Question 39. Should we look to remove land from the Green Belt if evidence shows it provides a more sustainable development option by reducing travel distances, helping us reduce our climate impacts?

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Yes. Paragraph 136 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. Therefore, it is appropriate to consider whether to review Green Belt boundaries through the emerging GCLP. 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 and the need to support economic growth. Paragraph 137 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. Paragraph 138 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 considered that Histon and Impington are well served by public transport. Land South of Milton Road, Impington should be released from the Green Belt as it provides an opportunity to deliver a Community Park of 4.8ha. This would help to address the existing and significant deficit (10.75ha) that there is for open space within Histon and Impington whilst delivering much needed new homes, including affordable homes, within Greater Cambridge. The site is also in a sustainable location with good public transport links. The proposals for the site would also include measures to increase its accessibility for pedestrians and cyclists, improving the site’s sustainability credentials. Additionally, the developer, Flagship, are a Housing Association (registered charity) whose purpose is to provide homes for people in need. They maintain their own housing stock and support the communities which they are part of. In addition to the delivery of the Community Park described above Flagship are committed to delivery 50% affordable housing on this site. Paragraph 134 of the NPPF states that the Green Belt serves five purposes: a) to check the unrestricted sprawl of large built-up areas; Response: The site is located on the north eastern edge of the village of Impington. Impington and Histon are villages which fall within the Cambridge Green Belt although they are located to the north of the city and are physically separated from it by the A14. The proposals comprise a total area of 7.8ha, with the proposed residential element comprising just 3ha, and are not, therefore considered to represent unrestricted sprawl. b) to prevent neighbouring towns merging into one another; Response: Milton is the closest neighbouring village to the application site and is located 2km to the east. The proposals will not, therefore, result in the merging of two neighbouring villages. c) to assist in safeguarding the countryside from encroachment; Response: The Landscape and Visual Assessment submitted with the previous application for the site demonstrated that the proposals could incorporate numerous mitigation measures that would assist in integrating the proposed development into the surrounding countryside. Additionally, the community park would allow for increased opportunities for recreational use of the countryside which is encouraged by paragraph 118 of the NPPF and a number of other themes of the emerging LP. d) to preserve the setting and special character of historic towns; and Response: The South Cambridgeshire Local Plan confirms that one of the specific functions of the Cambridge Green Belt is to preserve the setting and special character historic towns. Land South of Milton Road, Impington is removed from the city of Cambridge and the proposal will not have any impact on its setting or special character. Detailed proposals for the site would be designed with the special character of the villages of Histon and Impington in mind. Accordingly, the proposals will not have a detrimental impact on the setting of special character of Histon and Impington. e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Response: As set out above, 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.

Yes

7.4 Yes. Paragraph 136 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. Therefore, it is appropriate to consider whether to review Green Belt boundaries through the emerging GCLP. 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 7.5 Paragraph 137 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. 7.6 Paragraph 138 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. 7.7 Paragraph 141 seeks the beneficial use of Green Belt land including to provide access, for outdoor sport and recreation, and to retain and enhance landscapes and biodiversity. It is considered that open space, strategic landscaping and ecological enhancements are examples that would represent a beneficial use of Green Belt land.

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27. The Green Belt provides an important role in preventing urban sprawl by keeping land permanently open and serving the five purposes set out in paragraph 134 of the National Planning Policy Framework namely: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns from merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 28. A comprehensive review of the original 2012 Green Belt Review should be undertaken as part of the evidence base underpinning the new Greater Cambridge Local Plan. In many instances there may be opportunities to release land currently within the Green Belt, which plays a limited role in serving the five purposes set out in the NPPF. 29. It is clear that given the geography of Greater Cambridge in which many of the most sustainable parts of the spatial planning area 9such as my client’s land within very close proximity of Foxton railway station, are located within the Green Belt, that some Green Belt release should form part of the overall spatial strategy. In this way, the area can help to reduce travel distances and help facilitate sustainability through the provision of sustainable transport infrastructure. Historically, much development has taken place in locations beyond the Green Belt, and this has led to many of the unsustainable commuting patterns that we see today. 30. While the important role that the Green Belt plays is acknowledged, a flexible approach needs to be taken where sites such as my client’s land at Foxton benefit from its proximity to existing frequent public transport (with the railway station immediately adjacent to the site). The proposed Melbourn Greenway being promoted by the Greater Cambridge Partnership (GCP) would also to provide high quality sustainable transport infrastructure to further improve connectivity. 31. The land, which comprises two sites is very well-contained and provides a very limited contribution to the Green Belt purposes. Its release would play no role in facilitating unrestricted sprawl of large built up areas and would not result in towns merging into one another. 32. Summary: Sites like my client’s land at Foxton should be released from the Green Belt.

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Southern and Regional Developments (Cottenham) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options across the plan area and reduce travel distances within communities so reducing climate impacts. They support the direction established by the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the site to the north east of Cottenham benefits from good access to social infrastructure, with close walking distance, with amenities to includes a medical clinic, secondary school, post office and village shop. As these are within close proximity to the site, it should be recognised that the site is a sustainable location to accommodate new development. Furthermore, the site is not designated Green Belt and so its development will not result in wider impacts or harm to the strategic purposes of it. As such, review of Green Belt sites alone will not go far enough in ensuring an adequate spatial strategy, given that there are suitable locations for development that exist beyond it and located in sustainable settlements that are able to and have the capacity to accommodate new development to meet the needs of the new Plan period. Summary of Comments: Releasing sites from Green Belt should be an element of wider and more comprehensive spatial strategy that includes other approaches.

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9.3.1 Gladman recognise that the Green Belt covers around 25% of South Cambridgeshire and adjoins much of the built edge of Cambridge. Gladman submit that the Councils should undertake the evidence base work, through the form of a Green Belt Assessment, to inform any decisions made regarding development options within the Green Belt. 9.3.2 In this regard, Gladman refer to paragraph 138 of the NPPF – “When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.”

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Southern and Regional Developments (Willingham) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options such as reducing travel distances and thereby reducing climate impacts. They support the direction established by the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. Releasing sites from Green Belt should be an element of wider and more comprehensive spatial strategy that includes other approaches. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the site at Priest Lane, Willingham, benefits from access to social infrastructure, which includes amenities such as a primary school and medical centre. These are within walking distance from the site and therefore should be recognised as demonstrating a sustainable location for new development. Furthermore, the Priest Lane site is not designated Green Belt and so its development will not result in wider impacts or harm to the strategic purposes of it. As such, review of Green Belt sites alone will not go far enough in ensuring an adequate spatial strategy, given that there are suitable locations for development that exist beyond it and located in sustainable settlements that are able to and have the capacity to accommodate new development to meet the needs of the new Plan period.

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7.1 The Local Plan could seek to find appropriate land for a further 30,000 dwellings on top of those sites allocated within the existing South Cambridgeshire District Council and Cambridge City Council Local Plans 2018. Cambridge is enclosed by its Green Belt, which covers approximately 25% of the Greater Cambridge area. Completely discounting this area will put pressure on the non-Green Belt land, which by its very nature is further from Cambridge. 7.2 The villages that are fully or partly surrounded by Green Belt are those that are located in close proximity to Cambridge and, therefore, bring significant opportunities for development of an appropriate scale given their location. In order to provide truly sustainable development contributing towards net zero carbon development, Green Belt sites must be considered as potentially suitable options. One of the proposed ‘big themes of the Plan is climate change, and appropriate release of Green Belt can assist in achieving this aim. Not considering Green Belt release would be contradictory to this big theme. This will require a Green Belt Review to be undertaken to assess appropriate sites/parcels. 7.3 In relation to the Site, Environmental Dimension Partnership Ltd has undertaken a Green Belt Assessment at the site, and this is appended to these representations. It confirms the Site makes a ‘Low Contribution’ when assessed against Green Belt purposes. Its release, therefore, is considered appropriate given the need to provide residential development in sustainable locations.

Yes

Southern and Regional Developments (Waterbeach) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options such as reducing travel distances and thereby reducing climate impacts. They support the direction established by the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. It is considered that given the significant pressures within Greater Cambridge to deliver a substantial number of homes in line with the economic growth experienced in the sub-region, there is a need to review the current extent of the Green Belt.The site at Bannold Road, Waterbeach, under the control of Southern and Regional Developments is a site that benefits from good levels of accessibility. Waterbeach is recognised as a Minor Rural Centre, a second tier settlement within the strategic hierarchy, it is considered that access to a mainline station in the village enhances its sustainability credentials in accommodating growth. Furthermore, given that much of the land at the fringe of the village is designated as Green Belt, the new Plan should review the status of this land in its suitability for release from it and to accommodate development. It is maintained that the land at Bannold Road, Waterbeach demonstrates such suitability given the beneficial access it experiences to the train station at the village, which provides important access to major job markets located a Cambridge North and Cambridge city. If the Plan does not robustly consider these options as deliverable components of the new spatial strategy, it is likely that the new Plan will be unable to identify sufficient suitable sites to meet the identified residential need for the new Plan period. Summary of Comments: Releasing Green Belt land at locations benefitting from public transport is supported and complies with the strategic objectives of the NPPF.

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Green Belt policy is predicated on the principle of permanence, and the Cambridge Green Belt has proved effective at protecting the historic landscape setting of the city of Cambridge for some 50 years. The Trust holds covenants on land to the west of Cambridge which pre-date the establishment of the Green Belt but which now benefits from Green Belt policy protection and has objected to the proposed Cambourne to Cambridge (C2C) busway north of Coton. We support well designed carbon neutral transport solutions that respect the Local Plan policy purpose of protecting the historic setting of Cambridge. However, we are strongly opposed to any breach in the Green Belt in this location and have expressed concerns about the agricultural viability of land severed by the proposal. Following the recent East West Rail preferred route announcement we are now calling for a review of the busway’s business case. See also our comments on Q 45.

No

• CambridgePPF strongly disagrees with this proposal. The NPPF Para 144 makes it unambiguously clear that development in the Green Belt can be regarded as appropriate only under ‘very special circumstances’. We do not see that ‘very special circumstances’ exist in Greater Cambridge given the large areas of land beyond the Green Belt. The arguments for Green Belt development were comprehensively debated before the Planning Inspector at the Examination in Public of the 2018 Plan and then rejected, and we can see no reason why the situation two years later should be any different. • Green Belts are important because they can provide opportunities for exercise and wellbeing, they can help to improve air quality, reduce flooding, capture carbon, and provide habitats for wildlife. They can also encourage the recycling of previously developed land within the city. And they give city residents access to countryside and informal greenspace on their doorstep. One of the reasons that Green Belts have popular support is because they improve the qualityof-life of people. Building on the Green Belt would be incompatible with the Big Themes suggested for the Local Plan. • The evidence-base for the 2018 Plan included a detailed review of the importance of the Inner Green Belt Boundary in meeting the stated objectives of the Cambridge Green Belt. This review identified a small number of sites where land might be released without causing unacceptable harm to the Green Belt. These sites were all included in the 2018 Plan and will be carried over into the 2023 Plan. The rest of the inner boundary was regarded as being of high importance and was accepted as such by the Planning Inspector. We can see no grounds for any change in this position. • Previous Local Plans allowed the development of Cambourne, which has proved to be largely a suburb of Cambridge located in the countryside with poor public transport/cycle connections to employment sites and central Cambridge (even car travel is not good due to the Girton Interchange not being 4-ways). Greater Cambridge is still grappling with the consequences of this, and it is not a model that we feel should be repeated. The 2018 Plan has already made the commitment to two large new settlements outside the Green Belt – Northstowe and Waterbeach. Both of these have the advantage over Cambourne of having pre-existing public transport infrastructure (guided busway/cycle and railway) and Waterbeach is also closer and therefore will be more cycle-able. Both settlements are planned to be larger than Cambourne and therefore will hopefully be more self-sustaining communities, less reliant on Cambridge. Such communities could prove to be no less sustainable than building on the Green Belt. We are concerned that the council’s thinking on new settlements is influenced by what happened at Cambourne rather than what will hopefully happen at Northstowe and Waterbeach.

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It is time for a fundamental review of the purposes of, function and land uses within the Cambridge Green Belt. The Green Belt has undoubtedly “preserved the unique character of Cambridge as a compact, dynamic city with a thriving historic centre”. It has also largely achieved its objective of “preventing communities in the environs of Cambridge from merging”. However, it has done both of these through the building of several major new settlements beyond the Green Belt boundary, increasing commuting, congestion, pollution and contributing to significantly increased carbon emissions. Many of the transport schemes to service this pattern of growth have been or will be highly damaging to the natural environment. Looking ahead, achieving the levels of proposed growth and new development related to the doubling GVA ambition in a sustainable manner is almost certainly incompatible with retention of the Green Belt in its current format. The third purpose of the Green Belt is to “maintain and enhance the quality of Cambridge’s setting”. It can be argued from a biodiversity and nature recovery network perspective (and perhaps less so from a landscape perspective) that the Green Belt has in large parts failed to enhance the quality of Cambridge’s setting. Most of the green belt is ecologically sterile intensively farmed countryside. Much of the land is owned for its future development potential with little prospect of being enhanced for nature and people. Positive nature and people friendly land uses cannot compete against this hope value on the open market. A more positive vision with tangible actions is required to enhance the Green Belt. This should be based on the enhancement of the biodiversity, landscape and natural environment around the city in order to deliver a nature recovery network. Should there be significant changes to the Green Belt it will be essential to enhance the remaining areas of Green Belt and consideration could be given to extending the green belt or future green wedges in defined areas to compensate for any losses required to achieve a more sustainable pattern of development. Such changes should support and contribute to the proposed Greater Cambridge Nature Recovery Network, which must be permanent.

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As set out above, government aspirations for the Arc are clear, and the combined authority can plan for a significant amount of housing and employment land. EWR represents an opportunity to unlock land that would previously have not been considered for development. This may include some Green Belt land. Recommendation The combined authority should factor the EWR preferred route option in developing its revised Green Belt policy.

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This can only be considered if an equal or greater area of greenbelt is added nearby but not if this results in green spaces been too far away from homes to be a pleasurable and convenient facility. Creating new greenbelt in an area far away from homes would not be a benefit. Generally, HIPC would support the idea of jobs being near workers if recreational facilities do not suffer. Before anything like this is considered, this must be presented to the community for their opinion.

No

• The Green Belt is there for important purposes, and development can only be appropriate under “very special circumstances”. It is important that Cambridge remains a compact, relatively small city with the Green Belt providing a green, rural setting, easily accessible. A detailed review of the inner Green Belt boundary was accepted by the Planning Inspector at the 2018 Plan. There can be no justification for this to change just two years later. • The Green Belt is also very important to the setting and character of Fulbourn, bringing the countryside right into the village, and providing important views out into the wider landscape. This was strongly supported by a Planning Inspector in 2016 when a proposal for housing development on land to the north of Lanthorn Stile was refused permission. • Sustainable development outside the Green Belt can be achieved without major climate impacts if the necessary carbon-free travel options are planned for.

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1.45 Our clients believe that it is inevitable that further land will need to be removed from the Green Belt to enable the delivery of the most sustainable form of growth for the Greater Cambridge area. However, the release of further sites on the fringes of Cambridge, especially those to the west, will result in substantial harm to the relationship between the historic core of the city and the surrounding countryside. Therefore, it is necessary for the Councils to look towards the most sustainable rural settlements that are still within reach of Cambridge by sustainable modes of travel when considering where to focus future housing growth. 1.46 Our clients’ site benefits from existing boundary landscaping that has the potential to be enhanced with further landscaping to screen new homes on the edge of the village. By accommodating water attenuation and open space to the north of the site it will provide a soft edge to the village whilst maximining the number of new homes that can be accommodated near to the services and facilities of the village. This will significantly limit any impact upon the openness of this part of the Green Belt. This approach to the development of the site will also mean that new residents will be within easy cycling distance of Cambridge and have access to enhanced cycle connectivity with the city so that their travel needs do further exacerbate global climate change and other more localised environmental impacts.

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1.43 Our client believes that it is inevitable that further land will need to be removed from the Green Belt to enable the delivery of the most sustainable form of growth for the Greater Cambridge area. However, the release of further sites on the fringes of Cambridge, especially those to the west, will result in substantial harm to the relationship between the historic core of the city and the surrounding countryside. Therefore, it is necessary for the Councils to look towards the most sustainable rural settlements that are still within reach of Cambridge by sustainable modes of travel when considering where to focus future housing growth. 1.44 With well screened sites like our client’s sites at Bennell Farm new homes can be accommodated by maximising the use of land with no loss of openness to the Green Belt in a sustainable location. New residents will be within easy cycling distance of Cambridge and have access to enhanced cycle connectivity with the city so that their travel needs do further exacerbate global climate change and other more localised environmental impacts.

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This option is likely to provide some sustainable options close to Cambridge where jobs services and other facilities are concentrated. However, the potential of the Green Belt to accommodate further growth will be determined by site=-specific considerations including environmental constraints, access to public transport and the ability to integrate with the city. These issues need to be weighed against the impact on the functions of the Green Belt, and a comparison with other options that avoid development of Green Belt land.

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5.1 The Local Plan should seek to find appropriate land for a further 30,000 dwellings on top of those sites allocated within the existing South Cambridgeshire District Council and Cambridge City Council Local Plans 2018. Cambridge is enclosed by its Green Belt, which covers approximately 25% of the Greater Cambridge area. Completely discounting this area will put pressure on the non-Green Belt land, which by its very nature is further from Cambridge. 5.2 The villages that are fully or partly surrounded by Green Belt are those that are in close proximity to Cambridge and, therefore, bring significant opportunities for development of an appropriate scale given their location. These locations are where the most truly sustainable form of development can be achieved – as they have the ability to minimise the carbon footprints associated with day to day travel and commuting into Cambridge. From a health and well-being perspective, they also offer the most viable means for achieving increased commuting by foot and bicycle, promoting day to day activity, such as running to commercial developments, required today to provide shower and cycle parking facilities for employees. The new commercial developments at the Science Park are a case in point, minimising car parking provision, and maximising opportunities for healthy living. In order to provide truly sustainable development contributing towards net zero carbon development, Green Belt sites must be considered as potentially suitable options. One of the proposed ‘big themes of the Plan is climate change, and appropriate release of Green Belt can assist in achieving this aim. Not considering Green Belt release would be contradictory to this big theme, which is considered in the context of the Climate crisis to have far greater importance than the function of Green Belt, established over 60 years ago in a very different world. This will require a Green Belt Review to be undertaken to assess appropriate sites/parcels.

Yes

Paragraph 136 of the National Planning Policy Framework (NPPF) confirms that Green Belt boundaries should only be altered where exceptional circumstances can be demonstrated as part of the preparation of a Local Plan. Exceptional circumstances are present which would justify the Councils undertaking a review of the Cambridge Green Belt in the preparation of the Plan, in the context of the challenges and opportunities facing the area in respect of delivering housing and employment growth. These challenges and opportunities relate to the significant growth and investment anticipated and committed in the Greater Cambridge area. The exceptional circumstances are set out in the Issues and Options document it is estimated that an additional 30,000 new homes, above the Government’s standard method, will be required to support the economic growth of the area. This growth is driven and supported by the following initiatives: - The Cambridge and Peterborough Combined Authority (CPCA) have confirmed that due the high levels of growth and ‘exceptional’ housing market conditions in Greater Cambridge, the Government will provide £100m housing and infrastructure fund to help deliver infrastructure for housing and growth and at least 2,000 affordable homes. - The CPCA have confirmed that Central Government are to provide an additional £70m ring fenced for Cambridge to help meet the ‘exceptional’ housing needs of the city. - The CPCA anticipate that economic output will increase by 100% over the next 25 years. The GVA of the area is estimated to increase from £22bn to over £40bn. - Cambridge City and South Cambridgeshire anchors the eastern end of the Oxford-Cambridge Arc as defined by Central Government in March 2019. The Government have stated that the Arc area is an economic asset of international standing and can be influential to the performance of the national economy. The National Infrastructure Committee (NIC) found the Arc area to be home to UK’s most productive and fast-growing cities and has significant potential for transformative Growth. However, the growth and opportunity in this area is currently constrained by poor east-west infrastructure and a lack suitable housing. The Arc initiative aims to realise the full economic potential of the area by delivering significant new infrastructure and building up to 1 million new homes by 2050. - Cambridge and South Cambridgeshire also form part of the London-Stansted-Cambridge growth corridor, and the Cambridge-Norwich growth corridor. - Indicative calculations from the Cambridgeshire and Peterborough Independent Economic Review (CPIER), are that around 2,900 homes a year would need to be built in Greater Cambridge, creating an indicative total of 66,700 homes over 2017-2040. This compares with the adopted 2018 Local Plans target of 1,675 homes per year, and 1,800 homes per year to meet local needs using the Government’s standard method. Based on the CPIER 66,700 housing need figure the Issues and Options document states that the Local Plan will need to allocate housing sites capable of delivering an additional 30,000 dwellings over and above the sites already in the pipeline to be built out between 2017-2040. Against this backdrop of growth, it will be important to assess the most appropriate locations for addiitonal development, likely to be through a combination of spatial strategy appraoches due to the sheer number of dwellings required. This level of growth represents the exceptional circumstances that justify and indeed necessitate a Green Belt review. There are opportunties to remove from the Green Belt land which does not contribute to its established purposes (as set out in paragraph 2.30 of the current SCDC Local Plan). Green Belt designations are historical and in many cases appear to arbitrarily follow the village framework boundaries. Green Belt boundaries only appear to have been considered for removal on very large development sites, but some smaller locations do not fulfill the purposes of the wider Cambridge Green Belt designation, namely to: • Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre; • Maintain and enhance the quality of its setting; and • Prevent communities in the environs of Cambridge from merging into one another and with the city. There should be a comprehensive review of the outer edge, village edges and inner edges of the Green Belt boundaries, and there does not appear to be such a review in the evidence base documents. NPPF paragraph 139 states that plans should "not include land which it is unnecessary to keep permanently open." Land at Park Street, Dry Drayton is one such site that does not comply with the purposes of the Cambridge Green belt's designation. The Site Promotion Document for the site (submitted at the Call for Sites stage) sets out in greater detail why the allocation of that site and its removal from the Green Belt would be appropriate in this context.

No

No answer given

Nothing chosen

As part of the preparation of the Local Plan, a review of the Green Belt should be undertaken to assess whether land currently within the Cambridge Green Belt still serves the five purposes of the Green Belt as set out in paragraph 134 of the NPPF. Where land does not serve these five purposes or the fundamental aim of Green Belt policy, which is to prevent urban sprawl by keeping land permanently open (NPPF paragraph 133), the Green Belt boundaries should be altered by the Local Plan accordingly. Furthermore, Green Belt land that no longer serves the five purposes and is in locations which facilitate more sustainable patterns of development, for example land adjacent to some of the larger villages in the District, such as Cottenham, should be released to contribute to reducing climate impacts in preference for less sustainable locations that happen to be outside of the Green Belt. Land off Beach Road, Cottenham is located within the Green Belt, however, the site has the following characteristics which suggest that the site may show some discrepancies with Green Belt policy: ● Due to its location, development of the site would not result in the merging of neighbouring villages; ● There is existing mature vegetation on the site’s boundaries which provides a degree of enclosure; and ● The site, due to its location and scale, is not considered to relate to the contribution of the Green Belt to the setting and character of Cambridge. The site potentially no longer contributes to the fundamental aim of Green Belt policy nor the five purposes of the Green Belt. As such, it is strongly recommended that a full Green Belt review is undertaken and that the site’s contribution to each purpose of the Green Belt is assessed. It is important that any retained Green Belt serves a Green Belt purpose in order to have a robust Green Belt. A Green Belt review should be undertaken, to assess whether the current Green Belt boundary is enduring and includes defensible boundaries. Where it does not, then the Local Plan process must take the opportunity to review and amend; such as with Land off Beach Road, Cottenham The Local Plan should be focussed on providing sustainable development in the most appropriate locations. To prioritise the four big themes will result in some development impacts, such as the removal of land from the Green Belt. Notwithstanding the underlying purposes of the Green Belt (paragraph 134 of the NPPF), where it can be demonstrated that appropriate development can be brought forward in the Green Belt, sites should be considered within the context of their individual circumstances. Applications should be considered in the context of paragraph 136 of the NPPF including an assessment as to whether it can be demonstrated that a proposed development would bring substantial benefits, outweighing the loss of Green Belt land and thereby demonstrate exceptional circumstances needed to justify Green Belt release. In accordance with paragraph 138 of the NPPF, Green Belt boundaries should be reviewed to reflect the need to promote sustainable patterns of development. If the release of Green Belt can facilitate more sustainable patterns of development, particularly if the land has been previously developed or is well-served by public transport, there should be policy provision to allow for a consideration of this in order to determine Green Belt planning applications within the emerging Local Plan. Land off Beach Road, Cottenham should be permanently released from the Green Belt to allow for sustainable residential development to come forward on the site.

Nothing chosen

Southern and Regional Developments (Swavesey) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options across the plan area and reduce travel distances within communities so reducing climate impacts. They support the direction established by the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the Dairy Farm site at Boxworth End, Swavesey benefits from good access to social infrastructure, with close walking distance, with amenities to includes a medical clinic, secondary school, post office and village shop. As these are within close proximity to the site, it should be recognised that the site is a sustainable location to accommodate new development. Furthermore, the site is not designated Green Belt and so its development will not result in wider impacts or harm to the strategic purposes of it. As such, review of Green Belt sites alone will not go far enough in ensuring an adequate spatial strategy, given that there are suitable locations for development that exist beyond it and located in sustainable settlements that are able to and have the capacity to accommodate new development to meet the needs of the new Plan period. Summary of Comments: Releasing sites from Green Belt should be an element of a wider and more comprehensive spatial strategy that includes other approaches.

Nothing chosen

Summary: We question whether a further release of the Green Belt is needed for the reasons set out below (particularly national policy in relation to permanence of Green Belt combined with the previous substantial releases of land from the Green Belt). If further release is deemed necessary to provide a more sustainable development option, can this be based on the existing evidence base prepared in 2015? If this evidence base is not considered sufficient, then any review will need to factor in the purposes of the Green Belt including that of preserving the setting and special character of historic towns and preserving the unique character of Cambridge as a compact, dynamic city with a thriving historic core. We set out our comments in greater detail below. Paragraph 134 of the NPPF states that one of the five purposes of the Green Belt is to preserve the setting and special character of historic towns. Over the years it has been made clear that this purpose is of particular importance to the Green Belts around the following six historic cities: including Cambridge (see The Green Belts, MHSO, 1962 and Extract from Hansard, 8 November 1988) The three stated purposes of the Cambridge Green Belt are to: -preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre -maintain and enhance the quality of its setting -prevent communities in the environs of Cambridge from merging into one another and with the city From a heritage perspective, it should also be noted that the Green Belt serves to provide additional protection to heritage assets, such as the cluster of scheduled monuments to the south of the City or historic settlements including their Conservation Areas, which might otherwise be subsumed by development. Paragraph 136 of the NPPF emphasises that once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. Paragraph 139c of the NPPF makes it clear that Plans should identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period. It is clearly not the intention of national policy that another tranche of land should be taken out of the green belt at every Local Plan review. The 2006 Local Plan saw a substantial release of Green Belt land from the inner green belt boundary with land also released and safeguarded for development beyond the Plan period. There were further releases of green belt land in the 2018 plan, in part due to the fact that the airport land had not come forward for development. As the NPPF prescribes, Green Belt should have a degree of permanence in the long term and should endure beyond the plan period. We therefore question whether there should be further release of land from the Green Belt for this new Local Plan. There is already substantial land released at the airport which may come forward for development, subject to confirmation of the relocation of Marshalls. In addition, there is substantial land at North East Cambridge (sewage works/rail siding etc.) which can accommodate a significant number of new dwellings. We acknowledge that there may be unintended consequences which you will need to take into account should you choose not to review the Green Belt including leap frogging, over-development of inset and non-Green Belt settlements, pressure on the city of Cambridge, leading to erosion of character/identity etc. However if in weighing up all of the above it is concluded that further development of Green Belt land is required and justified in terms of providing a sustainable pattern of development, then consideration is needed as to whether the current evidence base for the Green Belt, prepared during the last EiP by LDA Design, the Cambridge Inner Green Belt Boundary Study 2015/6 (CIGBBS), would provide a sufficient basis and evidence for further release or whether an update or completely new Green Belt review should be undertaken. The findings of that report were broadly accepted by the Inspectors who stated, ‘We conclude that the CIGBBS is a robust approach which follows the PAS advice.’ The CIGBBS concluded that ‘all areas of land within the study area (with the exception of one small area, sub area 8.2 – [Shelford Rugby Club] are important to Green Belt purposes but the reasons differ from one area to another.’ For example: ‘West of the city, the Inner Green Belt plays a critical role in maintaining the impression of a compact city, with countryside close to the historic core. The rural character of the land emphasises this and is seen as the foreground in views from approaches to the city, the M11 and the countryside west of the M11. South-east of the city, the rising land of the Gog Magog Hills is a distinctive element of the setting of Cambridge, and is visible in views from within and across the city. The foothills extend to the urban edge in places; elsewhere, flatter land at the foot of the hills is also important as the foreground to the city in views from the elevated land. East of the city, the Fen and Fen Edge landscapes, while less visible than the Gog Magog Hills, are an equally close link to the historic origins of the city at the meeting point of three landscapes [etc…] Whilst virtually all areas of land within the study area have been assessed as being of importance to Green Belt purposes, consideration has been given as to whether it may nevertheless be possible for certain areas of land to be released from the Green Belt for development without significant harm to Green Belt purposes.’ This latter assessment identified a few parcels of land to the south and east of the city for development, subject to defined parameters. These were brought forward during the last Local Plan. It would seem therefore that the evidence base, at least for the inner boundary, is fairly robust and up-to-date. That said, there could be a case for a review of land within the Green Belt, but not forming part of the inner boundary e.g. around villages or for a new settlement, as in the case of York where a new settlement has been proposed within the Green Belt (Plan currently at EIP). If then it is concluded that an updated or new Green Belt review is required and is undertaken, it is imperative that the review gives sufficient consideration to the purpose of the Green belt to preserve the setting and special character of historic towns. Historic towns and former towns are situated across the region and should form a consideration in any review of Green Belt. Without an appreciation of the history of the region’s historic settlements and their close relationship to their surrounding landscapes, it is not possible to properly ascribe a value to the openness of the Green Belt land around them. Consideration of the value of the Green Belt requires understanding the historic significance of this open landscape and how this contributes to the significance of the historic environment. Whilst Green Belt reviews often divide the area into parcels of land to make the assessment exercise manageable, parcels should not be solely reviewed individually within their immediate context. It also is important to understand how collectively they achieve the strategic aims of the Green Belt. Finally, if the Green Belt is reviewed again, we would strongly advise that sufficient land is identified to ensure that land is safeguarded for development beyond the plan period and that the boundaries can endure without the need for a further review s part of the next Local Plan review.

Nothing chosen

4.93 Before exploring the release of Green Belt land, other sites adjacent to the major road network or the edge of villages along such nodes should be explored first as a sustainable option.

No

ENVIRONMENTAL CAPACITY issues as above. The City centre does not have the capacity to accommodate existing growth pressures arising from new development.

Nothing chosen

National and local planning policy reiterates the importance of protecting Green Belt land for its openness and permanence and it is recognised that Cambridge's capacity for growth is constrained by Green Belt designation. The NPPF is clear, however, that Green Belt locations can be reviewed in response to the need for sustainable development where sufficient brownfield options are not available. The Councils will need to look closely at the extent to which development needs can be met without taking Green Belt land, even with the availability of Cambridge East, which has predominantly been extracted from the Green Belt. Green Belt land can be released for development where it is necessary to meet the need for sustainable development. As part of that review, it is likely that Green Belt land will need to be released on the edge of Cambridge and land to the east of the Airport is a primary candidate. The east of Cambridge is relatively less sensitive in Green Belt terms than other locations and the release of land here as part of a comprehensively planned urban expansion would maximise the scale of the opportunity and secure additional benefits from the synergy which the land can have with development of Cambridge East.

Nothing chosen

European Property Ventures(Cambridgeshire) consider that the Local Planning Authority should look to remove land from the Green Belt to support sustainable development options such as reducing travel distances and thereby reducing climate impacts. The removal of land from the Green Belt should be considered on the edge of sustainable settlements where growth responds positively to sustainable growth. The review of Green Belt boundaries is justified by the circumstance of the Greater Cambridge Plan preparation and the quantum of housing to be delivered, this review must address all settlement boundaries to ensure that the ssutaianble distribution of develoment can be achieved. Support is advanced toward the direction proposed for the new Plan in reviewing Green Belt land at locations benefitting from public transport and thereby, enhanced accessibility. This complies with the National Planning Policy Framework at Paragraph 123a which encourages efficient use of land for housing, particularly towards locations well served by public transport. It also asserts that appropriate densities should be achieved at these locations, with particular consideration of higher densities to ensure that the best use of these accessible sites can be encouraged. By directing development towards these accessible locations, the emerging Plan will also contribute towards strengthening a modal shift away from the use of private cars which is a fundamental concept of the NPPF in its movement towards achieving sustainable development. Furthermore, it will contribute towards combating the impacts of climate change through reduction of carbon emissions and easing the congestion and pressure on the national highway system. However, it is maintained that seeking the release of sites from the Green Belt alone will not ensure that sufficient sites are identified to meet the need of the new Plan period. Identification of land that benefits from high degrees of accessibility should also include land that is located outside the Green Belt, but also at locations that benefit from access to services as well as public transport options. It is considered that the site at Dry Drayton Road, Oakington, benefits from access to social infrastructure, which includes amenities such as a primary school and convenience store. These are within walking distance from the site and therefore should be recognised as demonstrating a sustainable location for new development. Furthermore, although the site is designated as Green Belt, it is considered that existing development along Dry Drayton Road establishes a significant urbanising influence over the area. This development also provides an extent of enclosure around the promotion site and therefore, its development would not result in a detrimental impact on the openness of the area to the south of the village. The site and the village also benefit from proximity to Cambridge, with good local transport linkages into the city via bus services from within the village itselt as well as via the adjacent guided busway. As such, the consideration of the site for Green Belt release and subsequent allocation for development would comply with this option in securing release of Green Belt sites that are supported by sustainable transport options and encourage a modal shift away from private car use. Summary of Comments: Releasing sites from Green Belt should be an element of wider and more comprehensive spatial strategy that includes other approaches.

Nothing chosen

9.1 As part of the preparation of the Local Plan, a review of the Green Belt should be undertaken to assess whether land currently within the Cambridge Green Belt still serves the five purposes of the Green Belt as set out in paragraph 134 of the NPPF. Where land does not serve these five purposes or the fundamental aim of Green Belt policy, which is to prevent urban sprawl by keeping land permanently open (NPPF paragraph 133), the Green Belt boundaries should be altered by the Local Plan accordingly. 9.2 Furthermore, Green Belt land that no longer serves the five purposes and is in locations which facilitate more sustainable patterns of development, for example, land within close proximity to public transport corridors or adjacent to some of the larger villages in the District, should be released to contribute to reducing climate impacts in preference for less sustainable locations that happen to be outside of the Green Belt. 9.3 The Gas Field, Madingley Road is located within the Green Belt, however, the site shows some discrepancies with Green Belt policy and its essential quality of openness including the following: ● The increasing built form to this part of Cambridge, east of the M11, and surrounding mature planting provides an opportunity to reconsider the Green Belt boundary in this location; ● The site should not be assessed in isolation, the Green Belt review should also consider the Eddington development to the north and the West Cambridge University site to the south which creates an enclosed area of built development. The eastern side of the site which adjoins Madingley Road Park and Ride has a stronger connection to the surrounding built form which lessens its contribution to the Green Belt; ● The site is not located between villages nor does it contribute to the separation of settlements; ● The site, due to its location and scale, is not considered to relate to the contribution of the Green Belt to the setting and character of Cambridge. 9.4 The site potentially no longer contributes to the fundamental aim of Green Belt policy nor the five purposes of the Green Belt. As such, it is strongly recommended that a full Green Belt review is undertaken and that the site’s contribution to each purpose of the Green Belt is assessed. 9.5 Notwithstanding the need for a Green Belt review, given the initial findings above, the site’s location and the existing surrounding built form, it is considered that the site: ● Does not check the unrestricted sprawl of large built-up areas – it is largely surrounded by built development including the Eddington development to the site and enclosed by the M11 to the west. The removal of the site from the Green Belt would therefore not lead to unrestricted sprawl; ● Does not prevent neighbouring towns merging into one another – the site is not located between towns or villages. The surrounding area is already segregated by the M11. The removal of the site from the Green Belt would not result in the coalescence of adjoining settlements; ● Does not contribute to safeguarding the countryside from encroachment – as set out above, the site is surrounded by built development and whilst located outside of the development framework and is not considered to encroach on the countryside that is beyond the settlement pattern; and ● Does not preserve the setting and special character of a historic area – the site is not within or near to a Conservation Area. Due to its location and scale, the site is not considered to relate to the contribution of the Green Belt to the setting and character of Cambridge. 9.6 It is important that any retained Green Belt serves a Green Belt purpose in order to have a robust Green Belt. A Green Belt review should be undertaken, to assess whether the current Green Belt boundary is enduring and includes defensible boundaries. Where it does not, then the Local Plan process must take the opportunity to review and amend; such as with the Gas Field, Madingley Road. 9.7 The Local Plan should be focussed on providing sustainable development in the most appropriate locations. To prioritise the four big themes will result in some development impacts. 9.8 Notwithstanding the underlying purposes of the Green Belt (Para. 134 of the NPPF), where it can be demonstrated that appropriate development can be brought forward in the Green Belt, sites should be considered within the context of their individual circumstances. Applications should be considered in the contact of Para. 136 of the NPPF including an assessment as to whether it can be demonstrated that a proposed development would bring substantial benefits, outweighing the loss of Green Belt land and thereby demonstrate exceptional circumstances needed to justify Green Belt release. In accordance with Para. 138, Green Belt boundaries should be reviewed to reflect the need to promote sustainable patterns of development. If the release of Green Belt can facilitate more sustainable patterns of development, particularly if the land has been previously developed or is well-served by public transport, there should be policy provision to allow for a consideration of this in order to determine Green Belt planning applications within the emerging Local Plan. 9.9 The Gas Field, Madingley Road should be permanently released from the Green Belt to allow for sustainable employment or residential development to come forward on the site, whilst providing enhancements in biodiversity on site by preserving the western side of the site for net gain and biodiversity enhancements.

No

Absolutely not. See reasons already given above. Green Belt land is also a major carbon sink. CPRE will treat protection of the Cambridge Green Belt as a national issue if necessary.

No

- We disagree strongly with idea of removing land from the Green Belt. Improving the sustainability of travel is better since it benefits of the existing population and just the planned new homes.