerging GCLP is likely to include a requirement for developments to provide mitigation measures to address recreational impacts on nature conservation sites. The promoted development would provide mitigation measures. The promoted development would provide on-site ecological mitigation measures including enhancement of existing trees, planting of species rich calcareous grassland, and providing bird and bat boxes and hedgehog domes. The promoted development would need to make off-site contributions to address recreational pressure on nature conservation sites, in accordance with emerging Policy BG/BG.
• SA Objective 6: Landscape and Townscape. A minor negative effect likely is identified. The site is not visible from the surrounding area. The promoted development would retain the tree within the site and the hedgerows and vegetation at the site boundary. Additional trees and landscaping would be provided within the site to enhance landscape character. It is requested that the landscape and townscape score is changed to ‘negligible effects’.
• SA Objective 7: Historic Environment: A minor negative effect is identified. The promoted development does not affect any heritage assets. It is noted that the site assessment in the HELAA scored the site ‘green’ for historic environment matters. It is requested that the heritage score is changed to ‘negligible effects’.
• SA Objective 8: Efficient Use of Land – A minor negative effect is identified. It is acknowledged that the site is currently greenfield. The density of the promoted development is appropriate for the site, and compatible with the character of the site and the surrounding area.
• SA Objective 9: Minerals: A significant negative effect likely identified. An assessment of the mineral resource at the site will need to be undertaken to determine what resources exist. If there are any suitable mineral resources it is unlikely that the site would be suitable for mineral extraction because of the close proximity of residential areas, and the need for substantial buffers to be provided at mineral extraction sites to protect residential amenity.
• SA Objective 10: Water – A negligible effect is identified. The promoted development would need to meet water conservation standards.
• SA Objective 11: Adaptation to Climate Change – A negligible effect identified. The promoted development would need to meet climate change adaptation requirements.
• SA Objective 12: Climate Change Mitigation – A minor positive effect identified. The promoted development would need to incorporate climate change mitigation measures.
• SA Objective 13: Air Quality – A minor negative effect is identified. The promoted development is small scale. It is accessible by sustainable modes of transport, and there are realistic alternatives to the car for most journeys from the site to reduce potential increases in traffic and associated impacts on air quality. The phasing out of petrol and diesel vehicles and the requirement for new residential developments to include electric vehicle charging points should help to improve air quality. It is not clear what impacts on air quality would arise from the promoted development.
• SA Objective 14: Economy – A negligible effect is identified. The additional housing and affordable housing provided at the promoted development would meet the needs of employees and support the economy of Cambridge. It is requested that the economy score is changed to ‘minor positive effect likely’.
• SA Objective 15: Employment – A significant positive effect likely is identified. The promoted development is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to employment opportunities in Cambridge. All of the employment opportunities are accessible by walking, cycling or public transport.

It is requested that the above comments are taken into account when the SA is updated.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Endurance Estates that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Endurance Estates’ representations are: SA1 Housing; and SA2 Access to Services and Facilities.

The Endurance Estates representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the Endurance Estates representations to Policy S/DS, there are no housing allocations made in most villages, including Balsham, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 21 affordable dwellings in Balsham will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Endurance Estates has requested that land off Old House Road in Balsham is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Endurance Estates’ representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Balsham is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 21 affordable dwellings in Balsham. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Balsham, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 21 affordable dwellings in Balsham, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Balsham, will not be met by the development strategy or the strategy for rural areas. Balsham contains a primary school, village shop, post office, public houses, and a bus service which is due to be improved. The accessibility to services and facilities and employment opportunities is good for Balsham, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land off Old House Road in Balsham is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Endurance Estates that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Endurance Estates’ representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

The Endurance Estates representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the Endurance Estates representations to Policy S/DS, there are no housing allocations made in most villages, including Bassingbourn, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 65 affordable dwellings in Bassingbourn will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Endurance Estates has requested that land off Poplar Farm Close, land of The Causeway and land off Elbourn Way are allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Endurance Estates’ representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Bassingbourn is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 65 affordable dwellings in Bassingbourn. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Bassingbourn, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 65 affordable dwellings in Bassingbourn, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Bassingbourn, will not be met by the development strategy or the strategy for rural areas. Bassingbourn contains a good range of services and facilities, including a secondary school, primary school, convenience store, post office, doctor's surgery, dentist, pharmacy, public houses, mobile library, sports centre, and outdoor recreation areas. The accessibility to services and facilities is good for Bassingbourn, and the Greater Cambridge Partnership’s Making Connections proposes improvements to bus services, but these factors are not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

it is requested that land off Poplar Farm Close, land off The Causeway and land off Elbourn Way are allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

The driver behind AW relocation is GCP’s vision for NECAAP; the existing plant has capacity to absorb the housing targets including Waterbeach Newtown. Neither the emerging Local Plan nor NECAAP are dependent on the relocation. Given this and the site identified by AW is within Green Belt, deferring the SA/SEA of the effects of pursuing the S/NEC policy to AW and the DCO process might be within ‘law’ but not spirit of SA regulation and Local Plans in the context of transparency and public consultation; an SEA of the relocation and alternative vision based on AW remaining should be presented.

Unfortunately, despite the substantial assessment, the SA does not appear to consider all the relevant factors and as a consequence a number of the findings and in turn the Appraisal, appear incomplete or inaccurate.
Para 3.8 notes that the Assessment is not prepared in isolation and highlights the necessity of identifying the relationships between the Local Plan and other plans, policies and programmes so that any potential links can be built upon and any inconsistencies and constraints addressed.
Para 3.17 references the National Planning Policy Framework, that Local Plans should contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.
SA Chapter 5.4 states that issues such as the Waste Water Treatment Plant relocation will be included at a later issue of the Local Plan to address ‘in-combination effects’.
Chapter 5C considers and discounts options that retain the Waste Water Treatment Works on site yet includes no consideration of its relocation and the corresponding impact on Local Plan Policies.
Policy S/NEC references the Waste Water Treatment Works Relocation and based on 5C would appear to suggest that relocation is a dependency of Policy S/NEC.
While the investigation into relocation is being led by Anglian Water under a different Development Consent Order process, Policy S/NEC and the corresponding relocation is contrary to a wide range of Policies in the Local Plan First Proposal, including: GP/LC, GP/LC, GP/GB, GP/HA, BG/GI, BG/RC, BG/EO, BG/PO, J/AL, WS/HS, CC/NZ, CC/CS. This includes the capital carbon associated with rebuilding a fully operational treatment works at a Green Belt location identified in the 2021 Green Belt Study as having ‘Very High Harm’.
Consequently, the assessments relating to North East Cambridge (S/NEC) do not consider the effects of Waste Water Treatment Plant relocation and therefore provide an unrealistic and imbalanced assessment.
It is understood that the Environmental Impact Assessment Scoping Report for the Waste Water Relocation investigation has been submitted and the Planning Inspector has issued a scoping opinion. Consequently, sufficient information should exist for this to be included within the assessment.
The SA already makes provision within the scoring system for ‘?’ variations and contains a section on pages 43 & 44 addressing Problems Encountered and includes disclaimers relating to aspects of technical detail or mitigation.
It is therefore suggested that the effects of relocation of the Waste Water Treatment Works are included fully within the SA to provide a balanced view. Alternatively, North East Cambridge Policy S/NEC should be omitted from the SA completely until a comprehensive and balanced assessment can be made.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Bloor Homes Eastern that the Sustainability Appraisal has not sought to make the emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Bloor Homes Eastern’s representations to the Sustainability Appraisal are: SA1 Housing and SA2 Access to Services and Facilities. Requested amendments to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Bloor Homes Eastern’ s representations to Policy S/DS, there are no housing allocations made in most villages, including Papworth Everard, and as such the identified need for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages. That information is not reflected in the assessment contained in Table 5.4. The identified need for 41 affordable dwellings in Papworth Everard will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Bloor Homes Eastern has requested that land east of Ridgeway and Old Pinewood Way, Papworth Everard is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Bloor Homes Eastern’s representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Papworth Everard is an example where there are very limited opportunities within the boundary to accommodate major residential development that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 41 affordable dwellings in Papworth Everard. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Papworth Everard, will not be met by the currently defined settlement boundaries. Affordable housing need in the village is also now likely to be greater than that stated above as a result of the age of the Council's 'Housing Statistical Information Leaflet' (December 2019).

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 41 affordable dwellings in Papworth Everard, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Papworth Everard, will not be met by the development strategy or the strategy for rural areas. Papworth Everard contains an extensive range of services and facilities including a convenience store, hairdressers, fish and chip shop, coffee shop and a restaurant, a primary school, children’s nurseries, post office, library, doctor’s surgery/health centre, veterinary surgery, churches and village hall. Development has also commenced to deliver a bakery, microbrewery and Public House on the former print works site, south of Church Lane. The accessibility to services and facilities is good for Papworth Everard, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land east of Ridgeway and Old Pinewood Way, Papworth Everard is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Enterprise Residential Development Ltd and the Davison Group that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

Enterprise Residential Development Ltd and the Davison Group request amendments to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Enterprise Residential Development Ltd and the Davison Group’s representations to Policy S/DS, there are no housing allocations made in most villages, including Elsworth, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages. That information is not reflected in the assessment contained in Table 5.4. The identified need for 12 affordable dwellings in Elsworth will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. It is requested that land at Meadow Drift, Elsworth is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Enterprise Residential Development Ltd and the Davison Group’s representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified need for affordable housing. Elsworth is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 12 affordable dwellings in Elsworth. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Elsworth, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). A ‘mixed significant negative and minor positive effect’ score is also identified for efficient use of land objective (SA8). As set out above there is an identified need for 12 affordable dwellings in Elsworth, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Elsworth, will not be met by the development strategy or the strategy for rural areas. Elsworth contains some services and facilities, including a primary school, public houses, church and sport and social club. The accessibility to services and facilities is good for Elsworth, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land at Meadow Drift, Elsworth is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by NW Bio that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to NW Bio’s representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

NW Bio’s representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in NW Bio’s representations to Policy S/DS, identified needs for affordable housing in the villages, including Sawston, would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all village. That information is not reflected in the assessment contained in Table 5.4. The identified need for 115 affordable dwellings in Sawston will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. NW Bio has requested that the Mill Lane Site, Sawston is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in NW Bio’s representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Sawston is an example where there are very limited opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings, and the Green Belt restricts development outside the settlement boundary. As set out above there is an identified need for 115 affordable dwellings in Sawston. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Sawston, will not be met by the currently defined settlement boundaries.

• Table 5.20: Policy S/RSC: Village Allocations in the Rural Southern Cluster: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect / uncertain’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 115 affordable dwellings in Sawston, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Sawston, will not be met by the development strategy or the strategy for rural southern cluster. Sawston contains a good range of services and facilities, including a variety of convenience stores, a post office, library, primary schools, health services including doctors and dentist, banks, public houses and restaurants. Sawston is also served by Bus Services Citi 7 and 7A, providing access existing services and facilities in Sawston and beyond. The nearest railway station is Whittlesford Parkway Railway Station which can easily be reached by private car and bus, and is within an acceptable cycling distance, providing access to existing services and facilities in Cambridge and the wider area. The accessibility to services and facilities is excellent for Sawston and for land the Mill Lane Site, but this is not reflected in the assessment for this sustainability related objective, and additional development in this location would improve the sustainability outcomes and support the existing services and facilities. It is requested that the Mill Lane Site, Sawston is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Bloor Homes Eastern that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to the Bloor Homes Eastern representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

The Bloor Homes Eastern representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the Bloor Homes Eastern representations to Policy S/DS for land west of Linton, there are no housing allocations made in most villages, including Linton, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 50 affordable dwellings in Linton will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Bloor Homes Eastern has requested that land west of Linton is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in the Bloor Homes Eastern representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Linton is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for at least 50 affordable dwellings in Linton. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Linton, will not be met by the currently defined settlement boundaries.

• Table 5.20: Policy S/RSC: Village Allocations in the Rural Southern Cluster: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect / uncertain’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 50 affordable dwellings in Linton, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Linton, will not be met by the development strategy or the strategy for rural southern cluster. Linton contains a very good range of services and facilities, including primary schools, secondary school, convenience stores and post office, village hall, health services including a medical centre, public houses, cafes and restaurants, and bus services which are due to be improved by Greater Cambridge Partnership projects. The accessibility to services and facilities is very good for Linton, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities. In addition, the promoted development includes land for a GP surgery and early years facility.

It is requested that land west of Linton is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Mr James Manning that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Mr James Manning’s representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

Mr James Manning’s representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Mr James Manning’s representations to Policy S/DS, there are no housing allocations made in most villages, including Willingham, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 35 affordable dwellings in Willingham will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Mr James Manning has requested that land off Station Road in Willingham is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Mr James Manning’s representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Willingham is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 35 affordable dwellings in Willingham. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Willingham, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 35 affordable dwellings in Willingham, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Willingham, will not be met by the development strategy or the strategy for rural areas. Willingham contains a variety of convenience stores, a post office, library, primary school, doctor's surgery and pharmacy, public houses and restaurants, a bus service which is due to be improved, and is close to a Cambridge Guided Busway stop. The accessibility to services and facilities is good for Willingham, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land off Station Road in Willingham is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Hill Residential that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Hill Residential representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

Hill Residential representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in Hill Residential’s representations to Policy S/DS for land east of Balsham Road in Fulbourn, there are no new housing allocations made in most villages, and the existing and recent major developments in Fulbourn would only partially meet identified affordable housing needs but unmet needs would remain. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 65 affordable dwellings in Fulbourn will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Hill Residential has requested that land east of Balsham Road in Fulbourn is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Hill Residential’s representations to Policy S/SB the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Fulbourn is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for 65 affordable dwellings in Fulbourn. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fulbourn, will only be partially met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 68 affordable dwellings in Fulbourn, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Fulbourn, will not be met by the development strategy or the strategy for rural areas. Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. It contains a good range of services and facilities, including a primary school, doctor’s surgery, pharmacy, library, post office, supermarket and other small convenience stores, village hall, and outdoor recreation and play facilities. There are regular bus services to Cambridge, Haverhill and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The walking and cycling routes and bus services in Fulbourn are due to be improved in the future by Greater Cambridge Partnership projects. The accessibility to services and facilities is very good for Fulbourn, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land east of Balsham Road in Fulbourn is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Endurance Estates that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable. It appears that the assessment against sustainability objectives is not robust because it does not critically review or challenge the evidence provided by the Councils.

Endurance Estates representations and requested amendment to the assessment of policy options in the Sustainability Appraisal, which are relevant to the promoted development for employment uses at land at Caxton Gibbet are as follows:

• Table 5.4: Policy S/DS: Development Strategy - Assesses the development strategy against sustainability objectives. The economy objective (SA14) relates to employment land supply and business needs matters, and the and employment objective (SA15) relates to the availability of and access to employment opportunities. The score of the economy and employment objectives are ‘mixed minor effects likely’. These scores highlight how unambitious the development strategy is towards supporting the economy of Greater Cambridge, supporting businesses and meeting their needs, and providing job opportunities for residents. As set out in Endurance Estates’ representations to Policy S/DS, the need for additional land for industrial and strategic logistics will not be met through the preferred development strategy, and there is no clear strategy to make Cambourne more sustainable by directing strategic employment development to this location. It is considered that the SA should recommend amendments to Policy S/DS to improve the score for economy and employment related sustainability objectives. As requested in the representations to Policy S/DS and S/CB: Cambourne, a specific strategic employment allocation should be made at land at Caxton Gibbet for Class B2 and Class B8 uses, in order to meet the needs for industrial and strategic logistics floorspace in Greater Cambridge and to provide job opportunities close to Cambourne for existing and future residents.

• Table 5.16: Policy S/CB: Cambourne – Identifies ‘significant positive effects likely’ for the economy objective (SA14) and the employment objective (SA15). The commentary for these matters refers to the transport connections as providing an opportunity to attract a new workforce. The assessment and commentary for economy and employment matters is inadequate and not robust. There is already an existing highly skilled workforce available in Cambourne, the problem is that not enough jobs are provided in this location to enable residents to work locally and so they travel elsewhere for employment purposes. It is not a sustainable outcome for most residents of Cambourne, the largest settlement in South Cambridgeshire, to travel to other centres for work, and it is necessary for emerging GCLP to set out a deliverable strategy to increase significantly the amount of job opportunities available in Cambourne during the plan period. As set out in Endurance Estates’ representations to S/CB: Cambourne, it is requested that a specific strategic employment allocation should be made at land at Caxton Gibbet for Class B2 and Class B8 uses, in order to meet the needs for industrial and strategic logistics floorspace in Greater Cambridge and to provide job opportunities close to Cambourne for existing and future residents. This approach would more accurately reflect the ‘significant positive effects likely’ scores currently given for the economy and employment related sustainability objectives.

• Table 5.50: Policy J/NE: New Employment Development Proposals – Identifies ‘significant positive effects likely’ for the economy objective (SA14) and a ‘negligible effect’ for the employment objective (SA15). The ‘negligible effect’ score for the employment objective again highlights the lack of ambition in emerging GCLP to meet the employment needs of all residents. The ‘significant positive effects likely’ score for the economy objective does not take into account the decision to not meet the business needs for additional Class B2 and B8 floorspace – see findings in the Need for Employment Land Report (prepared by Savills) and the Market Demand Report (prepared by Carter Jonas) referred to in representations to Policy S/CB: Cambourne, Policy S/DS: Development Strategy and Policy J/NE. It is clear that emerging GCLP does not intend to accommodate the needs for high and mid-technology manufacturing and strategic logistics floorspace. The SA does not assess the consequences of industrial and logistics floorspace being provided elsewhere and not in Greater Cambridge, or the associated consequences on the economy, businesses, employees and transport. It is considered that there would be negative sustainability outcomes for all these matters. Policy J/NE should seek to deliver an actual ‘significant positive effects likely’ score for the economy and employment related sustainability objectives by meeting the needs for industrial and strategic logistics floorspace in Greater Cambridge and by providing job opportunities close to Cambourne for existing and future residents. This could be delivered by a specific strategic employment allocation at land at Caxton Gibbet for Class B2 and Class B8 uses, as requested by Endurance Estates.

It is requested that the above comments are taken into account when the SA is updated.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Hawkswren that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to Hawkswrens’ representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

The Hawkswren representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the Hawkswren representations to Policy S/DS, there are no housing allocations made in most villages, including Orwell, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 12 affordable dwellings in Orwell will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Hawkswren has requested that land off Leaden Hill is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in Hawkswrens’ representations to Policy S/SB, the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Orwell is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for at least 12 affordable dwellings in Orwell. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Orwell, will not be met by the currently defined settlement boundaries.

• Table 5.22: Policy S/RRA: Allocations in the Rest of the Rural Area: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 12 affordable dwellings in Orwell, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Orwell, will not be met by the development strategy or the strategy for rural areas. Orwell contains a good range of services and facilities, including primary school, convenience store, post office, public house, mobile library, community centre, and outdoor recreation areas. The accessibility to services and facilities is good for Orwell, and the Greater Cambridge Partnership’s Making Connections proposes improvements to bus services, but these factors are not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities.

It is requested that land off Leaden Hill is allocated in the emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.

New Settlements:
Between the First Conversation and the First Proposals stages, the October 2021 SA states that a sustainable settlement sizes review was undertaken and concluded that only new settlements of 4500+ homes should be considered ‘sustainable’ within the Options. This is different to the more detailed assumptions within the HELAA which has been applied to individual site option assessments yet this broader high-level is still considered by the authority as being appropriate for SA purposes. This has the effect of excluding the consideration of any HELAA site which is capable of meeting the key objectives and vision if it is below 4500 homes in size, even if it would comprise a strategic expansion at/adjacent to an existing village.

Furthermore, because of this minimum threshold criteria being applied, any New Settlement option has been negatively skewed on the basis that at this scale, sites were unlikely to provide sufficient housing until later in the plan period due to lead in times and delivery of new infrastructure. Hence no new or extended village options have progressed through to First Proposals.

Paragraph 105 of NPPF2021 guides significant development to locations that are or ‘can be’ made sustainable through offering a genuine choice of transport modes. No consideration has been given to strategic scale growth to improve the relative sustainability of any existing village where they meet other key objectives of the plan. This categorisation also goes against previous new settlement allocations. Bourn Airfield is considered to be a sustainable new settlement in the 2019 Local Plan at 3,500 homes. Cambourne has also evolved through previous development plans as four linked villages of circa 1200 units each.

As a result of this change in focus, no scheme under 4500 homes at any location in the rural areas has been assessed as a reasonable alternative – even as significant growth at existing villages along transport corridors. Any development in the rural areas has been dismissed outright based on the negative sustainability impacts of a perceived ‘dispersed’ strategy.

By limiting new settlements options to a minimum 4500+ new homes and other development in the rural areas to small/non-strategic sites without any regard to distribution or scale, the SA does not properly assess a combined urban area/transport corridor strategy. There is no explanation why new or extended villages cannot be considered a reasonable alternative where they meet other spatial objectives. The SA need to test strategic scale sites in/adjacent to rural centres or villages of between 700 units up to 4,500 units as an integral part of the spatial options.

The SA has not taken forward any meaningful appraisal of growth outside the City or the existing new settlements as reasonable alternatives to the preferred spatial strategy. Sites under 4500 homes have not been properly considered.

In summary, we consider the impacts of a New Settlement option or village expansion proposal as part of any spatial strategy has been unfairly discounted in the formation of the First Proposals strategy or testing of reasonable alternatives.

Western corridor:
A key theme of the GCLP is to reduce the over reliance on car use and high levels of car ownership and to minimise and mitigate the transport impacts of development, including the impacts on the environment and the health and wellbeing of local communities.

Paragraph 104 NPPF2021 states that transport issues should be considered from the earliest stages of plan-making/ and that opportunities from existing or proposed transport infrastructure should be optimised.
The delivery of ‘transformational’ infrastructure benefiting existing as well as new communities and the local environment should inform the selection of strategic sites and the policies to shape them. This primarily includes the EWR project and its future station at Cambourne and linked improvements along the C2C corridor. However, we do not consider this extends far enough.

The local opportunity arising from the nationally significant A428 Improvement scheme has not been fully explored within the SA when developing and refining options and assessing effects. The evidence base acknowledges this could include assessing where alternative allocations or mitigation measures would improve the sustainability, viability and deliverability of proposed land allocations (including individual sites) provided these are compliant with national policy as a whole (Infrastructure Topic Paper -ITP). The opportunity to extend the C2C corridor in a westerly direction along the section of the existing A428 from Caxton Gibbet to Croxton (and beyond to East of St Neots) once it has been down-graded to a local road should be explored further.

The ITP concludes that all of the spatial options with the exception of Option 5 Villages have the potential to increase use of active travel modes and reduce reliance on the car, as long as the exact location of the development sites is carefully considered. Unfairly, this rules out consideration of any village expansion opportunities along key corridors, as set out in the SA under the more recent spatial options. The transport evidence that the SA is based upon is overly restrictive.

There are some reasonable alternatives that should have been clearly considered including for example, a potential Croxton Garden Village Option as part of Options 4, 5,6 and 8. In relation to Croxton (HELAA Site 40288), the SA dismisses it on the basis that a new settlement option was not favoured, instead focusing on additional development onto brownfield sites on the edge of Cambridge, and to take advantage of a new EWR station at Cambourne.

If properly assessed against the backdrop that the A428 DCO scheme already has funding and a decision on its planning status is due before the next iteration of the draft plan in Summer 2022, the site should have scored differently. Both in terms of its relative sustainability and landscape impacts. The site was put forward as a location for a garden village of circa 1750 for the GCLP area with the potential to extend to 4000. However, as New Settlement options were ruled out before reasonable alternatives were considered, it was automatically discounted.

Given the aforementioned changes to the A428 and the opportunity this scheme brings to creating cycleways and/or extended bus strategy along the de-trunked route in the near future; the presence of an existing mainline rail station at St Neots and the new station options at Cambourne and St Neots South, this site should form part of any sustainable strategy across Greater Cambridgeshire.

For the site-specific assessments, Croxton was given a red flag overall and considered unsuitable, despite being available and achievable. The only red flag relates to landscape and townscape constraints. This whole assessment has been undertaken with no regard to the changing landscape from the A428. The site assessment should be reviewed and updated to properly reflect the changing circumstances, for consistency. There are examples where policy-on criteria has been used to assess a sites suitability, including at Cambourne and the potential future EWR station.

Vistry Group acknowledge the March 2021 announcement by the GCP indicating a change in focus away from the CAM project which has heavily influenced the First Proposals options. The LTP is yet to be updated and until such a time, we welcome the acknowledgement that the current proposals could be subject to change in the draft plan should the assumptions on the abandonment of the CAM change (Development Strategy Topic Paper Sept 2021).

Overall, the First Proposals do not currently include sufficient flexibility to adapt to rapid change and runs the risk of falling short on delivering the housing requirement. The sites selected do not create a balanced distribution of need and affordability focusing the majority of growth in Cambridge or at the existing three new settlements from the previous local plans. The narrow-focused distribution of development to 2041 does not provide sufficient confidence that delivery rates can be sustained over the short-medium and long-term.

Until all of the reasonable alternatives have been appraised, it is not possible to conclude that the First proposals would represent the most sustainable strategy. As stated in the 2021 evidence base, further work is required to establish which infrastructure projects can be relied upon.