Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options

Representations to Sustainability Appraisal of Issues & Options (December 2019)

The Sustainability Appraisal (SA) of the Issues & Options consultation document includes an assessment of a range of spatial distribution options, which are as follows:
• Option 1: Densification;
• Option 2: Edge of Cambridge – Outside the Green Belt;
• Option 3: Edge of Cambridge – Green Belt;
• Option 4: Dispersal – new settlements;
• Option 5: Dispersal – villages; and
• Option 6: Public transport corridors.

It is acknowledged in the SA the preferred spatial distribution strategy may be based on a combination of these options, but the assessment is based on each option individually. It is considered that some of the commentary on each of the spatial distribution options and likely effects is not correct, and it is requested that a more detailed analysis of the options is required in the SA for the Draft Greater Cambridge Local Plan.

The North Barton Road Landowners Group (North BRLOG) is promoting land at South West Cambridge which is located within the Green Belt; the site would fall within Option 3: Edge of Cambridge – Green Belt. The findings of technical work undertaken to support the promoted site at South West Cambridge will be referred to in these representations where relevant.
The following representations are focussed on the SA of the spatial distribution options at Paragraphs 3.38 to 3.119 and associated tables including Table 3.1.


General Comments

It is acknowledged in the SA that the scale of development, its design, and associated impacts will depend on the circumstances present at individual sites. It is considered that strategic sites will need to include appropriate services and facilities to meet local needs and capacity, and will need to be well-designed and include mitigation measures and enhancements to address impacts, but there is no reason why these matters cannot be satisfactorily addressed. For example, a Vision Document has been prepared for the promoted development at South West Cambridge, which has been designed to take into account landscape, heritage and ecological impacts. Mitigation measures are included to address any adverse impacts. Ecological and flood risk/drainage enhancements are provided, and the proposal includes a local centre and primary school and open space and recreation areas.
Therefore, the promoted development at South West Cambridge is capable of delivering positive outcomes when assessed against the sustainability objectives.


SA Objective 1: To ensure that everyone has the opportunity to live in a decent, well-designed, sustainably constructed and affordable home

It is not certain when Option 2 (Edge of Cambridge – Outside the Green Belt, which relates to development at Cambridge East) will be available for development because the existing uses need be relocated, and it is also not certain whether development at the site will provide policy compliant levels of affordable housing. The existing operations and businesses at Cambridge Airport will need to be relocated prior to the commencement of development. The Wing development at Cambridge East, for example, is required to provide 30% affordable housing against a policy requirement for 40%. It is requested that the assessment of Option 2 against the criteria for SA1 needs to take into account these factors.

It is incorrect to assume that Option 3 (Edge of Cambridge – Green Belt) do not deliver policy compliant levels of affordable housing. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG) demonstrates 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. It is requested that the assessment of Option 3 against the criteria for SA1 needs to take into account the fact that such sites are capable of providing policy compliant levels of affordable housing.

It is agreed that Option 4 (Dispersal – new settlements) do take a long time to be delivered largely because such developments are complex, and it is noted that initial predictions about the lead-in timetable for the delivery of new settlements are often unrealistic. It is also relevant to SA1 that new settlements typically do not deliver policy compliant levels of affordable housing; the amount of affordable housing provided and proposed in the initial phases of Northstowe and Waterbeach are examples where this has occurred. It is requested that the assessment of Option 4 against the criteria for SA1 needs to take into account realistic assumptions about lead in times for new settlements which will affect the supply of housing and affordable housing, and the fact that such developments are not capable of providing policy compliant levels of affordable housing.


SA Objective 12: To minimise Greater Cambridge’s contribution to climate change

It is considered that the assessment of effects for Option 3 (Edge of Cambridge – Green Belt) includes negative commentary about the accessibility of edge of Cambridge sites by sustainable modes of transport, although it is acknowledged that these locations score well against this objective. The outcome of those effects will to a certain extent depend on the strategic sites selected.

It should be noted for the SA for the Draft Greater Cambridge Local Plan that the area to the west of Cambridge is the focus for a number of proposed and potential transport infrastructure projects i.e. Cambourne to Cambridge Bus Corridor, Comberton Greenway, Barton Greenway, Madingley Road Cycle Improvements, and Cambridge Autonomous Metro. It is considered that the promoted site at South West Cambridge is well related to all of these proposed and potential projects; the Cambourne to Cambridge Bus Corridor, Comberton Greenway, Barton Greenway are either within or immediately adjacent to the site.