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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Summary Savills (UK) Limited have been instructed by Scotsdales Garden Centre Great Shelford to make representations to the Greater Cambridge Local Plan Issues and Options (January 2020) to seek the removal of the garden centre from the Green Belt. Savills (UK) Limited have been instructed by Scotsdales Garden Centre Great Shelford to make representations to the Greater Cambridge Local Plan Issues and Options (January 2020) to seek the removal of the garden centre from the Green Belt. Scotsdales Garden Centre is a well-respected and successful family run business which has been operating from its site in Great Shelford for over 40 years. The business is a major local employer, employing approximately 150 people. Scotsdales is a business which is rooted in the local community, servicing and employing many people from the local area. Planning permission for the garden centre and nursery was first granted in 1969 (reference C/0613/69/D). Since then, numerous applications have been submitted which have led to the expansion of the garden centre and its facilities. The site is considered previously developed land in the context of the NPPF (2019). Most recently, planning permission was granted in February 2017 for the redevelopment of the garden centre (reference S/2475/16/FL). The approved site plan (Appendix 1) shows that this site is already substantially developed and comprises a number large buildings and covered spaces, outdoor sales and display areas, storage and car parking. The site is currently located in the Green Belt, however, Scotsdales are seeking the site is removed. As noted at paragraph 133 of the NPPF (2019), the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping the land permanently open. It is not considered that removing this previously developed site from the Green Belt will affect the Green Belt’s fundamental purpose, and an assessment of the site against the Green Belt’s 5 purposes is set out below. a) To check the unrestricted sprawl of large built up areas As an existing built up area, the removal of the site from the Green Belt will not result in unrestricted built form. The footprint of the site will remain the same. b) To prevent neighbouring towns merging into one another Removing the site from the Green Belt will not result or lead to the merging of Great Shelford with Cambridge. c) To assist in safeguarding the countryside from encroachment The removal of the site from the Green Belt will not extend the site outside the existing pattern of development or into the countryside. Its removal will not have an effect on the physical or visual openness of the Green Belt to any degree than currently exists. d) To preserve the setting and special character of historic towns The setting of local heritage assets or the historic city of Cambridge will not be affected if the site is removed from the Green Belt. e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land Paragraph 136 notes that once established, they should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The above assessment confirms that the site makes no contribution to the Green Belt. As a previously developed site, it is our view that the site should be removed from the Green Belt.

Yes

2.19 Summary Answer: Yes. It is important to note that the Green Belt is a planning designation rather than an environmental designation. The current and future constraints to housing growth within Cambridge, its fringes together with a potential overreliance on new settlements presents a strong case to review Green Belt release when considering the high growth needs of the area and the overarching need to deliver growth in a sustainable way. The high level of housing delivery needed to sustain a rolling 5 year housing supply throughout the plan period is best met through a mix of housing sites and land availability. Sustainable growth on the edge of the City and within settlements surrounding Cambridge can make an important contribution to this objective, creating opportunity to rebalance housing supply and foster zero carbon developments and lifestyles through reduced travel distances and sustainable travel options. Releasing land from the Green Belt on the edge of and in close proximity to Cambridge, where existing infrastructure can be enhanced, arguably provides the best opportunity to influence and change people’s behaviours around travel and commuting and encourage adoption of more sustainable modes of transport. Development in these locations can support residents living sustainable lifestyles, as well as living in sustainable buildings. 2.21 Paragraphs 136 and 137 of the NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation of updating of plans. Prior to concluding exceptional circumstances the policymaking authority should demonstrate that it has examined all other reasonable options for meeting its identified need for development. This should include: 1) making as much use of possible suitable brownfield sites and underutilised land; 2) optimising the density of development; and 3) be informed by discussions with neighbouring authorities as to whether they could accommodate some of the identified need for development. 2.22 In light of the pressing housing problems in Greater Cambridge and the undersupply of housing relative to economic growth, there is a clear need for the emerging Local Plan to consider what capacity exists to accommodate housing delivery on brownfield sites, through densification and the duty to cooperate. Paragraph 3.112 of the adopted Cambridge City Local Plan (2018) acknowledges the lack of available previously developed land and with the exception of the Northern Fringe East it is hard to imagine where significant numbers of additional homes will be feasibly accommodated within the urban area of Cambridge by 2040. Applying the CPIER growth scenario to the current proportion of housing allocated to the Cambridge urban area would result in the need for 5,199 additional homes until 2040 (see Barton Willmore Housing Delivery Study, 2020). 2.23 Applying the CPIER growth scenario to Cambridge’s urban fringes would result in the need for 9,577 additional homes, either through further urban extensions or densification. This is especially challenging when considering the sensitivity of the edge of Cambridge and the existing extent of expansion beyond its historic core. It is therefore vital that less sensitive locations on the edge of Cambridge are reviewed for Green Belt release, taking into account the opportunity to bring forward sustainable development in a location that arguably provides the best opportunity to influence and change people’s behaviours around travel and commuting and encourage adoption of more sustainable modes of transport. Development in these locations can support residents living sustainable lifestyles, as well as living in sustainable buildings. 2.24 The majority of the growth needs are anticipated to be directed to the Greater Cambridge area, particularly given the existing affordable housing needs of the area. This is pertinent given the remaining high ratio of lower quartile price to incomes in the area (Housing Market Bulletin, Hometrack, September 2019) and the 4,712 applicants currently on the combined Housing Register. 2.25 The aforementioned constraints to housing growth within Cambridge, its fringes together with a potential overreliance on new settlements presents a strong case to review Green Belt release when considering the high growth needs of the area and the overarching need to deliver growth in a holistic and sustainable way. The Green Belt is a planning designation not an environmental designation, which should be reviewed at Local Plan stage in order to consider the most sustainable growth options for the area. 2.26 The high level of housing delivery needed to sustain a rolling 5 year housing supply throughout the plan period is best met through a mix of housing sites and land availability. Sustainable growth on the edge of the City where possible and within settlements surrounding Cambridge can make an important contribution to this objective, creating opportunity to rebalance housing supply geographically across the district and tie in with improved sustainable transport measures. Not all of the villages, however, will score highly in sustainability terms or benefit from planned transport improvements. 2.27 A total of 28 villages fall wholly within the Green Belt and 10 further villages adjoin the Green Belt totaling 36% of all village settlements in the district. A significant proportion of these villages fall within a ‘higher sustainability category’ taking into account both existing service and facilities and potential sustainability enhancements. The closer thesevillages are to the City the greater the options for sustainable travel and the use of new forms of mobility (e.g. electric bikes). 2.28 Continued limits to growth in these villages through Green Belt designation will result in dispersion of housing further away from Cambridge, increasing the burden on surrounding villages to accommodate growth of the anticipated 6,294 additional homes in rural areas, contributing in turn to more unsustainable travel patterns. Such an approach would result in these surrounding villages accommodating 123 homes each if distributed equally. This would represent a significant uplift in housing delivery particularly in current ‘infill villages’ where historically housing growth has been low. For instance, between 2002-2017 Knapwell Village only saw 2 new homes completed (‘Cambridgeshire Housing Completions 2002-2017, Cambridgeshire Insight, 2019). 2.29 Limited release of Green Belt land has previously been identified in the villages of Comberton, Histon and Sawston – all of which benefit from relatively good levels of service provision, including secondary schools or colleges. There is therefore a precedent for this approach and one that must meet the strict tests Chapter 13 (Green Belt) of the NPPF. Having assessed the reasonable options for meeting identified housing need set out in paragraph 137 of the NPPF, there is a compelling case for the Councils to initiate a review of the Cambridge Green Belt in order to best meet the challenges of its housing need and direct growth to sustainable locations, enhance the sustainability of existing rural settlements and promote sustainable travel in accordance with paragraphs 78, 103 and 138 of the NPPF. In doing so, the opportunity presents itself to: • Redistribute housing delivery in the area, enabling greater access to housing outside of Cambridge City and improving the wider sustainability of the area; • Recognise the role that small and medium sized sites can make in contributing to housing need, building out quickly and maintaining a rolling 5 year housing supply; • Promote more sustainable forms of construction in rural areas and high quality design in line with Village Design Guides and the National Design Guide to enhance the character and appearance of villages; • Secure more affordable housing and provide greater housing choices to meet a range of community needs, including specialist accommodation for the elderly, self/custom build and a mix of market homes; • Rebalance the scale of growth in existing settlements to create sufficient opportunity to transform local services and infrastructure, directing more S106 funding contributions and public investment towards villages; Bolster existing and proposed village services, improving vitality, demographic mix and social sustainability; • Relieve some of the development burden on Cambridge City, redistributing travel patterns, boosting opportunities for sustainable transport and reducing carbon emissions; and, • Support green infrastructure improvements and biodiversity net gain in rural areas that have hitherto lacked such opportunities due to limited growth and investment.

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Summary: Support for review of the Green Belt, where the land could deliver more sustainable development and reduce travel distances. Full comment: Q39 asks whether the Greater Cambridge Shared Planning Service should 'look to remove land from the Green belt if evidence shows it provides a more sustainable development option by reducing travel distances, helping us to reduce our climate impacts'? 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. 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. It is clear that given the geography of Greater Cambridge in which many of the most sustainable parts of the spatial planning area 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 faciliate 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. While the important role that the Green Belt plays is acknowledged, a flexible approach needs to be taken where sites such as land west of Station Road, Fulbourn benefit from their proximity to existing frequent public transport (with a bus stop just 100 metres south of the site). The proposed Fulbourn Greenway being promoted by the Greater Cambridge Partnership (GCP) would also to provide high quality sustainable transport infrastructure to further improve connectivity. In addition, my client's site at 'land west of Station Road, Fulbourn' presents opportunities for Green Belt release that would help to enable a sustainable large village such as Fulbourn to grow in a sustainable manner. The site itself 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. While it would play a limited role in safeguarding the countryside from encroachment, it is an exceptionally well-contained site with residential development on its western, southern, and eastern boundaries, and the Cambridge to Newmarket railway line providing a clear defensible boundary along its northern side. Sites like land west of Station Road, Fulbourn should be released from the Green Belt.

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8.1 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 in the next Local Plan accordingly. 8.2 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. Land at Capital Park is located within the Green Belt and is considered to meet this requirement for Green Belt release: ● The existing built form 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 adjoining land; ● Some areas of the site have different degrees of enclosure due to the existing built form and tree cover, particularly in the northern area of the site where there are some existing vacant buildings. As such, they have less ‘visual openness’; ● The site is located next to an area of built form and a policy area that is designated for significant development; ● 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. 8.3 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. 8.4 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 – there is built development to the north and west of the site with a policy area designated for significant redevelopment. The removal of the site from the Green Belt would therefore not lead to unrestricted sprawl; ● Does not contribute to safeguarding the countryside from encroachment – as set out above, the site is largely surrounded by built development and whilst located outside of the development framework, 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 town – the removal of the site from the Green Belt would not impact on the setting and character of the Fulbourn 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. 8.5 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 Land at Capital Park. 8.6 The proposed development would respect the immediate character and would retain the openness of the Green Belt and purpose of the land to the same extent as existing neighbouring development. Land at Capital Park is therefore considered suitable to become a site allocation as it would comprise a moderate extension to the existing allocation of Capital Park and comprise suitable infill development.

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The release of some areas of non-performing or underperforming Green Belt around the smaller Green Belt settlements could be considered for non-strategic development through a full Green Belt Review to sustain existing Green Belt settlements. However, the release of Cambridge Airport from the Green Belt though the 2018 Local Plan provides a significant SUE opportunity at the edge of the city to deliver sustainable strategic -scale development as and when it becomes available for release. The location of other strategic-scale sites within the Green Belt should only be considered after all non-Green Belt alternatives have been ‘fully explored’. It is our view that there are other non-Green Belt opportunities to consider that would positively alter the spatial strategy to 2040 to take advantage of the committed and planned infrastructure projects beyond the city edge and their likely effects on improved accessibility, connectivity and relative sustainability for settlements to the western part of the plan area, such as at Croxton. It is necessary to recognise a ‘tipping point’ for the City whereby further housing growth becomes unsustainable. The challenge is to recognise the existing and planned commitments through the 2018 Local Plan that will continue to deliver through the Greater Cambridge Local Plan period and the reality that too much growth focused in one location might have adverse impacts. It cannot be assumed that locations within the Green Belt are inherently more sustainable based solely on their proximity to Cambridge City thereby reducing travel distances. This is an out-dated approach. For example, the 142km CAM system could have multiple stops provided along the route which will change the relative sustainability of non-Green Belt locations. East-West Rail will also influence travel patterns and the sustainability credentials of the rural area to the west of the City. Both have the ability to alter travel patterns and create a shift away from the private car, in spite of travel distances. The spatial strategy should focus on maintaining the pace of delivery on identified city sites during the plan period. The new plan should not commit the same proportion of the new housing supply as the 2018 Local Plans given the significant commitment that is still to be delivered from North East Cambridge and Cambridge Airport and the importance of ensuring a balanced growth strategy to make sure other areas are supported and can also thrive.

Yes

2.1 Yes- land should be removed from the Green Belt if it provides a more sustainable option. The NPPF sets out at paragraph 8 that there are three overarching objectives to be pursued in order to achieve sustainable development; − Economic objective; − Social objective; − Environmental objective. 2.2 Whilst one of the key characteristics of the Green Belt is their permanence, their boundaries can be changed through the plan making process where exceptional circumstances are fully evidenced and justified. The evidence being gathered in the preparation of the emerging Local Plan appears to demonstrate that there is an increased demand for housing development to meet the objectively assessed needs of the area. The environmental objective includes contributing to mitigating and adapting to climate change, including moving to a low carbon economy. Removing selective parts of the Green Belt, that have good access to local shops and services and that can support and sustain those facilities, and reduce the need to travel, particularly by car, should be supported. 2.3 The selective release of Green Belt land will also relieve the pressure on the continued development of the existing urban areas. Higher density development will make efficient use of urban areas, particularly Green Belt land, but will result in mainly smaller, flatted developments. The release of Green Belt land will allow for a range of dwelling types to be built to meet all needs. 2.4 There is local support for this option from the residents of Impington. In the 2016 Parish survey, 46% of respondents were willing to accept some new houses, as long as there's significant delivery of affordable houses, or were relaxed about development on Green Belt. In the same survey, 23% of respondents suggested the location of new housing developments should be to the north east of the community.

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CUH does not feel that it is appropriate for us to comment on the specifics of the development strategy, but we wish to highlight two key points: 1. Any expansion to the Cambridge Biomedical Campus (including Addenbrooke’s) in the medium to long term would need to be proximate to the existing campus. This is being considered as part of the CUHP led work on the 2050 vision, due for publication by summer 2020, which may require a further Green Belt review in areas close to the existing campus. 2. As part of our housing case, we are advocating siting housing in accessible locations to the hospital, by walking, cycling and public transport (maximum journey time of 40-50 minutes). We believe that the most sustainable travel patterns, with associated benefits for air quality, congestion and quality of life, could be achieved through an appropriate review of the Green Belt boundaries, as part of a blended development strategy. This could include development on the edge of Cambridge and adjoining villages well served by public transport.

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CUHP does not feel it appropriate for us to comment on the specifics of the development strategy, but support the findings from the 2018 Cambridgeshire & Peterborough Independent Economic Review (CPIER). This concluded that, “a dispersal strategy, which seeks to relocate homes and businesses away from city centres is unlikely to be successful, as it is ‘agglomeration’ – the desire to be near other companies – that attracts companies to the area. Other options, such as densification, fringe growth, and transport corridors all have potential benefits, and should be pursued to an extent, though none should be taken to its extreme.” Any expansion to the Cambridge Biomedical Campus (CBC) in the medium to long term would need to be proximate to the existing campus, which may require a further Green Belt review in areas close to the existing campus. We would recommend that housing is sited in accessible locations to the campus, by walking, cycling and public transport (maximum journey time of 40-50 minutes). Potentially, the most sustainable travel patterns, with associated benefits for air quality, congestion and quality of life, could be achieved through an appropriate review of the Green Belt boundaries, as part of a blended development strategy. This could include development on the edge of Cambridge and adjoining villages well served by public transport. A CBC Strategy Group with representation from all campus organisations has agreed to develop a Vision 2050 for the CBC. Subject to ratification by the CBC Strategy Group, this will be shared with the Greater Cambridge Planning Service by summer 2020 to define the extent, scale and location of development proposed throughout the timescale of the next Local Plan, and the anticipated number of jobs to be supported by the CBC by 2050. CUHP is committed to working with the Greater Cambridge Planning Service to develop an appropriate policy framework to guide the future development of the CBC.

Yes

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 review Green Belt boundaries through the emerging GCLP. It is considered that exceptional circumstances exist to release land from the Green Belt within Greater Cambridge, 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 are difficult 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. As described above under Question 37, it is considered that Sawston is well served by existing public transport and future transport infrastructure improvements. The submitted Transport Technical Note also highlights the extensive existing public transport access from the Mill Lane Site, Sawston. The Site is located in close proximity to bus stops which provide regular services to a range of destinations including Cambridge. Whittlesford Parkway Railway Station and Shelford Railway station are both less than 4km away and within an acceptable cycling distance and can be reached via Sustrans National Cycle Route. Train services from Whittlesford Parkway Station and Shelford Station serve destinations including Cambridge, Bishop’s Stortford and London Liverpool Street. Shelford Railway Station is also located approximately 3.3km to the north of the site and is also within an acceptable cycling distance and provides access to the same services that are Available from Whittlesford Parkway Station. In addition, Cambridge Railway Station could be accessed from the Mill Lane Site via cycle and provides additional services to London Kings Cross, Ely, Norwich and Stansted Airport. It is considered that exceptional circumstances exist to justify the release of the Mill Land Site, Sawston from the Green Belt, which are related to the significant need for housing and affordable housing in Cambridge and South Cambridgeshire and supporting economic growth. The need for additional housing to support employees of the Vision Centre, and other nearby employment sites, also adds significant weight to these exceptional circumstances. Additionally, as a result of the expansion of Sawston, the site’s surroundings have changed, and this area of Green Belt is now out of place with the adjacent areas of housing and commercial areas of Sawston. It is also considered that development at the site would have no adverse impact on the compactness or setting of Cambridge and it would not lead to the merging of villages, and as such, the site makes a limited contribution to the purpose of including land within the Green Belt. The Landscape and Visual Overview & Green Belt Assessment confirms that the site adjoins the existing settlement boundary to the immediate east and south east. The existing Green Belt boundary in this vicinity could be redefined along the site’s northern and western boundaries, and given the A1301 road to the west, this could form a more robust and long term defensible Green Belt boundary.

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7.1.1 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. 7.1.2 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 context 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. 7.1.3 By way of example, the Greater Cambridge Partnership, in progressing the A428/A1303 Cambourne to Cambridge Better Public Transport Project, have recommended a Scotland Farm Park and Ride location, acknowledging that it is a priority project for development in the first five years of the Greater Cambridge Partnership’s (GCP’s) transport programme. Made up of three key elements: a public transport link between Cambourne and Cambridge, a new Park and Ride facility off the A428/A1303 to supplement the existing Madingley Park and Ride, and new cycling and walking facilities. Subject to statutory consent, construction of these elements is anticipated to commence in 2022, with an opening date in late 2024.

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Land should be removed from the Green Belt if evidence shows it provides a more sustainable development option, including adopting new boundaries utilising physical features that are more readily recognisable and likely to be more permanent than existing boundaries (paragraph 137 of the NPPF).

Yes

Yes Thakeham is of the view that whilst the Green Belt should be afforded a level of protection, the Green Belt is restricting growth outside the city of Cambridge. In accordance with Paragraph 138 of the NPPF, the need to promote sustainable patterns of development should be considered when reviewing Green Belt boundaries. As stated in the consultation material, the Councils’ acknowledge that a location that has sustainability advantages in terms of access to jobs and services and thus reducing trips by the private car, could help mitigate its climate impacts. Thakeham consider that allocating sites for development in and adjacent to existing village settlements, will enable other uses such as new employment space, community space and new sustainable transport links to come forward for the benefit of rural communities. This approach would spread new homes, jobs and facilities out to the villages, as well as help to sustain existing facilities and infrastructure in the villages. The provision of new employment spaces within villages will reduce travel distances across the district, helping the Councils’ to meet its Net-Zero Carbon commitments. As demonstrated in the appended Vision Document, the concept masterplan for the Land east of Long Road, Comberton could deliver new modern employment facilities as well as new open space and sustainable travel links into the centre of Cambridge. In line with National guidance, and to meet the test of “Soundness” (NPPF, paragraph 35), Local Plans should positively seek opportunities to meet development needs. In this regard, the Councils’ should be striving for as higher levels of growth as possible. Within this context and having regard to the scale of the shortage of housing and the need to meet the increased OAN, it is our view that the Councils’ housing need cannot be met without releasing some sites from the Green Belt. For these reasons we consider that the necessary exceptional circumstances exist to release sustainably located sites from the Green Belt, which includes sites like the Land east of Long Road, Comberton. PPG states that where it is necessary to release Green Belt land for development, authorities should set out policies for compensatory improvements to the environmental quality and accessibility of the remaining Green Belt land. As demonstrated in the appended Vision Document, Thakeham would be committed to providing a number of compensatory improvements at the Land east of Long Road, Comberton including new and enhanced green infrastructure, improvements to biodiversity, new walking and cycle routes and new recreational provision (Green Belt Paragraph: 002 Reference ID: 64-00220190722). As shown within these representations and appended Vision Document, the Land east of Long Road, Comberton could deliver a number of benefits for the wider community including much-needed affordable housing, as well as access to employment, open space, and other community facilities in rural areas. In Thakeham’s view, any adverse impacts relating to loss of Green Belt would be outweighed by the benefits of the Land coming forward for development, which is in accordance with Paragraph 11 of the NPPF. Please refer to the appended Vision Document titled 'Land east of Long Road, Comberton' produced by Thakeham

Yes

9.1 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. The preparation of the Greater Cambridge Local Plan (GCLP) provides the opportunity for the Councils to consider undertaking a review of the Cambridge Green Belt in the context of the challenges and opportunities facing the area in respect of delivering housing and employment growth, whilst also reducing climate change. 9.2 Over the next plan period and beyond significant investment and growth will come forward in Cambridge and the surrounding area within the district boundary of South Cambridgeshire. As 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 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. 9.3 The above described initiatives highlight the importance of Cambridge and South Cambridge and have already started to yield direct and indirect results in terms of investment and progress. The following major infrastructure improvements are either being planned or have started: - The A14 road improvements between Huntingdon and Cambridge. Expected completion date December 2020. - A new railway station close to Addenbrookes Hospital to the south of the city centre. Expected completion date 2025. - The duelling of the A428 between Black Cat Roundabout and Caxton Gibbet. Expected completion date 2026. - Cambridge Autonomous Metro route. Expected delivery of the core infrastructure by 2029. It is estimated that the delivery of the Metro route could create 100,000 new jobs and the opportunity to deliver 60,000 new homes in Cambridge and the wider region. - The delivery of East-West rail, which includes a Phase 3 link running between Bedford and Cambridge. Expected completion date 2030. As with the Black Cat to Caxton Gibbet A428 road improvements, the delivery of East-West forms key elements of Oxford-Cambridge Arc. 9.4 The Green Belt was defined many years ago and the opportunity can now be taken through the preparation of the GCLP to refresh those existing Green Belt boundaries. It is evident that the investment and growth in Cambridge and South Cambridge represent exceptional circumstances. The scale of economic and housing growth required in the region is highly unlikely to be delivered in a sustainable manner without the suitable and evidenced release of Green Belt land. As highlighted in the Devolution Deal for the CPCA the needs of the Cambridge and surrounding area are exceptional. Accordingly, in accordance with paragraph 136 of the NPPF, it is clear that exceptional circumstances exist to warrant a review of the Green Belt as part of the GCLP. 9.5 Paragraph 138 of the NPPF makes it clear that when reviewing Green Belt boundaries, it is important to promote sustainable patterns of development. Indeed paragraph 136 states, “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.” 9.6 Given the extent of the Cambridge Green Belt, drawn tightly to sustainable settlements such as Impington, it is vital that specific parcels of Green Belt land adjacent to settlement boundaries are subject to a detailed Green Belt review process. Notwithstanding its Green Belt designation, this land will often provide a sustainable location for growth by virtue of its proximity to the local service provision and public transport links. Indeed, this is the case of Impington where our client is promoting Land at Ambrose Way, Impington. 9.7 Central to the release of land from the Green Belt is how that land performs against the five purposes of the NPPF set out at paragraph 134 of the NPPF. In respect of the Land at Ambrose Way, our clients have commissioned a Green Belt Appraisal of the site. The Appraisal, produced by EDP, is appended to these representations and evidences the following conclusions in respect of the Ambrose Way site’s contribution to the Green Belt purposes: - Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/Moderate. - Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/No contribution - Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate. - Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as No Contribution. - Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a. 9.8 The detail underpinning the above listed conclusions is evidenced in the EDP report. In light of the specific assessment against each Green Belt purpose the Green Belt Appraisal provides an overarching conclusion which confirms that the Ambrose Way site provides a low contribution to the NPPF Green Belt purposes. In respect of bringing forward development at the site the Appraisal concludes that, “development can occur in this location without compromising the fundamental aims of the NPPF to keep land permanently open and while continuing to serve the five of Green Belt at this northern edge of Histon and Impington; primarily to check the unrestricted sprawl, prevent merging of settlements and safeguard the countryside from encroachment.” 9.9 It is strongly recommended that the Council review the Green Belt Appraisal alongside the other submitted evidence when preparing their Strategic Housing Land Availability Assessment (SHLAA) and Green Belt Review study. 9.10 Paragraph 136 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional circumstances. Martin Grant Homes believe that exceptional circumstances exist to warrant such a review and consider that a modification is required in order to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance. 9.11 Central to this review should be an assessment of specific parcels of land with development potential against the five purposes of Green Belt as set out in the NPPF. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for development. It is strongly contested that this is the case for the Land at Ambrose Way, Impington. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out at paragraph 8 of the NPPF and assist in delivering growth of regional and national importance.

Yes

The applicant is of the view that the Green Belt boundary reviewed, as there are opportunities for sustainable employment development, which cannot be realised. We agree with the suggestion that 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.

Yes

Yes. There are many sustainable settlements within close proximity to Cambridge and other key settlements that would be sustainable development options. More fundamentally there are other settlements, such as the Abington’s which are also within close proximity to Cambridge that are not wholly surrounded by Green Belt and could take growth

Yes

2.46. Yes, strong support is given to a Green Belt Review. 2.47. The release of sites from the Green Belt will unlock the potential for sustainable sites such as ‘Land South of High Street, Hauxton’. The site was submitted in response to the 'Call for Sites' in March 2019 on behalf of Redrow Homes Ltd. It represents an opportunity for sustainable expansion of Hauxton immediately adjacent to existing housing and Hauxton Primary School. The site is also well related to existing public transport links, including Shelford Railway Station and bus stops connected by bus routes into the city centre. 2.48. This submission is supported by a Landscape and Visual Appraisal and Green Belt Review Report (Appendix 2) for which identifies the site has a ‘Moderate-Low value’ in terms of the functions and use of the Green Belt. 2.49. As highlighted elsewhere in this submission, consideration needs to be given to existing and planned transport improvements within the area and how these could encourage a shift away from car use. In recent weeks there have been a number of key announcements and public consultations in respect of strategic transport schemes including East West Rail and Cambridgeshire Autonomous Metro.  'East-West Rail' is a proposal by the East West Rail Company for a new railway line linking Bedford and Cambridge. On 30th January 2020 the Government announced the preferred route for the new rail line was consultation 'Route Option E’. Hauxton is located within the 'preferred route option area'.  'Cambridgeshire Autonomous Metro' is a vision for an expansive metro-style network proposed by the Cambridgeshire and Peterborough Combined Authority. On 27th February a public consultation was launched seeking views about the proposal and the indicative route map for the ‘Cambridgeshire Autonomous Metro' (CAM) network. 'Hauxton Park and Ride' is identified as part of the indicative network route with connections to the new Cambridge South Rail Station.  'Cambridge South Rail Station' is a proposal for a new rail station to the south of Cambridge to better integrate southern Cambridge to the rail network to primarily benefit Addenbrooke's and Royal Papworth hospitals and the Cambridge Biomedical Campus but this will also benefit local residents. Network Rail launched a public consultation on 20th January 2020 about three site options for the new station. The consultation information identifies the delivery of the new station in 2025. As identified above, 'Hauxton Park and Ride' is identified as part of the indicative CAM network route with connections to the new Cambridge South Rail Station.

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Pigeon considers that there is scope to release some Green Belt sites on the edge of Cambridge for new development. However, it is recognized that most of the less sensitive sites have already been removed from the Green Belt and that any further Green Belt release will require the demonstration of exceptional circumstances and consideration of the tests in para 137 of the NPPF. In this context, it is important that the Councils have considered all reasonable alternatives and any site-specific factors before land is removed. Whilst the release of Green Belt land will have a role to play, this should be part of a balanced approach that also directs growth to sustainable settlements outside of Cambridge in locations served by rapid and sustainable public transport.

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7.1 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. 7.2 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. 7.3 Para. 145 of the NPPF allows for the limited infilling of villages provided this does not have a greater impact on the openness of the Green Belt than the existing development. The adopted Local Plan includes for a policy to allow for infilling in the Green Belt. The proposed residential development on Land off Station Road, Harston, is considered appropriate in the context of Para. 145 and would comprise suitable infill development that would extend only as far the existing development line of its neighbouring residential and agricultural properties. The proposed residential development would respect the immediate character and would retain the openness of the Green Belt and purpose of the land to the same extent as existing neighbouring development. Land off Station Road is therefore considered suitable to become a residential site allocation as it would comprise a moderate extension to the village and suitable infill development.

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4.57 The previous plans for the Greater Cambridge area have prioritised development firstly within Cambridge, then on the edge of Cambridge, at new settlements close to Cambridge, and at better served villages. This is clearly shown on the following extract on page 76 of the GCLP as follows: 4.58 There is a clearly defined circle around the city and noticeable development sites on the northern and eastern corridors and smaller scale employment sites to the south east. What is clearly noticeable is the lack of housing and employment sites in the south west of the area. 4.59 We agree that the special qualities of Cambridge and the Green Belt should be protected and options for growth should be considered in areas outside of the designated Green Belt. There should be consideration of improving existing settlements that are in sustainable locations outside of the Green Belt in the first instance. There are other sustainable options that should be considered first including the fact that not everyone wishes to work in the city centre. The current approach within the adopted Local Plan focuses on the city itself. The presence of the growth corridors coming forward, new ways of working and the intention to create an inclusive environment with the District requires a different approach.

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4.56 The previous plans for the Greater Cambridge area have prioritised development firstly within Cambridge, then on the edge of Cambridge, at new settlements close to Cambridge, and at better served villages. This is clearly shown on the following extract on page 76 of the GCLP as follows: 4.57 There is a clearly defined circle around the city and noticeable development sites on the northern and eastern corridors and smaller scale employment sites to the south east. What is clearly noticeable is the lack of housing and employment sites in the south west of the area. 4.58 We agree that the special qualities of Cambridge and the Green Belt should be protected and options for growth should be considered in areas outside of the designated Green Belt. There should be consideration of improving existing settlements that are in sustainable locations outside of the Green Belt in the first instance. There are other sustainable options that should be considered first including the fact that not everyone wishes to work in the city centre. The current approach within the adopted Local Plan focuses on the city itself. The presence of the growth corridors coming forward, new ways of working and the intention to create an inclusive environment with the District requires a different approach.

Yes

Yes – to assist in the provision of sustainable development, land within the Green Belt should be considered for removal. Specifically, the provision of a transport hub on Green Belt land to the east of Whittlesford Parkway Station would assist in reducing travel by car and promote sustainable travel options. This would clearly assist in the reduction of climate impacts. Whittlesford Parkway is a well-used train station assisting commuters traveling to Cambridge and London who live in the more rural areas to the South of Cambridge. The station also assists those who work at the science parks located in the Southern Cluster, including the Wellcome Trust. The provision of a transport hub on land to the east of Whittlesford Parkway would assist in providing enhanced sustainable transport options that will serve the AgriTech Park at Hinxton. By allowing the development of travel hubs in green belt locations such as this, businesses will be supported whilst reducing the reliance on private cars and reducing overall climate impacts.

Yes

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. It is considered that the sites promoted for development by EDBF in the Green Belt make a limited contribution to the purposes for including land within the Green Belt. The promoted developments in the Green Belt would have no adverse impact on the compactness or setting of Cambridge and would not lead to the merging of villages. Therefore, as set out in the call for sites submissions for EDBF the sites should be released from the Green Belt to meet needs for housing, affordable housing and self-build plots. As set out in the response to Qu.33 there is a significant local need for affordable housing in most villages in South Cambridgeshire. In addition, as set out in the call for sites submission for EDBF, land at Milton and Fulbourn should be released from the Green Belt to meet needs for employment growth.

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The Local plan should reflect the NPPF approach to Green Belt policies. Past experience around Cambridge has shown it is possible to release Green Belt land whilst improving green spaces, access and biodiversity. The Green Belt is a planning and not an environmental designation and given the imperative of development which maximises the use of low-carbon living and transport, more sustainable development options on the edge of Cambridge must not be ruled out, particularly those that have possibly the greatest opportunity to encourage changing behaviours and support people living more sustainable lifestyles.

No

We oppose removing land from the Green Belt. Cambridge is a compact city with scope for development on brown field sites, excluding existing green spaces of environmental and or recreational value.. To extend Cambridge into the green belt would create a conurbation of Cambridge and its surrounding villages. On the West of Cambridge the University is already intensely developing the North West Cambridge (previously released from the Green Belt) and West Cambridge sites. There is an urgent need to preserve the remaining Green Belt and green spaces to provide a green balance to the significant urbanisation of green spaces that is already occurring under the current plan. Summary of Comments: We oppose removing Land from the Green Belt.

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3.44 The NPPF underlines the Government’s commitment to maintaining the integrity of Green Belts, stating that once established, these should only be amended in ‘exceptional circumstances’ and only through the preparation or updating of plans. 3.45 The NPPF indicates that when drawing up Green Belt boundaries, the Council should consider the need to promote sustainable patterns of development, channelling development towards the urban area. Where Green Belt land is required for release, consideration should first be given to land which is previously developed and/or well served by public transport. When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that all appropriate options are fully explored, including amendments to Green Belt boundaries. 3.46 Grosvenor and USS consider that there are exceptional circumstances for the release of Green Belt land to meet the growing housing need in Cambridge, especially where travel distances can be reduced and sustainable patterns of development encouraged. This will provide an opportunity to identify sites which can provide a significant amount of homes to contribute to meeting identified housing needs, especially where those sites are well served by public transport (as advised in para 138 of the NPPF) and also well connected to key destinations, such as major employment hubs, education and community facilities. Grosvenor and USS agree that climate impacts could be reduced if the Councils take this approach to remove Green Belt land if evidence shows it provides a more sustainable development option by reducing travel distances. 3.47 Grosvenor and USS maintain that any Green Belt Review undertaken by the Councils should be a robust assessment, undertaken in accordance with the national Planning Practice Guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development. 3.48 There are a number of Green Belt locations where housing sites can be identified that reduce travel distances, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain. Trumpington South is such a site, situated on the southern edge of Cambridge, located next to the existing Trumpington Park and Ride, and the future Cambridge South West Travel Hub, with proposals to extend the guided busway around the edge of the site. Trumpington South is well connected via active and shared travel modes to the Cambridge Biomedical Campus, the city centre and nearby community facilities, reducing commuting and travel distances to key locations. 3.49 Furthermore, the Green Belt and Landscape Appraisal prepared by Terence O’Rourke, which has been prepared in support of these representations, assesses the local purpose of the Green Belt in this location which is to preserve its setting and special character and to prevent the merging of communities with each other and to the city. The Appraisal considers the contribution of the site to the prevention of communities merging into one another to be limited. The Appraisal’s focus has, therefore, been on the changing nature of the site and surrounding environs and how this has, and will, affect the setting of Cambridge city. 3.50 The Green Belt and Landscape Appraisal conclusions advise that the alterations to the landscape, specifically the urbanising nature of development, such as the proposed Park and Ride, and associated reduction in visual openness, will alter the contribution of the site to Green Belt purposes. It goes on to say that this is particularly the case in relation to the setting of and approach to the settlement edge and that these changes have also, therefore, altered the qualities and function of the Green Belt. 3.51 The Appraisal notes that the future development of this site would provide an opportunity to create a new settlement edge which responds to the changing and increasingly enclosed nature of the landscape as a result of development. It advises that the extent of the settlement edge should allow for a sufficient countryside edge to be preserved, ensuring that the landscape predominates. It concludes that alterations to the landscape would provide the opportunity to enhance the countryside edge and, therefore, the setting and special character of Cambridge. 3.52 Lastly, the NPPF also refers to “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”. 3.53 The Green Belt and Landscape Appraisal advises that Trumpington South offers the opportunity to significantly enhance the quality of the remaining Green Belt within the site through biodiversity enhancements and access for multi-recreational purposes, as has been demonstrated in the Country Park to date. Grosvenor and USS consider these compensatory measures would offset any loss of Green Belt arising from the development.

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3.44 The NPPF underlines the Government’s commitment to maintaining the integrity of Green Belts, stating that once established, these should only be amended in ‘exceptional circumstances’ and only through the preparation or updating of plans. 3.45 The NPPF indicates that when drawing up Green Belt boundaries, the Council should consider the need to promote sustainable patterns of development, channelling development towards the urban area. Where Green Belt land is required for release, consideration should first be given to land which is previously developed and/or well served by public transport. When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that all appropriate options are fully explored, including amendments to Green Belt boundaries. 3.46 Grosvenor and USS consider that there are exceptional circumstances for the release of Green Belt land to meet the growing housing need in Cambridge, especially where travel distances can be reduced and sustainable patterns of development encouraged. This will provide an opportunity to identify sites which can provide a significant amount of homes to contribute to meeting identified housing needs, especially where those sites are well served by public transport (as advised in para 138 of the NPPF) and also well connected to key destinations, such as major employment hubs, education and community facilities. Grosvenor and USS agree that climate impacts could be reduced if the Councils take this approach to remove Green Belt land if evidence shows it provides a more sustainable development option by reducing travel distances. 3.47 Grosvenor and USS maintain that any Green Belt Review undertaken by the Councils should be a robust assessment, undertaken in accordance with the national Planning Practice Guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development. 3.48 There are a number of Green Belt locations where housing sites can be identified that reduce travel distances, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain. Trumpington South is such a site, situated on the southern edge of Cambridge, located next to the existing Trumpington Park and Ride, and the future Cambridge South West Travel Hub, with proposals to extend the guided busway around the edge of the site. Trumpington South is well connected via active and shared travel modes to the Cambridge Biomedical Campus, the city centre and nearby community facilities, reducing commuting and travel distances to key locations. 3.49 Furthermore, the Green Belt and Landscape Appraisal prepared by Terence O’Rourke, which has been prepared in support of these representations, assesses the local purpose of the Green Belt in this location which is to preserve its setting and special character and to prevent the merging of communities with each other and to the city. The Appraisal considers the contribution of the site to the prevention of communities merging into one another to be limited. The Appraisal’s focus has, therefore, been on the changing nature of the site and surrounding environs and how this has, and will, affect the setting of Cambridge city. 3.50 The Green Belt and Landscape Appraisal conclusions advise that the alterations to the landscape, specifically the urbanising nature of development, such as the proposed Park and Ride, and associated reduction in visual openness, will alter the contribution of the site to Green Belt purposes. It goes on to say that this is particularly the case in relation to the setting of and approach to the settlement edge and that these changes have also, therefore, altered the qualities and function of the Green Belt. 3.51 The Appraisal notes that the future development of this site would provide an opportunity to create a new settlement edge which responds to the changing and increasingly enclosed nature of the landscape as a result of development. It advises that the extent of the settlement edge should allow for a sufficient countryside edge to be preserved, ensuring that the landscape predominates. It concludes that alterations to the landscape would provide the opportunity to enhance the countryside edge and, therefore, the setting and special character of Cambridge. 3.52 Lastly, the NPPF also refers to “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”. 3.53 The Green Belt and Landscape Appraisal advises that Trumpington South offers the opportunity to significantly enhance the quality of the remaining Green Belt within the site through biodiversity enhancements and access for multi-recreational purposes, as has been demonstrated in the Country Park to date. Grosvenor and USS consider these compensatory measures would offset any loss of Green Belt arising from the development.

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37. Paragraphs 133 and 136 of the NPPF are clear that great importance is attached to Green Belt and boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. 38. Paragraph 137 explicitly requires the strategic policy-making authority to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries. Compliance with this process will be assessed through the examination of its strategic policies. 39. Therefore, the onus is on the Greater Cambridge Authority to demonstrate that all other reasonable options for growth have been exhausted before releasing Green Belt regardless of the potential sustainability benefits of Green Belt locations. 40. Cambourne in general present a suitable and sustainable location for development and therefore must be given significant weight and consideration for allocation of additional development before any land can be released from Green Belt. 41. If further sites are required to meet growth needs once all land outside the Green Belt has been assessed and, where appropriate, allocated, then the Green Belt boundaries can then be changed and justified as necessary. 42. Additionally, the previous Sustainability Appraisal for the SCLP assessed the approach to new settlements/Green Belt. This concluded that the removal of additional large-scale sites from the Cambridge Green Belt could result in irreversible adverse impacts on the special character of Cambridge as a compact historic city and risk the economic success of the Cambridge area. This further highlights the importance of considering sustainable locations outside the Green Belt as a priority for future growth.

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Reviewing Green Belt boundaries is particularly relevant to Cambridge, given its primary purpose of its role in protecting Cambridge as an historic city. The NPPF underlines the Government’s commitment to maintaining the integrity of Green Belts, stating that once established, these should only be amended in ‘exceptional circumstances’ and only through the preparation or updating of plans. The NPPF indicates that when drawing up Green Belt boundaries, the Council should consider the need to promote sustainable patterns of development, channelling development towards the urban area. Where Green Belt land is required for release, consideration should first be given to land which is previously developed and/or well served by public transport. When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that all appropriate options are fully explored, including amendments to Green Belt boundaries. Grosvenor consider that on the basis of the extent of development need, there are exceptional circumstances for the release of Green Belt land for housing in Greater Cambridge. This will provide an opportunity to identify sites which can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain. The Green Belt Review should be a robust assessment, undertaken in accordance with the national Planning Practice Guidance and the NPPF, specifically taking account of the need to promote sustainable patterns of development. Further, the guidance refers to “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” therefore it is dependent on the credentials of the site. For reasons set out in the attached story boards, Whittlesford is an ideal sustainable location for growth where land removed from the Green Belt can make a valuable contribution to meeting future needs. The existing Local Plan spatial strategy for the City and South Cambridgeshire relies upon major growth weighted to the north and west, whereas investment in the life science and research based employment parks has been directed towards the south and east of Greater Cambridge. The Green Belt review should therefore address this imbalance in order to provide new homes in locations with good public transport facilities and where conveniently accessible by cycling and walking. The Green Belt review should also take into account the four big themes when revising the Green Belt boundaries. These are all part of the overall exceptional circumstances to justify an amendment to the Green Belt to allow for the expansion of Whittlesford to help meet the need for homes and other facilities in Greater Cambridge to support growth, minimise congestion and reduce travel by private car. The location of Whittlesford Railway Station provides the opportunity to consolidate the existing settlements into a comprehensive sustainable community without compromising the essential functions of the Green Belt.

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Please see section 8.0 of the accompanying representations document.

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34. Paragraphs 133 and 136 of the NPPF are clear that great importance is attached to Green Belt and boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. 35. Paragraph 137 explicitly requires the strategic policy-making authority to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries. Compliance with this process will be assessed through the examination of its strategic policies. 36. Therefore, the onus is on the Greater Cambridge Authority to demonstrate that all other reasonable options for growth have been exhausted before releasing Green Belt regardless of the potential sustainability benefits of Green Belt locations. 37. Cambourne in general presents a suitable and sustainable location for development and therefore must be given significant weight and consideration for allocation of additional development sites before any land can be released from Green Belt. 38. If further sites are required to meet growth needs once all land outside the Green Belt has been assessed and, where appropriate, allocated, then the Green Belt boundaries can then be changed and justified as necessary. 39. Additionally, the previous Sustainability Appraisal for the SCLP assessed the approach to new settlements/Green Belt. This concluded that the removal of additional large scale sites from the Cambridge Green Belt could result in irreversible adverse impacts on the special character of Cambridge as a compact historic city and risk the economic success of the Cambridge area. This further highlights the importance of considering sustainable locations outside the Green Belt as a priority for future growth.