Question 45. What do you think about developing around the edge of Cambridge in the Green Belt?

2.42 As has been set our earlier in this representation, it is considered that the edge of Cambridge in the Green Belt should be developed for employment and residential uses, in appropriate locations. 2.43 The most sustainable location for development will inevitably be adjacent to existing development, and therefore adjacent to Cambridge itself, along with its fringe villages. This is where the majority of services and facilities are, along with public transport opportunities, employment and housing. In order to meet the target for net zero carbon by 2050, the only realistic option is for development to be delivered in locations that offer the most sustainable transport options. 2.44 Over the past 20 years there have been reviews of the Green Belt, and the value of certain parts of it. It is considered that where areas of the Green Belt have been deemed to be of lesser value and importance, and where sites are in sustainable locations, those sites should be considered first for release and subsequent development. The Land at Ely Road, Milton is such an area, being a village to the fringe of Cambridge.

As explained in the section above, Cam Conservators maintain that the land known as Fen Road, Cambridge should be developed to provide a marina with residential moorings as well as a quality residential development of both apartments and houses. Cam Conservators are of the opinion that there is sufficient justification and evidence that the site known as ‘Fen Road, Cambridge’ should be removed from the Green Belt for residential development, particularly due to the highly sustainable credentials of the site. We hope that these representations are of assistance in taking the plan forward. Should you require any further clarification on the issues raised in this representation please do not hesitate to contact me.

2.37 As has been set our earlier in this representation, it is considered that the edge of Cambridge in the Green Belt should be developed for employment and residential uses, in appropriate locations. 2.38 The most sustainable location for development will inevitably be adjacent to existing development, and therefore adjacent to Cambridge itself, along with its fringe villages. This is where the majority of services and facilities are, along with public transport opportunities, employment and housing. In order to meet the target for net zero carbon by 2050, the only realistic option is for development to be delivered in locations that offer the most sustainable transport options. 2.39 Over the past 20 years there have been reviews of the Green Belt, and the value of certain parts of it. It is considered that where areas of the Green Belt have been deemed to be of lesser value and importance, and where these sites are in sustainable locations, these should be those first considered for release and subsequent development. The land around Teversham is such an area, being a village to the fringe of Cambridge, and therefore this applies to the Land at Fulbourn Road, Teversham.

4.10 As part of a hybrid approach to the spatial growth strategy, the Councils should undertake a review of the inner Green Belt to identify suitable locations for growth. This should identify locations which are of low significance to the Green Belt and allow residents to cycle, walk and use public transport to access the City Centre and other key employment, shopping and leisure destinations. 4.11 The Housing Delivery Study (February 2020) prepared by Barton Willmore demonstrates that a transformational level of housing delivery is required to support the economic growth potential of the Greater Cambridge area, with figures going well beyond the standard method requirement. This could mean a requirement to deliver around 27,363 additional homes in Greater Cambridge until 2040. The transformational level of housing delivery will be required both within Cambridge, the edge of Cambridge and rural areas to balance the development strategy. 4.12 Growth on the edge of the City, which provides residents and businesses with direct access to an extensive network of walking, cycling and public transport routes, has the immediate benefit of reducing travel distances, fostering sustainable travel patterns and promoting a change in behaviours for people to live and work sustainably. 4.13 This accords with Para. 138 of the National Planning Policy Framework 2019, which starts that Green Belt boundaries should be reviewed to reflect the need to promote sustainable patterns of development.

Question 45. What do you think about developing around the edge of Cambridge in the Green Belt? 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. 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. The established 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; and prevent communities in the environs of Cambridge from merging into one another and with the city (para 2.30 of the adopted South Cambridgeshire Local Plan 2018). The land at Thorpe, Huntingdon Road is currently located in the Cambridge Green Belt but no longer serves a Green Belt purpose (as outlined in Paragraph 134 of the NPPF), nor the three purposes of the Cambridge Green Belt outlined above. The reasoning for this is discussed below via addressing each purpose of the Green Belt. NPPF Five Green Belt Purposes a) to check the unrestricted sprawl of large built-up areas; The Site is contained by existing and committed development; the site abuts the settlement framework for Girton to the west and north, and North West Cambridge development to the south. The land to the north-west of the site is not located in the Green Belt and is characterised as large residential plots which are also located off Huntingdon Road. This is shown on the plan at Appendix 1. The Site no longer serves this purpose. b) to prevent neighbouring towns merging into one another; The Site abuts the existing settlement framework of Girton to the west, and the new North West Cambridge development. Outline consent for this development was granted in February 2013 (REF: S/1886/11), which sought the development of up to 3,000 dwellings, 2,000 student bedspaces, 100,000m2 employment floorspace and other community facilities, including a Primary School (an amended version of the approved Masterplan can be found in Appendix 3, which located the land at Thorpe in relation to the North West Cambridge development). Following the granting of the outline consent, a series of Reserved Matters Applications have been submitted and approved for Phase 1 of the development, with the construction of this Phase now almost complete. 2.8 The Site therefore no longer serves this purpose. c) to assist in safeguarding the countryside from encroachment; 2.9 The site no longer assists in safeguarding the countryside from encroachment. As mentioned above, the land to the south which previously constituted a countryside location is now to comprise a major, mixed use but residential-led development. To the east, west and north (beyond Huntingdon Road) lies existing residential development. Therefore, there is no surrounding countryside in which the land at Thorpe can protect from encroachment. As a result, the site fails to meet this Green Belt purpose. d) to preserve the setting and special character of historic towns; 2.10 It can also be demonstrated that the site does not preserve the setting and special character of historic towns. The supporting text to adopted South Cambridgeshire Policy S/4 states that one of the established purposes of the Cambridge Green Belt is to ‘preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre’. The text continues that there are a number of factors which define the special character of Cambridge and its setting, which include the following: ● Key views of Cambridge from the surrounding countryside; ● A soft green edge to the city; ● A distinctive urban edge; ● Green corridors penetrating into the city; ● Designated sites and other features contributing positively to the character of the landscape setting; ● The distribution, physical separation, setting, scale and character of Green Belt villages; and ● A landscape that retains a strong rural character. 2.11 It is considered that the land at Thorpe fails to meet the majority of the above factors which contribute to the special historic character of Cambridge. For example, given that the site is heavily screened by dense vegetation, no key views of Cambridge can be observed from the land. Meanwhile, the land does not form part of the distinctive urban edge to Cambridge, considering the residential development and open space associated with the North West Cambridge development which lies between the site and the built-up edge of Cambridge. There are also no green corridors within the vicinity of the site and, while the site itself could be viewed as having a rural character when one considers the mature vegetation on-site, the surrounding residential land (with a particular regard to the settlement of Girton to the west and north, as well as the North West Cambridge development to the south) significantly urbanises this part of the landscape. For all of these reasons, it is reasonable to deduce that the site does little to preserve the setting and special character of Cambridge. 2.12 All the above points are reinforced by the findings of the Cambridge City Council and South Cambridgeshire District Council Inner Green Belt Boundary Study (2012), which indicate that development of the site would have an insignificant impact on the Green Belt. 2.13 Green Belt land which facilitates more sustainable patterns of development should be released in order to make a positive contribution towards reducing climate impacts. Indeed, the land at Thorpe benefits from being located within 15m from a bus stop which is served by both the Citi 5 and 6 bus services, which in turn provide regular journeys to Cambridge, the boundary of which is less than 500 metres from the Site. In addition, Cambridge can be easily accessed via bicycle and on foot from this location, due to segregated cycle paths and footpaths running along Huntingdon Road through to Castle Street. As it is evident that the land at Thorpe is situated in a location which benefits from access to regular public transport and thus its development would result in a more sustainable pattern of development, it would be logical to release the site from the Green Belt, especially when one also considers how the site fails to meet the purposes of the Green Belt. 2.14 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. 2.15 Although it has been demonstrated that the land at Thorpe does not serve a Green Belt purpose, it is important to note that no single solution will deliver a sound Local Plan; rather, a combination of approaches to the distribution of spatial growth will be necessary in order to establish the appropriate locations of new housing and employment development in the district. A hybrid approach will be required, but underpinned with a focus on transport corridors and accessible areas, such as the Land at Thorpe. 2.16 Notwithstanding the above, the NPPF is clear at paragraphs 136 and 137 that Green Belt boundaries should only be amended in exceptional circumstances once it has been established that all other reasonable options for meeting identified needs have been examined. Key to these considerations is that only reasonable options for meeting needs should be considered. This should not only take account of the level of needs but where those needs are within the Greater Cambridge area. It should be reminded, for example, that the CPIER (2018) report recommends that it may be necessary to deliver between 6,000 to 8,000 dwellings annually over the next 20 years (albeit this is across the whole of Cambridgeshire and Peterborough) in order to combat the potential negative local and national economic impacts associated with a constrained housing supply. Given, however, Cambridge’s potential economic growth it would be logical to site the bulk of this housing need within the Greater Cambridge Authority Area. 2.17 Given the potential level of need in the Greater Cambridge area, it is evident that there are exceptional circumstances that will require the Council to amend Green Belt boundaries in order to meet its housing need. 2.18 It is suggested that a diverse approach to delivering new development, including amendment of Green Belt boundaries, would potentially provide for the most sustainable patterns of development and be consistent with paragraph 138 of the NPPF. 2.19 For all of the above reasons, it has been demonstrated that the land at Thorpe should be released from the Green Belt due to it no longer contributing to the five Green Belt Purposes and comprising a location where, if developed, would facilitate a more sustainable pattern of development. An illustration of how this could look in the emerging Proposals Map is provided in Appendix 4, which is based on the Adopted Inset Map for Girton (Number 38).

8.9 The NPPF paragraph 136, provides allowances for development within the Green Belt, under exceptional circumstances, subject to the site being evidenced and justified to an appropriate level. Careful consideration should therefore be given to sites located within the Green Belt that offer a suitable, appropriate and sustainable use. 8.10 A hybrid approach needs to be taken when considering sites for allocation within a local plan, including Green Belt land. Paragraph 137 require local authorities to consider all other reasonable options for development, ahead of exceptional circumstances sites. Green Belt land must be considered if there is a benefit to its preferential development over other land, just because it is not Green Belt without considering the real sustainable and climate change impacts.

Q45: What do you think about developing around the edge of Cambridge in the Green Belt? The focus on growing our villages throughout South Cambridgeshire District would, as paragraph 5.4.3 of the consultation document outlines, maximise the potential for sustainable transport. Paragraph 136 of the NPPF is clear that Green Belt boundaries should only be altered where exceptional circumstances can be evidenced and justified through the preparation or updating of plans. In respect of the three sites being put forward by NIAB, they are located between Girton, Histon and Impington which are settlements located on the edge of Cambridge and have excellent public transport links into the centre, which is also accessible by cycling and walking. We are of the view that a strategic case for the allocation of all three sites can be made which would provide additional housing and employment space within compatible sites and in a sustainable location. Paragraph 138 of the NPPF states promoting sustainable patterns of development should be taken into account when reviewing Green Belt boundaries. It goes on to state that Local Planning Authorities should channel sustainable development towards urban areas within the Green Belt boundaries and the impact of removing land from the Green Belt should be offset through compensatory improvements. The sites are located within the Green Belt and therefore the Council will need to amend the boundary to accommodate their allocation. The preparation of the new Local Plan therefore represents an opportunity to review the Green Belt boundary for the sites being put forward by NIAB. We believe the three sites are suitable for a sympathetic, sustainable and proportionate extension to the existing settlements of Histon, Impington and Girton for additional housing and employment land. These sites are ideally located on the edge of Cambridge with excellent transport links into the centre via public transport, cycling and walking. In view of this, with the support of an allocation, we would encourage our client to bring forward a development that takes advantage of these links to reduce the amount of private car journeys into Cambridge and improves footway and cycleway connections, access to the remaining Green Belt with biodiversity and environmental quality compensatory improvements. The concept of Green Belt was introduced in 1955 and has remained relatively unchanged for some 65 years. At the time Green Belts were introduced, the need to promote sustainable development which meets today’s needs including housing, employment and environmental considerations were very different. Today’s issues of climate change, congestion, pollution, water security, food production and fuel poverty suggest that a more radical approach to planning policy is required. At the time the Green Belts were established, the tools available to planners were more limited and the ability to analyse opportunities and constraints and develop robust evidence and justification, were at best very basic. A blanket protection of large swathes of land was therefore considered appropriate. At the time the pressures for growth and essential need for development were considerably less. Greater Cambridge is an exceptional area, both in its contribution to the national economy and its international reputation. In order to sustain its natural growth in a sustainable way, a wholesale review of the Cambridge Green Belt should be undertaken. This should be a balanced review, not simply an assessment of the performance of various parcels of land against the purposes of Green Belt. It should be a challenging assessment balancing the scale of development required to support the growth necessary to deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over the next 25 years. To support this level of job growth around 2,900 homes will need to be built each year to deliver a total of 66,700 homes between 2017 – 2040. It is imperative, both locally and at the national level, Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. Cambridge as a city is exceptional and as such a radical review of Green Belt policy is clearly justified to facilitate its growth. The tools available today to analyse and inform plan making decisions are highly sophisticated and should be used to undertake a challenging and balanced review of the existing Green Belt. Summary of Comments: Development needs to take place within the Cambridge Green Belt, a radical review of the Green Belt is required to facilitate growth in the area.

Support is given to development around the edge of Cambridge within the currently defined Green Belt where exceptional circumstances exist. However – priority should be given to developing around the edge of Cambridge in the Green Belt along key public transport corridors. Trinity College Cambridge are committed to transforming a parcel of agricultural land adjacent to the Cambridge Science Park into a world-leading centre of excellence in skilled manufacturing and development. The site is strategically located in the north of Cambridge within 6km of circa 43,600 new homes planned by 2031. This includes • homes within walking and cycling distance being promoted through the North East Cambridge Area Action Plan. • 6,500 new homes at Waterbeach connected via improved cycle access on Mere Way, and through the Waterbeach Transit Corridor. • 10,000 new homes at Northstowe already connected to Cambridge Science Park via the Guided Busway and integrated cycle routes. Branded Cambridge Science Park North, it will be an extension of, and benefit from the successful innovation eco-system of the globally renowned Science Park It will promote social inclusion by creating skilled, well paid jobs in local companies for people with no university education where they will work alongside graduates from Cambridge and other universities around the world. The Centre will be nestled in 250 acres of stunning parkland with recreational facilities open to local residents. It will be an early adopter of environmental initiatives including green transport, waste management, energy, ecology and smart buildings; it will also provide a testbed for companies developing sustainable products and services in Cambridge and further afield. Through innovative design and actively supporting innovation in technological advancement the land would be working beyond net zero carbon. Actively supporting businesses working to develop practical solutions to address climate change. The land identified provides an opportunity to create a substantial (approximately 80 hectares) area of biodiversity improvement areas and new accessible green space. This is especially important in this location due to the proposed North East Cambridge HIF funded growth area and additional population being introduced to the area. There is an absolute need and there is no other option

78. Please see response to Question 39.

2.60 As stated in relation to Q42, development should be dispersed throughout the villages to not over burden a single area with additional demands. Where it is not required the development of Green Belt should be avoided and given the suitable sites that can be brought forward in village locations, development in the Green Belt is not necessary.

The South Cambs Local Plan 2018 includes a strategic green belt release to develop a large-scale urban extension as and when the airport relocates. This was envisaged to meet the city’s expansion requirements during this next plan period to 2040 without requiring significant Green Belt releases. However, there are some small pockets of Green Belt land that are capable of being removed around other Green Belt settlements, including for example at Great Shelford, without creating urban sprawl or coalescence of settlements but that would sustain particular villages that have otherwise been constrained for many years. The GCLP should include a review of existing villages within the Green Belt to establish where there may be capacity to increase housing supply without prejudicing the key GB principles; meet identified needs of Green Belt villages; contribute towards a balanced growth strategy.

The emerging Greater Cambridge Local Plan must be confident that exceptional circumstances exist to demonstrate that releasing Green Belt at the fringes of Cambridge city is an appropriate strategy. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving adequate levels of development to meet the needs of the new Plan period. Claremont Planning have advised Southern & Regional Developments (Cottenham) and identify that the Cambridge and Peterborough Independent Economic Review has established that the economic growth of the Plan area has significantly outstripped forecasts, and so are of the mind that exceptional circumstances do exist to justify Green Belt review. The quantum of housing demand that is coupled to the substantial increas in economic growth will result in new development pressures influencing the whole of the Local Plan area. As such, it is imperative that the new Plan reviews its Green Belt to ensure that sufficient sites can be identified to meet this increased need as a result of this rapid economic growth experienced within the sub-region. It is considered that whilst the Plan should ensure that it robustly considers the options in releasing land from the Green Belt to ensure that the development potential of sustainable sites can be realised, it should not preclude the consideration of other suitable sites that are not constrained by their Green Belt designation. This includes Southern and Regional Developments (Cottenham) site to the north east of Cottenham which provides a further option to achieve sustainable development. As it is not constrained by Green Belt, Cottenham should be considered as an alternative route to achieving the requisite levels of growth. It is emphasised that all options to achieve a robust spatial strategy should be considered, alongside the review of sites in the Green Belt. The review of Green Belt sites at the edge of Cambridge should ensure that they do not directly contravene national guidance in relation to the purposes and strategic functionality of the Green Belt. The review of Green Belt sites at Cambridge is sensitive given that these sites demonstrate purposes in safeguarding the countryside from encroachment as well as checking urban sprawls (Paragraphs 134a and 134c of the NPPF). As such, consideration of any Green Belt sites at the fringes of Cambridge city must in the first instance be assessed against these strategic purposes to ensure that wider function of the Green Belt at the edge of the city is not detrimentally compromised. Therefore, it is maintained that the preferable approach should be to assess Green Belt and non-Green Belt sites beyond the fringes of the city, located within the villages of South Cambridgeshire given that the development at these locations will not result in significant sprawl or urbanisation. Summary of Comments: More suitable Green Belt and non-Green Belt sites exist for release that are more appropriate for the emerging Local Plan's consideration.

9.8.1 As part of the process of preparing a new Local Plan, the Councils should undertake a detailed review of the Green Belt around Cambridge. In terms of directing growth to these areas, this would need to be dependent on the outcomes of the Green Belt review and also consideration of alternative options available within the plan area to deliver the necessary scale of growth. 9.8.2 Paragraph 136 of the NPPF (2019) states “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…” 9.8.3 As part of plan preparation Gladman believe this option is something that should be given further consideration and that a robust Green Belt assessment will be needed to inform any strategy in relation to releasing land for the Green Belt for development. The Council will need to weigh up the potential release of Green Belt land against other reasonable alternatives available across the plan area in order to deliver the necessary scale of housing. 9.8.4 Paragraph 137 of the NPPF relates to the need to consider reasonable alternatives in relation to the exceptional circumstances to justify amending the Green Belt boundaries. Gladman note that this should not only take account of the overall levels of housing need but also where those needs are within Greater Cambridge. Expecting unrealistic options to meet these needs in order to avoid amending the Green Belt boundaries would not be an appropriate response. 9.8.5 Given the level of housing need across Greater Cambridge, Gladman consider it is likely that the exceptional circumstances will exist and that a degree of amendments to Green Belt boundaries will be required through the new Local Plan.

The emerging Greater Cambridge Local Plan must be confident that exceptional circumstances exist to demonstrate that releasing Green Belt at the fringes of Cambridge city is an appropriate strategy. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving adequate levels of development to meet the needs of the new Plan period. It is considered that whilst the Plan should ensure that it robustly considers the options in releasing land from the Green Belt to ensure that the development potential of sustainable sites can be realised, it should not preclude the consideration of other suitable sites that are not constrained by their Green Belt designation. This includes Southern and Regional Developments (Willingham) site at Priest Lane, Willingham which provides a further option to achieve sustainable development. Although it is not constrained by Green Belt, it should be considered an alternative route to achieve requisite levels of growth. It is emphasised that all options to achieve a robust spatial strategy should be considered, including the review of sites in the Green Belt at Cambridge city and the villages, as well as non-Green Belt sites located within the villages of South Cambridgeshire. The review of Green Belt sites at the edge of Cambridge must ensure that they do not directly contravene national guidance in relation to the purposes and strategic functionality of the Green Belt. The review of Green Belt sites at Cambridge is sensitive given that these sites demonstrate purposes in safeguarding the countryside from encroachment as well as checking urban sprawls (Paragraphs 134a and 134c of the NPPF). As such, consideration of any Green Belt sites at the fringes of Cambridge city must in the first instance be assessed against these strategic purposes to ensure that wider function of the Green Belt at the edge of the city is not detrimentally compromised. Therefore, it is maintained that the preferable approach should be to assess Green Belt and non-Green Belt sites beyond the fringes of the city, located within and on the edge of villages in South Cambridgeshire given that the development at these locations will not result in significant sprawl or urbanisation. Summary of Comments: All options to achieve a robust spatial strategy should be considered including sites within the Green Belt as well as non Green Belt sites in village.

Greater Cambridge has experienced a high level of employment growth and the Cambridgeshire and Peterborough Independent Economic Review (CPIER) has shown that this growth has been faster than previously forecast. Accordingly, this will have significant pressure on the need to increase housing within Greater Cambridge. It is considered that exceptional circumstances exist to demonstrate Green Belt release. However, Greater Cambridge must be confident that they are releasing the most appropriate Green Belt across the area. The need to be confident that releasing Green Belt at the fringes of Cambridge city is appropriate. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving development outside the Green Belt. This should include other locations within the Green Belt that demonstrate lesser sensitivity than those locations at the urban-rural fringe, where the purpose of checking sprawl is demonstrably at its most significant. It is considered that the Local Plan should look to alternative locations within the Green Belt before assessing those sites to the outskirts of Cambridge. This includes sites such as that under the control of Southern and Regional Developments (Waterbeach) at Bannold Road, Waterbeach. This site falls within the Green Belt and is located to the eastern settlement limits of the village. It is well enclosed by built form of the settlement to the west, the Fen Line railway which forms its eastern boundary and highways which abut the site to the north and south. In this case, the release of the site from the Green Belt would not result in harm to the wider purposes of the Green Belt around Waterbeach, given that these enclosing elements can be utilised to produce tangible and defensible new boundaries to the Green Belt. As such, Green Belt sites beyond the edges of the South Cambridgeshire villages should be considered first before releasing sites at the fringes of Cambridge. These sites will certainly result in the sprawl of the urban form of the city and thus encroachment into the countryside that surrounds the city. This directly contravenes the fundamental purposes of the Green Belt as identified at paragraphs 134a and 134c of the National Planning Policy Framework. Given that it has been demonstrated that alternative opportunities exist elsewhere in the Plan area to secure more sensitive Green Belt release that will not contravene the fundamental requirements of it has recognised in national guidance. Summary of Comments: More suitable, alternative Green Belt sites exist for release that are more appropriate for the emerging Local Plan's consideration.

As a general principle, the Trust is opposed to major development around the edge of Cambridge inside the Green Belt. See also our comments on Q 39.

• We strongly oppose this option. 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 a 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. • The 2016 Review of the Inner Green Belt Boundary showed that other than a few small areas that were incorporated in the 2018 Plan, there were no sites around the edge of Cambridge that could be developed without causing unacceptable harm to the objectives of the Cambridge Green Belt. This review was extensively debated at the Examination in Public in front of the Planning Inspector whose final conclusions endorsed the findings of the review. CambridgePPF can see no reason why this decision should now be overturned. • Green Belts are important because they can provide opportunities for exercise and wellbeing, they can help to improve air quality, reduce flooding, capture carbon, regulate heat and provide habitats for wildlife. Their protection helps prioritise the recycling of previously developed land within the city. And they give city residents access to countryside on their doorstep. One of the reasons that Green Belts have popular support is because they provide quality of life to people. It would seem to us that building on the Green Belt would be incompatible with the Big Themes suggested for the Local Plan.

There are clear sustainability advantages from a climate change and net zero carbon viewpoint of development being located closer to jobs and leisure opportunities. However, a more critical issue is access to sustainable transport, as the reality of the modern world is that people move jobs regularly, but move homes less regularly. Therefore the assumed advantages of co-locating jobs and homes is not as clear cut in practice as in theory. However, sustainable mass public transport options do require sufficient users, so the case for Cambridge to grow and to grow closer to Cambridge still has merit. Much of the Green Belt is impoverished from a biodiversity perspective and not all of it would be considered of high landscape value. Should this approach be favoured, locations must avoid nature conservation sites, priority high value landscapes, and those areas we have identified for the creation of a long-term and permanent nature recovery network.

See answers to question 44 and 39 as they apply even more so with the encroachment into the Green belt. Much of the Green Belt land is adjacent to arterial infrastructure. As we understand more the danger of micro-pollutants, already 25% come from tyres and brakes, and the impact of traffic noise the unsuitability of these sites will increase as traffic (inevitably) increases. If such developments were undertaken (and we would be hard pressed to support such a proposal except in special circumstances), It is imperative that extra land is added to the Green Belt as close as possible to the land lost.

• We strongly oppose this proposal. Already large areas have been taken out of the Green Belt around the edge of Cambridge and more are included in the 2018 Local Plan. If more is taken then the purpose of the Green Belt will be lost, including easy access to the countryside for city residents. Building on the Green Belt would also be incompatible with the proposed Big Themes. New settlements must be the preferred option with the question of sustainability resolved by the provision of high quality, affordable, green public transport from the very beginning. • For Fulbourn, situated very close to Cambridge, further development in the Green Belt is of great concern. The urban edge of Cambridge has crept towards the village over several years, much of it in the Green Belt. The Beechwoods Estate, the Tesco supermarket, Fulbourn Hospital expansion, and Capital Park have all been developed in the parish. Recent permissions include the redevelopment and densification of the Ida Darwin Hospital site, and a social club with ten 3-storey flats together with a large 3-storey care home, both on the edge of the Capital Park Business Park. All are brownfield sites in the Green Belt, but all identified as ‘departure applications’, i.e. they do not conform to both national (NPPF) and local Green Belt policies which aim to prevent overdevelopment (both in plan and height) and a loss of openness. • In addition, expansion of the Peterhouse Technology Park into the Green Belt within Fulbourn Parish is incorporated into the 2018 Local Plan, and an Exception Site in the Green Belt has recently been completed on the eastern edge of the village. This drip-drip of planning permissions, a kind of ‘ribbon development’, has resulted in densification in the Green Belt, and has gradually joined Fulbourn to Cambridge. Policies need to be written to ensure that officers will refuse applications that have a major impact on the purposes of the Green Belt.

1.56 The NPPF recommends that Green Belt boundaries only be amended in exceptional circumstances once it has been established that all other reasonable options for meeting identified needs have been examined. The NPPF also identifies the need to promote sustainable patterns of development when reviewing Green Belt boundaries. 1.57 Increasing densities in urban or village locations or poorly located new settlements should not be promoted as viable alternatives to amending Green Belt boundaries around Cambridge. The Councils need to take a diverse approach to allocating new sites for residential development, which inevitably will result in amendments of Green Belt boundaries in less sensitive areas in order to deliver the most sustainable patterns of development and be consistent with the requirements of the NPPF.

1.54 The NPPF recommends that Green Belt boundaries only be amended in exceptional circumstances once it has been established that all other reasonable options for meeting identified needs have been examined. The NPPF also identifies the need to promote sustainable patterns of development when reviewing Green Belt boundaries. 1.55 Increasing densities in urban or village locations or poorly located new settlements should not be promoted as viable alternatives to amending Green Belt boundaries around Cambridge. The Councils need to take a diverse approach to allocating new sites for residential development, which inevitably will result in amendments of Green Belt boundaries in less sensitive areas in order to deliver the most sustainable patterns of development and be consistent with the requirements of the NPPF.

9.1 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. 9.2 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 and urban fringes of Cambridge by 2040. 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 walking, running, cycling as well as public transport for more sustainable modes of transport. Development in these locations can support residents living sustainable lifestyles, support well-being as well as living in sustainable buildings. 9.3 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. 9.4 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 these villages are to the City the greater the options for sustainable travel and the use of new forms of mobility (e.g. electric bikes). 9.5 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. 9.6 Having assessed the reasonable options for meeting identified housing need set out in paragraph 137 of the NPPF, the time is right given the scale of identified need for housing in the immediate and wider area for a review of the Cambridge Green Belt. There is a compelling case for the Councils to initiate this review of the 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, carbon reduction 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.

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 additional development, likely to be through a combination of spatial strategy approaches 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 opportunities 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 fulfil 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 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.

The destruction of Cambridge as a human scale city.

The emerging Greater Cambridge Local Plan must be confident that exceptional circumstances exist to demonstrate that releasing Green Belt at the fringes of Cambridge city is an appropriate strategy. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving adequate levels of development to meet the needs of the new Plan period. Southern and Regional Developments (Swavesey) considere that whilst the Plan should ensure that it robustly considers the options in releasing land from the Green Belt to ensure that the development potential of sustainable sites can be realised, it should not preclude the consideration of other suitable sites that are not constrained by their Green Belt designation. This includes Southern and Regional Developments site at Boxworth End, Swavesey which provides a further option to achieve sustainable development. As it is not constrained by Green Belt, Swavesey should be considered as an alternative route to achieving the requisite levels of growth. It is emphasised that all options to achieve a robust spatial strategy should be considered, including the review of sites in the Green Belt at Cambridge city and the villages, as well as non-Green Belt sites located within the villages of South Cambridgeshire. The review of Green Belt sites at the edge of Cambridge should ensure that they do not directly contravene national guidance in relation to the purposes and strategic functionality of the Green Belt. The review of Green Belt sites at Cambridge is sensitive given that these sites demonstrate purposes in safeguarding the countryside from encroachment as well as checking urban sprawls (Paragraphs 134a and 134c of the NPPF). As such, consideration of any Green Belt sites at the fringes of Cambridge city must in the first instance be assessed against these strategic purposes to ensure that wider function of the Green Belt at the edge of the city is not detrimentally compromised. Therefore, it is maintained that the preferable approach should be to assess Green Belt and non-Green Belt sites beyond the fringes of the city, located within the villages of South Cambridgeshire given that the development at these locations will not result in significant sprawl or urbanisation. Summary of Comments: It is considered that the Plan must exhaust other Green Belt and non-Green Belt sites at sustainable villages prior to assessing sites at Cambridge.

Very strongly oppose. The Green belt was set up to protect the setting of the historic University City. This setting is already seriously at risk due to the current quantum of development. Building on the Green Belt would be incompatible with the 4 draft Key Themes, and with my proposed 5th key theme.

As identified above, 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 the airport for development. Green Belt land can be released for development where that 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 shown in this submission 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 secure additional benefits from the synergy which the land can have with development of the airport site. It is recognises that there are some careful considerations in releasing Green Belt in this area, including (for instance) the setting and identity of Teversham village, which Marshall believes can be protected and retained through the design of the development and its green infrastructure strategy.

Summary of Comments: The emerging Greater Cambridge Local Plan must be confident that exceptional circumstances exist to demonstrate that releasing Green Belt at the fringes of Cambridge city is an appropriate strategy. This is entirely the responsibility of the Councils to identify whether these circumstances exist following the exhaustion of all other avenues in achieving adequate levels of development to meet the needs of the new Plan period. Euopean Property Ventures (Cambridgeshire) identify that the Cambridge and Peterborough Independent Economic Review has established that the economic growth of the Plan area has significantly outstripped forecasts, and so are of the mind that exceptional circumstances do exist to justify Green Belt review. The quantum of housing demand that is coupled to the substantial increas in economic growth will result in new development pressures influecning the whole of the Local Plan area. As such, it is imperative that the new Plan reviews its Green Belt to ensure that sufficient sites can be identified to meet this increased need as a result of this rapid economic growth experienced within the sub-region. This review of the Green Belt however should take into account the existence of sites that are within elsewhere in the Local Plan area, beyond the fringes of Cambridge city. Areas of land such as that under control by European Property Ventures(Cambridgeshire) demonstrates lesser sensitivity in terms of release from the Green Belt than those sites located at the fringes of Cambridge. These sites, given that they are not located at the edge of large urban areas, do not contribute towards the strategic purposes of checking urban sprawl, nor do they contribute towards protecting the open countryside from encroachment. The site at Dry Drayton Road is located at the southern edge of Oakington, and its immediate context is characterised by significant urbanising influences arising from development located along Dry Drayton Road which includes a large garden centre and farm buildings. Their presence erodes the openness of the Green Belt at this location and undermines the contribution of the undeveloped site to the local rural landscape, which is significantly affected by this built form. As such, the delivery of the site would not result in wider harm to the strategic function of the Green Belt and should be viewed as a preferable location to achieve new residential development. Although this site represents a suitable and appropriate option to achieve delivery of important housing numbers, it should not in the first instance mean that the emerging Local Plan should not consider reviewing the Green Belt as a whole, including sites at the edge of the Cambridge urban area. The review of Green Belt sites at the edge of Cambridge must ensure that they do not directly contravene national guidance in relation to the purposes and strategic functionality of the Green Belt. The review of Green Belt sites at Cambridge is sensitive given that these edge of settlement locations are more likely to demonstrate function in safeguarding the countryside from encroachment as well as checking urban sprawl (Paragraphs 134a and 134c of the NPPF). As such, consideration of any Green Belt sites at the fringes of Cambridge city must, in the first instance, be assessed against these strategic purposes to ensure that wider function of the Green Belt at the edge of the city is not detrimentally compromised. Therefore, it is maintained that the preferable approach should be to assess Green Belt and non-Green Belt sites beyond the fringes of the city, located within the villages of South Cambridgeshire given that the development at these locations will not result in significant sprawl or urbanisation. Summary of Comments: More suitable Green Belt sites exist for release that are more appropriate for the emerging Local Plan's consideration.

9.11 On appropriate sites, the release of Green Belt land is likely to be necessary to deliver the growth that is needed to achieve economic targets including doubling GVA in Cambridgeshire over 25 years. Development of the Gas Field is considered appropriate given the built context of the site to the east of the M11. The site is located in an employment cluster, has access to public transport and is in a locality which is already set to have improved pedestrian and cyclist access