Draft Greater Cambridge Local Plan for consultation

Vision for Greater Cambridge

Comment

KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn. The Vision for Greater Cambridge in the Reg.18 Draft Greater Cambridge Local Plan (draft GCLP) refers to increasing quality of life for communities, minimising carbon emissions, reducing car use, providing housing, supporting infrastructure and increasing green spaces.

As set out in these representations, the preferred housing target, the development strategy and the selected allocations for draft GCLP are unlikely to fully deliver the Vision for Greater Cambridge. The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. The development strategy is too focussed on the delivery of large strategic sites including an expanded Cambourne, existing new settlements at Northstowe, Waterbeach and Bourn Airfield, and a proposed new settlement at Grange Farm. The delivery timetable for infrastructure to support an expanded Cambourne and at Grange Farm is uncertain. For all of the large strategic site allocations the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. The development strategy avoids directing development to the larger villages, including Fulbourn, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs.

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Fulbourn.

Strategic Priorities

Comment

KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn. The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the preferred housing target, the development strategy and the selected allocations for draft GCLP are unlikely to fully deliver the strategic priorities.

The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. This outcome would not meet the climate change strategic priority. The development strategy is too focussed on the delivery of large strategic sites, where the timetable for the delivery of necessary infrastructure is uncertain in some cases, the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. It is considered that housing and affordable housing needs would not be met by a development strategy based on this approach, and would not meet the homes strategic priority. The development strategy avoids directing development to the larger villages, including Fulbourn, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs. This approach does not support the residents or services and facilities in those villages, and would not meet the great places, homes, connectivity and infrastructure strategic priorities. It is noted that some green infrastructure opportunity areas identified in draft GCLP, including close to Fulbourn, are unrelated to strategic development allocations that could support their delivery. In these circumstances those proposed green infrastructure opportunity areas are unlikely to be delivered, and this outcome would not meet the biodiversity and green spaces strategic priority.

It is considered that the strategic priorities for draft GCLP would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Fulbourn.

Requested Change

The following changes to Policy S/JH are requested.

It is requested that the housing target is recalculated to include the previous commuting patterns adjustment, consistent with the adjustment made in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report.

It is requested that the housing target includes some upward adjustments for growth ambitions, that reflect the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal, the draft Local Growth Plan of the Mayor for Peterborough & Cambridgeshire, and the Cambridge Growth Company.

It is requested that housing target include some upward adjustment to address affordable housing needs.

Consistent with the representations to Appendix D, a new policy is required in draft GCLP to ensure that the housing requirements for neighbourhood plan areas are delivered.

Policy S/JH: New Jobs and Homes

Object

Policy S/JH of draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,195 dwellings. The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,295 dwellings per annum. In summary, the housing target is not consistent with national policy because upward adjustments for growth and affordable housing have not been considered.

It is noted that the job target is not aligned with the housing target. It is considered that a job target that is higher than the housing target would require potential employees to commute into Greater Cambridge to fill those jobs. This outcome would lead to an increase in in-commuting to Greater Cambridge. It is anticipated that most of the in-commuting would be by car, particularly if public transport options are not available or the delivery of transport infrastructure projects are subject to unconfirmed funding decisions and associated development.

The housing target identified in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report was based on a Central Growth Scenario, the preferred 2011 Census commuting data, and included a 1:1 commuting patterns adjustment. This previous approach sought to better align the job and housing targets. The 2025 Greater Cambridge Employment and Housing Needs Update 2024-2045 Report does not include a similar commuting patterns adjustment, which is an inconsistent approach. It is requested that the housing target is recalculated to include the previous commuting patterns adjustment.
Paragraph 61 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 62 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 63 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. Paragraph 69 states in part that “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. Paragraph 008 (ID. 67 - Housing needs of different groups) in the Planning Practice Guidance states in part that “An increase in the total housing requirement included in the plan may need to be considered where it could help deliver the required number of affordable homes”. The housing target in Policy S/JH is based on the standard method only, with no adjustments for growth linked to economic development and infrastructure investment or to meet affordable housing needs, all of which are relevant to Greater Cambridge.

The Greater Cambridge City Deal 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 draft Local Growth Plan of the Mayor for Peterborough & Cambridgeshire sets out two growth scenarios: a core scenario which doubles the economy by 2050; and an aspirational scenario which triples the economy by 2050. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership have previously acknowledged and supported the economic growth potential of the Greater Cambridge area, and concluded 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. The housing target in Policy S/JH ignores the commitments made in the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal. It also ignores the findings of work undertaken by the National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership.

In 2024 the Government established a Cambridge Growth Company to maximise Cambridge’s full economic potential and to deliver nationally significant growth. The Growth Company will seek to unlock and accelerate development for Cambridge, and to deliver the homes, jobs and infrastructure needed for the long-term and sustainable growth of the City. It will seek to deliver more ambitious levels of growth than are proposed in the emerging Greater Cambridge Local Plan. In order to deliver more ambitious levels of growth, the Growth Company will need to tackle some of the barriers to growth including water and transport infrastructure, traffic congestion, and housing affordability. It is acknowledged that draft GCLP does not need to take into account the levels of growth to be addressed by the Cambridge Growth Company. However, it does indicate that there are growth ambitions for Greater Cambridge and there should be some upward adjustment to the housing target in Policy S/JH to reflect this future growth during the plan period for draft GCLP.

There are a number of proposed and planned infrastructure projects in Greater Cambridge that should have been taken into account in deciding whether adjustments should be made to the housing target in Policy S/JH. The list of infrastructure projects includes East West Rail, Cambourne to Cambridge Busway, Cambridge South East Transport project, Waterbeach to Cambridge Busway, Cambridge Eastern Access project, and Cambridge South Station. In addition, the Greater Cambridge Partnership is delivering greenways to connect surrounding villages to Cambridge by walking and cycling. The funding for some of these projects have not been confirmed, but it is anticipated that they will need to be supported by associated development.

The 2025 ‘Housing Needs of Specific Groups in Cambridge and South Cambridgeshire’ Report identifies the housing needs of different groups, including the need for affordable housing. Chapter 7 of the Report deals with affordable housing need. The Report identifies an acute need for affordable housing in Greater Cambridge. It estimates an annual need for 1,083 affordable homes for households unable to buy or rent housing across Greater Cambridge, excluding those that can rent but not buy – see Paragraph 7.62 in the Report. It includes an analysis of the affordable housing need if those households already living in accommodation are excluded, which would be an affordable need for 425 homes per annum in Cambridge and 318 dwellings per annum in South Cambridgeshire – see Paragraph 7.63 in the Report. A combined figure for Greater Cambridge would be 743 affordable homes per year. It is acknowledged that the affordable housing data is complex, households needs will change over time, and the annual affordable housing needs should not be multiplied to generate a figure for the whole plan period. The Report concludes that no adjustments are required to the housing target for draft GCLP to address affordable housing needs. This cannot be correct. The annual monitoring data shows that affordable housing delivery in Greater Cambridge does fluctuate each year, but does show that c.500 affordable dwellings are provided on average each year, which is less than the current need. In addition, some the existing strategic sites are not able to deliver policy compliant levels of affordable housing (e.g. Northstowe and Waterbeach new settlements) because of the need to provide significant amounts of new infrastructure, and it is anticipated that the outcome would be the same for the proposed strategic sites at North Cambourne and Grange Farm. If affordable housing needs are to be met then a higher housing target and additional allocations should be identified in draft GCLP to address the shortfall in the delivery of affordable housing from the existing and proposed strategic sites. It is considered that the housing target in Policy S/JH should include some upward adjustment to address affordable housing needs.

The representations to Appendix D deal with the part of Policy S/JH that relates to the housing requirements for neighbourhood plan areas.

Requested Change

The following changes to Policy S/JH are requested.

It is requested that the housing target is recalculated to include the previous commuting patterns adjustment, consistent with the adjustment made in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report.

It is requested that the housing target includes some upward adjustments for growth ambitions, that reflect the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal, the draft Local Growth Plan of the Mayor for Peterborough & Cambridgeshire, and the Cambridge Growth Company.

It is requested that housing target include some upward adjustment to address affordable housing needs.

Consistent with the representations to Appendix D, a new policy is required in draft GCLP to ensure that the housing requirements for neighbourhood plan areas are delivered.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet development needs.

It is requested that additional allocations are made in the more sustainable villages, including Fulbourn.

Policy S/DS: Development Strategy

Object

Policy S/DS of draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed.

Most of the existing 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. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm would also be reduced for the same reasons.

It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. It is requested that land is released from the Green Belt to meet development needs.

The Minor Rural Centres, including Fulbourn, are referred to as part of the development strategy but there are limited allocations in this category of settlement. It is considered that the growth of the more sustainable villages should be part of the development strategy for draft GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. Fulbourn falls within this category.

KG Moss Will Trust has promoted land off Home End in Fulbourn, and the Moss Family has promoted land at Court Meadows House off Balsham Road in Fulbourn. These promoted developments would support the existing services and facilities in the village. They are a small and medium sized sites that could be delivered relatively quickly. The sites are accessible by sustainable modes of transport. The sites would deliver affordable housing to meet the identified needs for the village.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet development needs.

It is requested that additional allocations are made in the more sustainable villages, including Fulbourn.

Policy S/SH: Settlement Hierarchy

Comment

Policy S/SH of draft GCLP defines the settlement hierarchy. KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn. Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. Minor Rural Centres have an indicative maximum scheme size of 30 dwellings within the defined development extents of those villages.

Fulbourn 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 Greater Cambridge Partnership is delivering a greenway (walking and cycling route) between Fulbourn and Cambridge. It is appropriate for Fulbourn to be defined as a Minor Rural Centre.

However, there has been no review of the capacity of settlements to accommodate additional development for draft GCLP, or whether the development threshold limits remain relevant if no sites are available. The allocation at the Ida Darwin Hospital site and the committed development off Teversham Road in Fulbourn are being delivered and will be completed in the short term. There appears to be no other major residential development opportunities within the development framework boundary of Fulbourn, and any development opportunities that do exist would be small scale and would not deliver affordable housing or provide any meaningful support to existing services and facilities. In these circumstances, the indicative maximum scheme size of 30 dwellings for Minor Rural Centres is irrelevant to Fulbourn.

As set out in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Fulbourn to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.
Requested Change

It is requested that a review is undertaken of the capacity of the more sustainable settlements in South Cambridgeshire, including Minor Rural Centres such as Fulbourn, to determine whether additional development can be accommodated within the existing development framework boundary, and whether the development threshold limits remain relevant if no sites are available. If the indicative maximum scheme size limits are no longer relevant they should be deleted.

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs then additional allocations should be made on the edge of those villages.

Policy S/DE: Defined Development Extents

Comment

Policy S/DE of draft GCLP set out the approach to development within and outside the defined development extents of villages. KG Moss Will Trust and the Moss Family do not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire, including Fulbourn, have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018. In Fulbourn, heritage assets, protected village amenity areas, local green space and important countryside frontage designations restrict development opportunities within the settlement boundary, and the Green Belt restricts development outside the settlement boundary. The made Fulbourn Neighbourhood Plan (March 2023) does not allocate any land for development, and could not allocate land on the edge of the village because the adopted South Cambridgeshire Local Plan 2018 did not support the release of land from the Green Belt through the neighbourhood plan process.

The currently defined development framework boundary for Fulbourn means that limited development would take place in this village. The housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities. The community aspirations (in the made Fulbourn Neighbourhood Plan) for open space, improvements to health facilities, and for additional green infrastructure would not be met.

No changes are requested to Policy S/DE. However, as set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Fulbourn to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Policy S/GB: The Cambridge Green Belt

Object

Policy S/GB of draft GCLP sets out the Green Belt policy for Cambridge. Paragraph 143 of the NPPF sets out the five national purposes for Green Belts. The second purpose listed in Paragraph 143 states “b) to prevent neighbouring towns merging into one another;”. The third purpose for the Cambridge Green Belt in Policy S/GB states “1c. prevent communities in the environs of Cambridge from merging into one another and with the city”. Purpose 1c in Policy S/GB is inconsistent with the second purpose in NPPG Paragraph 143 i.e. it refers to communities and not towns. Consistency with national policy is one of the soundness tests for local plan policies. The reference to communities rather than towns could have implications for how inappropriate development in the Green Belt is assessed and the implementation of grey belt policy at planning application stage.
KG Moss Will Trust has promoted land off Home End in Fulbourn, which is currently located within the Green Belt. The character of the site and the surrounding area means that the site does not meet the Green Belt purposes. It is requested that this land is removed from the Green Belt.

The Moss Family has promoted land at Court Meadow House off Balsham Road in Fulbourn, which is located within the Green Belt. It is considered that this land would meet the definition for grey belt land, as set out in Chapter 13 and Annex 2 of the NPPF and in Section Id.64: Green Belts of the Planning Practice Guidance. The site does not strongly contribute towards Green Belt purposes (a), (b), or (d). The promoted development would not lead to the unrestricted sprawl of a large built-up area, it would not result in the coalescence of neighbouring towns, and it would not affect the setting and special character of a historic town. The site is not designated as a protected area, other than being within the Green Belt. It is requested that this site is identified as grey belt land.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Requested Change

It is requested that land off Home End in Fulbourn is removed from the Green Belt and is allocated with the following policy requirements:

• Site Area of 0.27 Ha
• Capacity for approx. 18 dwellings, including affordable housing
• Seek to retain trees and hedgerows at site boundary
• Design and layout to protect and enhance Fulbourn Conservation Area and other heritage assets

Policy S/RRA: Additional Allocation - Land off Home End, Fulbourn (Site Ref. 40523)

Object

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct development to the more sustainable villages, and there are exceptional circumstances to release land from the Green Belt. All these factors indicate that additional allocations should be made in draft GCLP to meet development needs.

KG Moss Will Trust has promoted land off Home End in Fulbourn (Site Ref. 40523). There are no significant constraints to development at this site. The site does not meet the criteria for designation as an Important Countryside Frontage because of the activities and uses that occur between the site and the countryside. The characteristics of the site and surrounding area mean that the site does not contribute towards the openness of the Green Belt or the purposes for including land within the Green Belt, and it should be removed from the Green Belt. The design and layout of the promoted development would need to protect and enhance the Fulbourn Conservation Area. The promoted development would include open space and green infrastructure. The site is accessible to the services and facilities in Fulbourn by walking and cycling, and it is accessible to Cambridge and to employment opportunities by bus and by bicycle. A drainage strategy, access appraisal, landscape appraisal, heritage assessment, ecological assessment, and archaeological assessment would be prepared for the promoted development at planning application stage. It is requested that this site is identified as an additional allocation in Policy S/RRA: Rest of Rural Area.

Requested Change

It is requested that land off Home End in Fulbourn is removed from the Green Belt and is allocated with the following policy requirements:

• Site Area of 0.27 Ha
• Capacity for approx. 18 dwellings, including affordable housing
• Seek to retain trees and hedgerows at site boundary
• Design and layout to protect and enhance Fulbourn Conservation Area and other heritage assets

Requested Change

It is requested that land at Court Meadows House off Fulbourn Road in Fulbourn is allocated with the following policy requirements:

• Site Area of 4.30 Ha
• Capacity for approx. 130 dwellings, including affordable housing and self/custom build plots
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at north eastern boundary
• Provide green infrastructure
• Protect the existing public bridleway at south eastern boundary

Policy S/RRA: Additional Allocation - Land off Balsham Road, Fulbourn (Site Ref. 40522)

Object

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct development to the more sustainable villages, and there are exceptional circumstances to release land from the Green Belt. All these factors indicate that additional allocations should be made in draft GCLP to meet development needs.

The Moss Family has promoted land at Court Meadows House off Balsham Road in Fulbourn (Site Ref. 40522). The site area for the promoted development was reduced in November 2021 to address potential impacts on landscape character, the setting of listed buildings, and the Green Belt. The promoted development would include a significant amount of green infrastructure and strategic landscaping. The promoted development would retain the trees and hedgerows at the site boundary and would include additional landscaping to avoid impacts on the character of the area. The promoted development at the site would have no adverse impact on the compactness or setting of Cambridge and it would not lead to the merging of towns. The site makes a limited contribution to the purposes for including land within the Green Belt. The promoted development would include open space and green infrastructure. The site is accessible to the services and facilities in Fulbourn by walking and cycling, and it is accessible to Cambridge and to employment opportunities by bus and by bicycle. A drainage strategy, transport assessment, landscape appraisal, ecological assessment, and archaeological assessment would be prepared for the promoted development at planning application stage. It is requested that this site is identified as an additional allocation in Policy S/RRA: Rest of Rural Area.

Requested Change

It is requested that land at Court Meadows House off Fulbourn Road in Fulbourn is allocated with the following policy requirements:

• Site Area of 4.30 Ha
• Capacity for approx. 130 dwellings, including affordable housing and self/custom build plots
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at north eastern boundary
• Provide green infrastructure
• Protect the existing public bridleway at south eastern boundary

Policy BG/GI: Green and Blue Infrastructure

Comment

Policy BG/GI of draft GCLP seeks to protect and enhance green and blue infrastructure, and identifies a number of strategic green infrastructure initiatives. It is anticipated in Policy BG/GI that major development should provide financial contributions towards projects related to one of those green infrastructure strategic initiatives. KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn. Policy BG/GI identifies a green infrastructure strategic initiative at No.4 Enhancement of Eastern Fens, which is located to the east of Fulbourn. It is noted that the made Fulbourn Neighbourhood has a policy and community aspirations to increase the green infrastructure network.

KG Moss Will Trust and the Moss Family supports in principle initiatives to improve the green infrastructure network around Fulbourn. The promoted developments by KG Moss Will Trust and the Moss Family would include green infrastructure if these sites were allocated in draft GCLP.

It should be noted that there are no allocations identified in draft GCLP for Fulbourn that could make financial contributions towards the proposed green infrastructure strategic initiative at No.4 Enhancement of Eastern Fens. It is not clear how this initiative would be delivered effectively in the absence of related development. It is considered that draft GCLP needs to better align the development strategy and site allocations with the proposed strategic green infrastructure initiatives, in order to ensure that the initiatives are implemented.

No changes are requested to Policy BG/GI. However, as set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Fulbourn. This approach could support the delivery of green infrastructure at Fulbourn, and contribute towards the green infrastructure strategic initiative at No.4 Enhancement of Eastern Fens.