Greater Cambridge Local Plan: Proposed Submission

1. That a further Grey Belt Assessment is carried out to align with national policy and provided a justified basis. Or failing that,
2. That the Local Plan makes it explicit in para 2.137 that the 2026 GBA should carry little weight in any future decision as to definitive classification as grey belt or that the inclusion of FD3 and FD7 as provisional grey belt in the Plan should equally carry little weight.
3. That para 2.137 is reworded to include the phrase “provisionally identify”

25.1 FDPC supports in principle Policy S/GB: The Cambridge Green Belt. However, para 2.137 of the
supporting information states that “The Cambridge Green Belt Assessment (2021) and the Cambridge Green Belt Assessment Review following changes to National Policy and Guidance (2026) assess the contribution of different parcels of land to these purposes and identify grey belt land to inform plan making…”.
25.2 There is an issue with the methodological approach that has been taken by the 2026 Green Belt
Assessment (‘GBA’).
25.3 The starting point is that the GBA has attempted to continue the approach taken in the 2021 Greater Cambridge Green Belt Assessment (GCGBA) and simply ‘refresh it’ to take account of the new concept of Grey Belt. There are several issues with this.
25.4 The first is that the GCGBA followed the historic pattern of focusing on the three historic Cambridge Purposes (Purpose 1, 2 and 3) rather than the five purposes of the NPPF. It is appreciated that this approach has previously been tolerated, but it is no longer fit for purpose when faced with the new definition of Grey Belt.
25.5 This is because the definition of Grey Belt – inherently central for identifying Grey Belt –
requires that land does not contribute strongly to any of ‘of purposes (a), (b), or (d)’. There is
therefore a need for assessments to look at each purpose individually because even if land didn’t contribute strongly to two out of the three purposes, if it contributed strongly to the third then it would not be Grey Belt. There is an inherent need to therefore assess each purpose individually.
25.6 However the 2026 GBA has not done this but instead – as is made clear between 3.14 – has only considered whether parcels contribute strongly to Purpose D. Not only does that fail to recognise their own findings – see Table 3.1 at page 44 of GCGBA - that Cambridge Purpose 1 aligns with NPPF purpose (a), and Cambridge Purpose 3 aligns with NPPF purpose (b), but it is fundamentally inconsistent with national policy which requires grey belt be identified by examining all three purposes.
25.7 Fundamentally this first issue means that the 2026 GBA does not actually identify Grey Belt. It simply identifies land which does not strongly contribute to purpose (d). But that is not Grey Belt and there is a real concern that if this document is relied upon at local plan stage to establish – even provisionally – grey belt then it will be relied upon as such in the future. Even though it has not examined the other two relevant purposes.
25.8 On this issue alone the evidence is unjustified.
25.9 The second issue is that – by attempting to carry across findings from the 2021 GCGBA – the GBA has mistranslated its own findings.
25.10 This is a point of particular concern with the areas of Grey Belt for Fen Ditton (FD3 and FD7). Both these Sites were classified as ‘moderate-high’ in the 2021 GCGBA.
25.11 The 2026 GBA makes clear at 5.5 that it equates those sites which were found to be ‘moderate-high’ harm rated parcels in the 2021 GCGBA to having only a moderate contribution to Purpose D given they do not make a ‘considerable’ contribution (relying on the PPG).
25.12 However this fails to engage with the findings of the 2021 GCGBA. We will use FD3 as an example.
This is provided at Table 3.6 on page 105. “Moderate-high’ harm is defined as one of two things:
ReleaseoflandresultsinalossofstrongcontributiontooneoftheGreenBeltpurposes,
but would constitute a negligible impact on adjacent Green Belt land;
or Release of land results in a loss of relatively limited contribution to one of the Green
Belt purposes, and would constitute a moderate impact on adjacent Green Belt land.
25.14 So – on the terms of this definition – the relevant question for the 2026 GBA is which of those
categories the land falls into. If it is the first part of the definition (strong contribution to purposes
but negligible impact on adjoining land) then it is not Grey Belt. If it is the second part (limited
contribution but moderate impact on adjoining) then it could be said to be Grey Belt.
25.15 The point is the ‘rating’ system in the 2021 GCGBA took into account impact on adjacent land
– which is not relevant to the Grey Belt definition.
25.16 In terms of Parcel FD3, it is found to have had a ‘Relatively Significant’ contribution to
Cambridge Purpose 2 (which equates to NPPF Purpose D). However, it only makes a limited impact
on contribution of adjacent Green Belt. This is captured by the site specific assessment summary:
Parcel FD3 makes a relatively significant contribution to maintaining and enhancing the
quality of Cambridge’s setting and a relatively limited contribution to preserving
Cambridge’s compact character. The additional impact on the adjacent Green Belt of the
release of the parcel would be minor. Therefore, the harm resulting from its release, as an
expansion of Fen Ditton, would be moderate high.
25.17 It therefore falls into the moderate-high definition because while it makes a strong
contribution to Purpose D, it would only have a limited impact on adjoining Green Belt.
25.18 The critical point being the element of the ‘moderate-high’ definition that is relevant to
Grey Belt is that it was found in the 2021 GCGBA to make a strong contribution to Cambridge
Purpose 2 (and thus NPPF Purpose D). But – and this is where the error lies – because the 2026
GBA has not recognised the role that ‘impact of adjoining Green Belt’ has played in the 2021
‘Moderate-High’ rating it has been wrongly classified as provisional Grey Belt.
25.19 It can be noted in this regard that the other parcels assessed as a ‘Relatively Significant’
contribution to Purpose 2 in the 2021 GCGBA – FD1, FD4, FD5, FD6 – have all been considered in
2026 GBA to not be Grey Belt.
25.20 This is an error that would not have occurred had LUC done what was required, and carried
out a fresh assessment against the relevant Green Belt purposes for determining the Grey Belt
definition. They have not done so and attempted to rely on translating over findings from the
2021 GCGBA. But that has been done in a manner which is not justified.
25.21 The issue for the Examination is that this assessment is being relied upon to provisionally
define Grey Belt going forward. This could have significant development ramifications. But it has
been done in an unjustified way which fails to properly define Grey Belt.
the key evidence base (the 2026 GBA) is neither justified nor consistent with national policy. It
has – quite simply – failed to properly apply the definition of Grey Belt by only focusing on one
purpose (D) and compounded the error by mistranslating over findings from the 2021 GCGBA.
25.23 Furthermore para 2.137 is inconsistent with Figure B.19 of the latter document shows 2
areas, FD3 and FD7, which are described as “Provisional Grey Belt - Moderate contribution to
purpose D” and Topic Paper Appendix 4: Revised Greater Cambridge Local Plan Green Belt which
statesinpara4.1“…assessmenttoidentifylandthatcouldprovisionallybeconsideredgreybelt…”.
The absence of the term provisional in para 2.137 is very important because the 2026 document
above is erroneous or misleading in that:
1) On page 26, CWWTPR is listed as a new extant permission but the Red Line boundary
shown on Figure 4.10 is in error because it does not match the approved LOCATION AND
SCHEME ORDER LIMITS PLAN REGULATION 5(2)(o)00001-100006-CAMEST-ZZZ-LAY-Z-
9816 REVC02.
2) Figure B.19 shows an area labelled FD3 which includes the village Recreation Ground
and Cemetery and part of the Fen Ditton Conservation Area.
25.24 Greater Cambridge Green Belt Assessment Response to comments from Site Submissions
Update and Draft Local Plan Consultation contains responses to comments on both FD3 and FD7
which indicate that neither can be considered grey belt in their entirety.