Draft Greater Cambridge Local Plan for consultation

The Council has not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across mix the Plan period.

Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. We are very concerned that the draft strategy for the Plan (Policy
S/DS) relies very heavily on allocating significant dwelling numbers on a small number of very large sites.
These sites rely on the timely provision of strategic scale infrastructure which must be in place before these
sites can be delivered.

The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (6,000 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway on the adjacent side of the A505.

The Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We believe this is
highly unlikely.

Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that this approach sets the Council on a path of over-reliance on these sites which is
problematic for the following reasons:
1. The speed at which these developments can deliver homes is often far slower than the Council
has envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the
large strategic sites in the current Development Plan, may now be delivering at an appropriate
rate, however they came on stream several years later than anticipated.
2. The Council has not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across mix the Plan period.
3. The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be sustainable
locations in the rural area such as Papworth Everard, a Minor Rural Centre, and which is clearly
capable of delivering an appropriate scale of development (ie: indicative scheme size of 30
dwellings as set out in the draft local plan).

See attached our full representations.

The scale and large extent of the draft allocation S/SEA/CBN is disproportionate and covers land that could sustainably accommodate future development without compromising the separation of Papworth Everard and Cambourne North.

We therefore request that the Council engage with the landowner and remove or revise the allocation.

On behalf of our client, Varrier-Jones Foundation (“VJF”), we are responding to the Regulation 18
consultation on the emerging Greater Cambridge Local Plan (“the Plan”). This representation objects to
the proposed draft allocation (ref: S/SEA/CBN), which designates a large area of land to the east of
Papworth Everard as non-developable in connection with the adjacent Cambourne North draft allocation
(ref: S/CBN).

VJF owns and controls land in and around Papworth Everard. The proposed designation has significant
implications for the landowner’s interests and the Plan’s ability to deliver sustainable growth.

Draft policy S/CBN requires development at Cambourne North to deliver a well-considered landscape
buffer within the Strategic Enhancement Area (S/SEA/CBN), intended to respond sensitively to
neighbouring villages and their Conservation Areas, deliver landscape and ecological enhancement, and
avoid settlement coalescence.

The proposed Strategic Enhancement Area extends across a substantial area of open agricultural land
and is designated as wholly non-developable. The emerging local plan states that this land is required to
provide an appropriate setting for nearby Conservation Areas, support farmland birds and other species,
and maintain a soft, green landscape between Cambourne North and surrounding settlements, including
Papworth Everard, Elsworth, Knapwell, Bourn Airfield New Village and Childerley. While these aims are
broadly reasonable, the Plan does not demonstrate that the full extent of the land designated is necessary
to achieve them and does not account for landownership.

In heritage terms, the evidence indicates that the density of designated heritage assets north of the A428
is low, with the principal concentrations located at Elsworth, Knapwell and Childerley Park. In Papworth
Everard, the conservation area and heritage assets are located primarily within the central and western
parts of the village, rather than on the eastern edge closest to the proposed Cambourne North
development. As such, there is no clear heritage-based justification for the extent of land included within
the S/SEA/CBN designation in order to protect the setting of Papworth Everard.

The emerging local plan does not explain why more targeted landscape buffers, design-led mitigation, or
selective development restraint could not achieve the same outcome. The designation of a broad,
continuous non-development area risks acting as a precautionary constraint rather than a proportionate
response to identified impacts. The supporting Topic Papers for the emerging Greater Cambridge Local Plan do not include a dedicated study on settlement separation or strategic gap analysis for the S/SEA/CBN allocation. In this case there is no published Topic Paper demonstrating why the full extent of the S/SEA/CBN non-development area is necessary to prevent coalescence between Papworth Everard and Cambourne North, nor why smaller, targeted buffers or other landscape solutions were discounted.

As Cambourne North is delivered, Papworth Everard will become increasingly well connected to jobs, services and infrastructure, strengthening its role as a sustainable settlement capable of accommodating future growth. The blanket designation of extensive land as non-developable within S/SEA/CBN risks unnecessarily constraining longer-term development opportunities without clear evidence that such restriction is essential to maintain settlement separation.

The land affected by the S/SEA/CBN designation sits in close proximity to existing employment uses, including the established Papworth Business Park, where a number of commercial tenants are currently operating successfully. It is understood that tenants have expressed interest in expanding their operations in the medium to longer term, reflecting the attractiveness of the location and the availability of an existing workforce.

The blanket designation of extensive areas of land as non-developable within the Strategic Enhancement Area risks constraining the future growth and expansion of these existing businesses. This is particularly concerning given that national and local planning policy seeks to support the retention and growth of employment uses, promote economic resilience, and ensure that Local Plans provide sufficient flexibility to respond to changing economic circumstances.
In particular, paragraph 85 of the adopted National Planning Policy Framework (2024) states that “planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development”. Paragraph 86 further emphasises that planning policies should be “flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances”. Together, these policies establish a clear expectation that Local Plans should provide sufficient flexibility to support business growth. The ongoing draft NPPF consultation reinforces this direction of travel, continuing to place strong emphasis on supporting economic resilience and adaptability.

The Strategic Enhancement Area (SEA) extends onto a swathe of land owned by VJF to the edge of Papworth Everard, yet there has been no discussion by the Council or promoter with VJF about this. Any policy dependency on the SEA land performing or delivering certain things across the VJF part of the SEA is not deliverable and cannot be relied on. The effectiveness of the policy and the degree of environmental enhancement promoted by the Cambourne North allocation is brought into serious question. The SEA must be rolled-back from Papworth Everard to avoid the VJF land if the Council wish to demonstrate a sound and deliverable Cambourne North allocation.

We request that the Council engage with the landowner, remove the proposed Protected Open Space allocation at Park at St Peter’s Lane from draft policy BG/PO, and recognise that general development management policies provide adequate control over the land set against the quality and characteristics of the land.

On behalf of our client, Varrier-Jones Foundation (hereafter “VJF”), we are responding to the Regulation
18 consultation on the emerging Greater Cambridge Local Plan (hereafter “the Plan”). This representation
objects to the proposed draft allocation of Protected Open Space (Parks and Recreation Space
subcategory) on land owned by VJF within the village of Papworth Everard, Cambridgeshire.

The land in question lies on the south-western edge of the settlement, immediately adjacent to the
settlement framework, with the A1198 bypass forming its outer boundary, referred to as Park at St Peter's
Lane.

Papworth Everard is currently served by a number of designated local green spaces under the adopted
South Cambridgeshire Local Plan 2018. These include:
● Papworth recreation Ground - community green space located within the village, providing formal
and informal recreational opportunities;
● Jubilee Green - public open space situated centrally in Papworth Everard. It is used for informal recreation, children’s play, and community events;
● Papworth Hall - adjoining open grounds act as a recreational and amenity space that is used by
residents for informal activities with mature planting;
● Meadow at western end of Church Lane - open field of grassland situated on the edge of the settlement
offering informal recreational space;
● Papworth Wood (SSSI) – an 8.7-hectare Site of Special Scientific Interest woodland with public access
from near the hospital grounds, offering biodiversity and informal recreation.
Papworth Everard also benefits from several areas designated as protected village amenity areas located
across the settlement.

There are currently no allocations for future development of housing in Papworth Everard, so the question
is raised why additional protected open space allocations have been proposed within the draft local plan,
especially in regard to the large extent of land to the south west (Park at St Peter's Lane).

South Cambridgeshire Sustainability Appraisal Report Appendix 12, titled “Review of Proposals for Local Green Space, Protected Village Amenity Areas and Important Countryside Frontages”, forms part of the adopted South Cambridgeshire Local Plan evidence base. It was prepared as an appendix to the Initial Sustainability Appraisal Report in support of the Issues and Options consultation undertaken in 2012–2013. The proposed allocation at Park at St Peter’s Lane was not included or assessed within this earlier open space assessment, and therefore did not form part of the evidence used to justify open space designations in the adopted South Cambridgeshire Local Plan. As such, there is no historic assessment demonstrating that the site meets the relevant policy tests for protection as local green space or protected village amenity area under the adopted South Cambridgeshire Local Plan.

As part of the First Conversation consultation in 2020, a Call for Sites consultation was held including submissions for green space. Upon reviewing the sites submitted to the Call for Green Sites, no land within Papworth Everard was put forward for consideration. Consequently, no sites located in Papworth Everard were assessed as part of the Green Infrastructure evidence base study commissioned by the Councils. In the absence of any site submissions, the study did not undertake an appraisal of potential new or enhanced green spaces within the village, and no conclusions were drawn regarding the suitability, deliverability, or need for additional green infrastructure in this location.

The emerging Greater Cambridge Local Plan has reviewed protected open spaces and introduces a new supporting Topic Paper, which replaces and expands upon earlier South Cambridgeshire assessments. This updated evidence base is therefore the relevant material for assessing new or amended open space allocations. Topic Paper 3: Biodiversity and Green Spaces specifically references the proposed allocation ZP&G 045 – Park at St Peter’s Lane and explains that sites designated as Protected Open Space must demonstrate either environmental or recreational importance.

However, the justification for the proposed allocation at ZP&G 045 remains unclear, as whilst Topic Paper 3 identifies new sites it does not provide a site-specific assessment demonstrating how this land meets the required criteria.

A significant area of Papworth Everard, Park at St Peter’s Lane, has been allocated under draft policy BG/PO for Protected Open Space. As a Park and Garden designation, it is intended to be retained and safeguarded for public recreation, amenity and green space use, restricting development in these areas.

Part of the land proposed for the Protected Open Space allocation was previously promoted for residential development (HELAA site ID: 115352). At present, the land has no open space designation within the adopted Local Plan. Draft Policy BG/PO requires Protected Open Space to demonstrate either environmental or recreational importance in order to justify its designation.

The land was assessed through the HELAA process and received a ‘red’ score, primarily due to concerns regarding landscape impact and potential encroachment into the countryside. It is noted that the HELAA submission related to a larger area of land, including land to the north of the proposed Protected Open Space allocation at Park at St Peter’s Lane, rather than the precise extent of the draft designation.

An Ecological Report previously submitted by Applied Ecology Ltd concluded that adverse impacts on the nearby SSSI are unlikely, indicating that the land itself does not perform a specific environmental protection function. The land is not located within the Green Belt, and while priority habitats are present within the area of land, these are capable of mitigation and enhancement, with biodiversity net gain capable of being delivered through development.

The land is under private ownership and does not function as formal public open space. While a public right of way footpath crosses the site, this provides only pedestrian passage and does not grant recreational use or public open space status. If the site were to be developed in the future, there is significant potential to enhance public recreational use. Development could incorporate formal public open space, improved pedestrian and cycle access, landscaping, and recreational facilities, creating a safe and accessible environment for the community.

Although the site lies adjacent to the Conservation Area, this relationship alone does not confer recreational or environmental importance and certainly not in a manner that necessitates some heightened policy protection of the land. There is no adopted neighbourhood plan or other community-led evidence identifying the land as valued open space or demonstrating a local need for its protection.

Taken together, the evidence suggests that the allocation of the site as Protected Open Space is largely derived from HELAA landscape and countryside impact considerations, rather than from demonstrable recreational use or intrinsic environmental importance. These matters are not special, insofar they relate to huge swathes of open countryside across the District. As such, the justification for designation under draft policy BG/PO appears to rely on development constraint evidence rather than on the policy tests required for Protected Open Space designation.
The land at St Peter’s Lane is well-located relative to existing services, schools, and public transport links to Cambridge, including bus routes and cycling connections. Its draft designation as protected open space restricts opportunities to provide much-needed housing in a village that can sustainably accommodate growth.

The draft Plan and associated evidence base do not demonstrate that the Park at St Peter’s Lane is of exceptional historic, ecological, or recreational value that would warrant full protection under the draft allocation. Without robust evidence, the designation risks unnecessarily constraining the Local Plan’s ability to deliver future housing in this area.