Greater Cambridge Local Plan Preferred Options

OBJECT

These representations are submitted on behalf of the North Barton Road Landowners Group (North BRLOG), who has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension. The promoted development is referred to as “South West Cambridge” in these representations. A number of technical reports and a Vision Document have been prepared for the promoted development, all of which were submitted at the Issues & Options stage of emerging GCLP. The findings of the technical reports and Vision Document are referred to in response to relevant policies in the GCLP Preferred Options consultation and the associated site assessments in the Housing and Economic Land Availability Assessment (HELAA) and Sustainability Assessment (SA).

The then named Greater Cambridge City Deal (now known as the Greater Cambridge Partnership) recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has had an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal included a commitment to deliver substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. Neither does the ‘medium plus’ growth option reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or recognise that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected a higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

A Housing and Economic Development Needs Assessment was prepared by Iceni Projects Ltd for North BRLOG, and was submitted with representations at Issues & Options stage for emerging GCLP; it is resubmitted with these representations. The Assessment examined the inter-related issues of economic growth, affordability and housing need in Greater Cambridge.

The evidence in the Assessment identifies a fundamental imbalance between rates of economic growth and housing delivery, which is leading to acute housing affordability issues. It is noted in the Report that median house prices are more than 11 times average earnings across the Greater Cambridge Area (with a higher ratio in Cambridge City). The undersupply of homes presents a fundamental challenge to the area’s future economic growth because workers are being priced out of the area and firms in the Greater Cambridge area finding it increasingly difficult to recruit.

It is recommended in the Assessment that planning for housing should be based on a blended economic growth rate of 2.8% per annum i.e. based on short-term economic trends to 2031 and longer-term economic trends thereafter; this recommendation is consistent with the findings of the Cambridge and Peterborough Independent Economic Review (CPIER), the Cambridgeshire and Peterborough Devolution Deal, and the Local Industrial Strategy for the area. It is common planning practice to seek to align housing and economic strategies.

Iceni’s analysis demonstrates that 101,200 dwellings are required in the Greater Cambridge area between 2017 and 2040, which equates to 4,400 dwellings per annum.

Requested Change

It is requested that the housing target in Policy S/JH is based on achieving a blended economic growth rate of 2.8% per annum. It is requested that the housing target should be 4,400 dwellings per annum for Greater Cambridge to meet this economic growth rate.

OBJECT

North BRLOG is promoting land at South West Cambridge for a landscape-led urban extension to Cambridge, and in representations it is requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy overall and the strategy for the edge of Cambridge, including the over reliance on the existing new settlements and new neighbourhoods to meet the housing requirements, and the decision to not release additional land from the Green Belt on the edge of Cambridge despite these being identified as sustainable locations.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum. The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates for Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG and submitted with Issues & Options representations) highlighted the difficulty that the existing new settlements have in providing sufficient affordable housing, and also that there is sufficient residual value in strategic greenfield sites on the edge of Cambridge to support planning obligations and policy requirements including affordable housing in full. It is clear that the existing and planned new settlements and new communities on the edge of Cambridge are not and will not provide enough affordable housing, which should be a major concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from other strategic sites, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including the promoted development by North BRLOG at South West Cambridge.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt around Cambridge, which are related to the significant need for housing and affordable housing in Greater Cambridge, and the need for additional housing to support the economic growth of Greater Cambridge. The cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high too. The Housing Needs of Specific
Groups Report (GL Hearn October 2021) provides further information on affordability and affordable housing needs. Table 42 of the GL Hearn Report identifies an affordable housing need of 199 dwellings per annum for Cambridge and 105 dwellings per annum for South Cambridgeshire, which equates to a combined total of 304 affordable dwellings per annum or a total of 6,384 dwellings during the plan period from 2020 to 2041. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely a large proportion of those journeys are undertaken by car this would add to traffic congestion and air pollution. The promoted development by North BRLOG at South West Cambridge would include affordable housing, and is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge and to other employment opportunities available in the City. The promoted development at South West Cambridge would be consistent with the exceptional circumstances to justify the release of land from the Green Belt, and would enable more employees and residents to live closer to where they work.

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

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. The promoted development at South West Cambridge is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities available in the City Centre. It is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge, and to other employment opportunities available in the City. Therefore, the release of the land at South West Cambridge from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

As set out in the North BRLOG representations to Section 2.3: Edge of Cambridge and to the HELAA Site Assessments for Site Ref. 52643 (Land north of Barton Road and at Grange Farm,
Cambridge), the Vision Document for South West Cambridge seeks to address landscape, heritage and Green Belt impacts by retaining substantial parts of the promoted development for green infrastructure that would remain within the Green Belt.

There are three other paragraphs in the NPPF that suggest additional allocations should be made on the edge of Cambridge at the South West Cambridge site. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders.

As set out above, the South West Cambridge site is accessible by walking, cycling and public transport, and will be well-related to planned bus and walking/cycling improvement projects being brought forward by the Greater Cambridge Partnership. The site is accessible to employment, education, retail and leisure opportunities. The promoted development would include a primary school and neighbourhood centre to meet the needs of residents and the surrounding area. There is a substantial and current identified need for affordable housing and a high housing affordability ratio in Cambridge and South Cambridgeshire, making it difficult for those that work in Greater Cambridge to access housing to buy and rent. The promoted development at South West Cambridge would provide market and affordable/social housing.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including sites in the edge of Cambridge, in order to address the under-delivery of affordable housing from elsewhere.

It is requested that the promoted development at South West Cambridge is released from the Green Belt and allocated in emerging GCLP for a landscape-led urban extension.

OBJECT

As highlighted in the North BRLOG representations to Policy S/DS: Development Strategy, the key parts of the development strategy for emerging GCLP comprises 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. It should be a concern for emerging GCLP that most of the strategic sites will not provide enough affordable housing, particularly in an area such as Greater Cambridge which has significant housing affordability issues. In contrast, there is sufficient residual value in strategic greenfield sites on the edge of Cambridge to support planning obligations and policy requirements in full, including affordable housing. The proposed redevelopments at North East Cambridge and Cambridge East are complex and involve the relocation of the existing uses.

Paragraph 140 of the NPPF allows land to be released from the Green Belt through the plan-making process where exceptional circumstances exist. It is considered that exceptional circumstances exist to release land from the Green Belt around Cambridge, which are related to the significant need for housing and affordable housing in Greater Cambridge, and the need for additional housing to support the economic growth of Greater Cambridge. The cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely a large proportion of those journeys are undertaken by car this would add to traffic congestion and air pollution.

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

The promoted development by North BRLOG at South West Cambridge would include market and affordable housing, it is accessible by sustainable modes of transport, and is well-related to employment opportunities.

Therefore, it is considered that the development strategy for emerging GCLP should also include additional allocations on the edge of Cambridge at South West Cambridge.

The following reports were submitted with the North BRLOG representations at Issues & Option stage to support the promoted development at South West Cambridge:
• Vision Document (David Lock Associates)
• Landscape and Visual Appraisal and Green Belt Review (The Landscape Partnership)
• Initial Noise Assessment (WSP)
• Air Quality Constraints Report (WSP)
• Archaeological Desk Based Assessment (Cambridge Archaeological Unit)
• Preliminary Ecological Appraisal (The Landscape Partnership)
• Flood Risk and Drainage Appraisal (Peter Brett Associates)
• Initial Heritage Impact Assessment (Bidwells)
• Transport Technical Note (WSP)

The benefits of the promoted development include the following:
• the provision of housing and affordable housing for key workers and others, including but not limited to University and College staff;
• the provision of residential accommodation for the elderly, including care provision;
• the provision of new tenures such as ‘Build to Rent’, co-living and intra-generational housing;
• accessible parkland with potential connections to Coton Countryside Reserve offering significant scope for biodiversity enhancement;
• delivery of green infrastructure in the form of publicly accessible open space providing access from the City to the countryside to the west of Cambridge;
• other green infrastructure and strategic landscaping, including new woodland planting to address visual impact and provide a buffer with the M11 to address noise and air quality impacts;
• improvements to walking and cycling routes to encourage travel by non-car modes of transport, which is far more attainable for an edge of City Centre site;
• potential to provide land for the Cambourne to Cambridge Bus Strategy and the Comberton and Barton Greenways which are Greater Cambridge Partnership projects;
• the creation of additional north south public transport and cycle routes, connecting Barton Road to Madingley Road, and the provision of connections to existing developments at NW Cambridge, West Cambridge and Addenbrookes/Cambridge Biomedical Campus;
• the provision of a new local centre for the west Cambridge area as well as additional health and education facilities.

The promoted development would be consistent with the relevant policies contained in Section 3.1: Climate Change, Section 3.2: Biodiversity and Green Spaces, Section 3.3: Wellbeing & Social Inclusion; Section 3.4: Great Places; Section 3.6: Homes and Section 3.7: Infrastructure of emerging GCLP.

The landowners - Corpus Christi College, Jesus College, St John’s College, Downing College and the University of Cambridge - have a long-standing commitment to Cambridge and its future and will continue to be neighbours of the promoted development. North BRLOG are committed to the identified benefits and policy aims and their long-term stewardship of the site will assist in delivering these.

For all these reasons, the site at South West Cambridge should be allocated for a landscape-led urban extension in the emerging GCLP. The Vision Document for South West Cambridge could form the basis for a site specific policy and additional allocation on the edge of Cambridge. The key policy requirements for the promoted development are set out in the requested changes.

Requested Change

Additional Allocation at Edge of Cambridge: Land at South West Cambridge

A landscape-led urban extension to Cambridge of high-quality, with high sustainability standards and delivering a net gain in biodiversity.

The promoted development contains the following mix of uses:

• Between 2,500 and 2,800 dwellings including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and student accommodation;
• A comprehensive new green infrastructure network comprising open space and sports pitches, a new country park with connections to Coton Countryside Reserve, wildlife areas and biodiversity enhancement, and strategic landscaping including new woodland planting;
• Creation of new flood meadows and the potential re-wilding of Bin brook in certain locations to enhance capacity and its ecological benefits;
• A green landscape edge to the M11 to provide a landscape setting to the South West of Cambridge;
• A community facility including primary school, community centre, health centre;
• A neighbourhood centre including food store and other shops, services and facilities to serve the local community, nearby residents and the West Cambridge campus;
• Enhanced pedestrian and cycle connections to the existing and planned walking, cycling and public transport network in the local area, and a development which places the needs of pedestrians and cyclists ahead of car users;
• A network of streets and spaces that are diverse in their function and character;
• A public transport corridor that will link the site with other service and routes and to other City destinations;
• High levels of energy performance in building design that follows best practice in energy and carbon reduction; and
• Sustainability measures including a water recycling system, district heating system and underground waste collection system.

OBJECT

As highlighted in the submitted Vision Document, the promoted development at South West Cambridge would include new accessible parkland and green infrastructure with potential connections to Coton Countryside Reserve. It would retain and enhance existing ecological features on the site and provide biodiversity enhancement including a new wetland habitat at Bin Brook which would also retain floodwater. It is considered that this approach would be consistent with the aims of the following policies in Section 3.2: Policy BG/BG: Biodiversity and Geodiversity; Policy BG/GI: Green Infrastructure; Policy BG/RC: River Corridors; and Policy BG/EO: Providing and Enhancing Open Spaces. It is the large-scale development with sufficient land available that can deliver significant benefits for all these policy areas.

Figure 54 in the GCLP Preferred Options document identifies green infrastructure initiatives, including one at West Cambridge GI Buffer – Coton Corridor, which is located on the western side of the M11 and opposite the South West Cambridge site. The objective for this green infrastructure initiative is to “Enhance the recreational and habitat offer to ensure there is sufficient high-quality and accessible GI to keep pace with growing development (and associated recreational pressure) west of Cambridge. This includes improving accessibility to and between GI assets and surrounding settlements, providing more opportunities for recreation and nature (making sites 'work harder'), expanding GI where possible, and enhancing habitats” – see pg.8 of Greater Cambridge Green Infrastructure Opportunity Mapping Part 2 Recommendations Report (LUC September 2021). The green infrastructure proposed for the promoted development at South West Cambridge would be consistent with this initiative, in terms of providing additional opportunities for recreation and nature, improving accessibility to green infrastructure for Cambridge residents, and connecting green infrastructure areas.

Cambridge Past Present & Future (CPPF) owns and manages the Coton Countryside Reserve, which involved taking land out of agricultural use to create habitats for wildlife including trees, hedges, orchards and meadows. It is considered that the proposed new wetland habitat within the promoted development at South West Cambridge would represent a continuation of the environmental work that CPPF undertakes at the Coton Countryside Reserve.

There is a real opportunity to deliver green infrastructure improvements on the western edge of Cambridge in conjunction with development at the South West Cambridge site, and complement existing initiatives and activities.

Requested Change

It is requested that the promoted development at South West Cambridge is allocated in emerging GCLP to deliver substantial green infrastructure benefits and complement the West Cambridge GI Buffer – Coton Corridor initiative and CPPF’s work at Coton Countryside Reserve.

COMMENT

North BRLOG is promoting land at South West Cambridge as an exemplar, landscape-led, and highly sustainable new neighbourhood. A Vision Document, informed by a number of technical reports, has been prepared for the promoted development.

The Masterplan for the promoted development has taken into account the significance and setting of the identified heritage assets and landscape character, in order to ensure that any impacts are mitigated wherever possible. In summary, the promoted development includes a substantial central east-west open corridor through the site which takes into account some of the primary viewpoints towards the City from the west, retains existing landscape features, and locates development to avoid potential adverse effects on the setting of landmark/taller heritage assets in the City. This approach of detailed heritage and landscape assessments followed by careful and sensitive design is consistent with the design policies in Section 3.4. The Masterplan demonstrates that heritage and landscape assets within and on the edge of Cambridge can be protected in conjunction with a strategic site allocation at South West Cambridge.

COMMENT

Policy I/ST: Sustainable Transport and Connectivity set out how the transport impacts of development should be managed, and how new development should be connected to the transport network. An aim of the policy is to reduce transport emissions. The preferred development strategy seeks to co-locate housing close to jobs, services and facilities in order to reduce the need to travel and support travel by walking, cycling and public transport. This approach is consistent with Paragraphs 104 and 105 of the NPPF and is supported. However, it is considered of the aim of Policy I/ST will only be fully implemented if all available opportunities to direct development to sustainable locations are taken, including additional development being directed to the edge of Cambridge.

The promoted development by North BRLOG at South West Cambridge is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities available in the City Centre. It is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge, and to other employment opportunities available in the City, which will enable more residents to live closer to where they work. It is considered that the promoted development at South West Cambridge is an example of land that should be released from the Green Belt through the emerging GCLP in order to reduce travel distances and respond to climate change.

Therefore, additional allocations on the edge of Cambridge, including at the promoted development at South West Cambridge, would be consistent with the aims of Policy I/ST.

Requested Change

It is requested that the promoted development by North BRLOG at South West Cambridge is allocated for an urban extension, in order to support the aims of Policy I/ST e.g. reduce transport emissions, reduce the need to travel, and encourage the use of sustainable modes of transport.

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 North BRLOG 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.

North BRLOG 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 North BRLOG 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 are 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 strategic allocations in sustainable locations that deliver affordable housing such as on the edge of Cambridge.

The promoted development by North BRLOG at South West 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. 52643 Land North of Barton Road and land at Grange Farm, 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.

North BRLOG’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 would provide between 2,500 and 2,800 dwellings, including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and student accommodation. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG and submitted with Issues & Options representations) highlighted that there is sufficient residual value in strategic greenfield sites on the edge of Cambridge, including at South West Cambridge to support planning obligations and policy requirements including affordable housing. It is requested that the score for housing is changed to ‘significant positive effect likely’.
• SA Objective 2: Access to Services and Facilities – A significant positive effect likely/minor positive effect is identified. The site is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities and employment opportunities available in neighbouring areas and within the City Centre. The promoted development includes a primary school, community centre, health centre, and neighbourhood centre with a food store and other shops. 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 mixed minor/negligible effect is identified. No comments. The promoted development would deliver housing and a substantial amount of affordable dwellings. The promoted development would provide 40% affordable housing. The site is also well related to other employment opportunities available elsewhere within and on the edge of the City. All of the employment opportunities are accessible by walking, cycling or public transport. In addition, the promoted development would provide jobs during the construction phase, and there would be jobs available within the proposed school, shops, and health centre. The promoted development would deliver positive social inclusion and equality benefits. It is requested that the social inclusion and equalities score is changed to ‘significant positive effect’.
• SA Objective 4: Health – A minor positive effect/negligible effect is identified. The promoted development would include substantial areas of open space and recreation areas for outdoor activities, walking and cycling facilities for active travel, and a health centre. It is requested that the health score is changed to ‘significant positive effect likely’.
• SA Objective 5: Biodiversity and Geodiversity – A minor negative effect is identified. A Preliminary Ecological Appraisal has been undertaken of the site. The County and City Wildlife Sites, the network of ditches, the Bin Brook watercourse, and the hedgerows at the site would all be incorporated into the promoted development. The proposed development provides a number of opportunities for ecological enhancement, including the re-naturalisation and ‘rewilding’ of the Bin Brook and the creation of a dedicated arable weed reserve. An assessment of the benefits from these ecological enhancements will need to be calculated, but are likely to be beneficial. It is requested that the biodiversity score is changed to ‘significant positive effect likely’.
• SA Objective 6: Landscape and Townscape. A significant negative effect is identified. A Landscape and Visual Appraisal and Green Belt Review has been undertaken of the site. The promoted development includes a substantial central east-west open corridor through the site which takes into account some of the primary viewpoints towards the City from the west, retains existing landscape features, and locates development to avoid potential adverse effects on the setting of landmark/taller heritage assets in the City. The key views across the site would be retained as part of the promoted development, and there would be additional landscaping at the edge of and within the proposed residential areas. It is requested that the landscape and townscape score is changed to ‘negligible’.
• SA Objective 7: Historic Environment: A minor negative effect is identified. An Initial Heritage Impact Assessment has been undertaken of the site, to identify the significance and setting of heritage assets that might be affected by the promoted development. The most sensitive parts of the site in heritage terms and the key views across the site remain undeveloped, and are part of the central east-west corridor through the site.
• SA Objective 8: Efficient Use of Land – A mixed significant negative/minor positive effect is identified. The site is greenfield, although a substantial part of the site would remain as open space and green infrastructure as part of the promoted development and the soil resources would be retained. A variety of densities and building heights would be provided within the promoted development, consistent with the findings of the landscape and heritage assessments and with an edge of City location. The proposed densities at the site are appropriate for this location, and represent an efficient use of land. The mixed effect score is appropriate.
• 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 minor negative effect is 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. An Air Quality Constraints Report has been prepared for the site. The 250m wide landscape buffer along the western edge of the site and adjacent to the M11 would also address air quality impacts on the promoted development. 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 overall.
• 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 ‘significant positive effect likely’.
• SA Objective 15: Employment – A significant positive effect likely is identified. The promoted development is adjacent to West Cambridge, which provides existing employment opportunities but is due to grow substantially in the near future. The site is also well related to other employment opportunities available elsewhere within and on the edge of the City. All of the employment opportunities are accessible by walking, cycling or public transport. In addition, the promoted development would provide jobs during the construction phase, and there would be jobs available within the proposed school, shops, and health centre. It is agreed that the promoted development would deliver a ‘significant positive effect’ for employment.

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