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

CPRE absolutely oppose it.

Natural England supports the purpose of Cambridge’s Green Belt in preserving the unique character of Cambridge, maintaining and enhancing the quality of its setting and maintaining community separation. The Plan should, as far as possible, seek to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide areas for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. In our view the Councils should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

- We disagree very strongly with idea of developing land in the Green Belt.

2.20 Summary Answer: Applying the CPIER growth scenario to Cambridge’s urban fringes and factoring in some housing delivery at North East Cambridge and Cambridge Airport would result in the need for 6,294 additional homes on the edge of Cambridge up until 2040 see Barton Willmore Housing Delivery Study, 2020). This is especially challenging when considering the sensitivity of the edge of Cambridge and the existing extent of expansion beyond its historic core. 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 provide more sustainable travel to justify potential release from the Green Belt. 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.

The Local Plan 2018 already included a strategic green belt release to develop a large-scale urban extension as and when the airport relocates. Going forward, further large-scale releases of Green belt land should only be considered only when other options have been exhausted, as required by NPPF 2019, para 137. This would include considering sustainable new communities beyond the Green Belt, which includes giving due consideration to our Client’s proposal to develop a new garden village at Croxton. The NPPF also guides that discussions should be held with neighbouring authorities to establish if there are non-greenbelt locations to accommodate some of the identified need within adjoining districts. The new garden village opportunity presented at Croxton could be extended into Huntingdonshire district, where land is available and achievable, to create a larger new settlement. This option should also be fully explored before committing to any significant Green Belt releases. There may be some small pockets of Green Belt land that are capable of being removed without creating urban sprawl or coalescence of settlements to sustain particular villages if required but we do not expect this option to deliver significant levels of new housing. It is disappointing that this spatial option does not state similar challenges identified as other options – including loss of agricultural land and impacts upon the landscape. These are different tests to Green Belt principles and should also be noted here, for consistency.

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

The pressure on land remains high and we support the need to make the most efficient use of land within and adjoining the existing Cambridge Biomedical Campus (CBC). Any expansion to the CBC in the medium to long term may require policies supporting densification of the existing campus (both built and subject to extant consents under CBC Phase 1 and 2) and/or would need to be proximate to the existing campus, which may require a further Green Belt review. This may also include health infrastructure required to support the work of the CBC, particularly its hospitals. We would recommend that housing appropriate to the needs of staff on the Cambridge Biomedical Campus (CBC) is sited in accessible locations by walking, cycling and public transport (maximum journey time of 40-50 minutes). 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.

NPPF para 136 makes clear that exceptional circumstances must be evidenced before any changes are made to the Green Belt boundary around Cambridge. The planmaking process needs to provide the evidence to explain how the release of land from the Green Belt is an essential part of the strategic approach to meeting the identified needs of both Council areas. Pigeon would support some further Green Belt releases, if so justified, as part of the balanced approach to the delivery of a range of sizes and types of sites for jobs and homes, particularly where these coincide with proposed strategic transport corridors into and from Cambridge and subject to the five purposes of the Green Belt (para 134 NPPF) being adequately safeguarded.

4.67 The designation and permanence of the Green Belt boundary is key to its success to prevent urban sprawl by keeping land permanently open. The boundaries should only be reviewed in exceptional circumstances and where it can be demonstrated that the councils have has fully examined all other reasonable alternatives for meeting the identified need. We do not believe this is necessary at this stage.

4.66 The designation and permanence of the Green Belt boundary is key to its success to prevent urban sprawl by keeping land permanently open. The boundaries should only be reviewed in exceptional circumstances and where it can be demonstrated that the councils have has fully examined all other reasonable alternatives for meeting the identified need. We do not believe this is necessary at this stage.

The CDF does not propose specific sites. Our response supports development which delivers new homes which are accessible to public transport, local services and jobs, where, with quality design, affordable housing across a range of tenures can be delivered seamlessly as part of the community. Priority should be given to densification in urban areas and previously developed land as well as to development along public transport corridors and on the edge of Cambridge, where housing and jobs can be delivered most sustainably having regard to the goal of achieving net zero carbon by 2050. No one option will provide the level of housing delivery that the local plan identifies as being required and therefore a mixed strategy will be required. Small and medium sized sites should also play a part in this, supporting and enhancing the sustainability of rural communities and providing a proportionate level of growth where needed. We believe that a focus on a mixed strategy is best advocated which is resilient and flexible and provides the homes needed quickly and reliably. The major strategic sites do provide a subsistence level of delivery, but they don’t provide the necessary choice to meet demand and generally provide below policy levels of affordable housing.

5Bad idea to the west where the Green belt protects and preserves Cambridge unique historic centre and setting by its views and vistas and offers easy accessibility for residents to the countryside

3.54 When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that developing around the edges of Cambridge on land in the Green Belt is included in the review of any strategy. The NPPF indicates 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. 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, as would be the case with sites on the edge of the City. 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. 3.55 As set out in the response to Question 39, Grosvenor and USS, therefore, urge the Councils to review sites for release around the edges of Cambridge in the Green Belt which are well served by public transport and well connected to key destinations such as major employment hubs, education and community facilities. Trumpington South is 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. 3.56 Furthermore, the Green Belt and Landscape Appraisal prepared by Terence O’Rourke in support of these representations, assesses the local purpose of the Green Belt in Cambridge 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. 3.57 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. 3.58 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. 3.59 Finally, 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”. 3.60 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.

3.54 When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that developing around the edges of Cambridge on land in the Green Belt is included in the review of any strategy. The NPPF indicates 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. 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, as would be the case with sites on the edge of the City. 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. 3.55 As set out in the response to Question 39, Grosvenor and USS, therefore, urge the Councils to review sites for release around the edges of Cambridge in the Green Belt which are well served by public transport and well connected to key destinations such as major employment hubs, education and community facilities. Trumpington South is 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. 3.56 Furthermore, the Green Belt and Landscape Appraisal prepared by Terence O’Rourke in support of these representations, assesses the local purpose of the Green Belt in Cambridge 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. 3.57 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. 3.58 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. 3.59 Finally, 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”. 3.60 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.

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.

Similar to Q.42 - Growth at the edge of Cambridge could relieve some pressure the city is under. This could be achieved through a well-planned urban extension, integrating the edge into city transport systems. However, as stated in response to Q42 a combination of spatial strategies will be needed, to provide choice, flexibility and to serve in the most sustainable way the various needs of communities and the wide distribution of employment and other facilities in Greater Cambridge.

Please see section 8.0 of the accompanying representations document.

48. Please see response to Question 39.

A. Please see response to Question 39.

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 M Scott Properties site, Land west side of South Street, Comberton, it is located outside the development framework of Comberton, which is a settlement located to the south west of Cambridge and has good public transport links into the centre. We are of the view that a strategic case for the allocation of all three site 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 site is located within the Green Belt and therefore the Council will need to amend the boundary to accommodate their allocation. Paragraph 136 of the NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation and updating of plans. The preparation of the new Local Plan therefore represents an opportunity to review the Green Belt boundary for the sites being put forward by M Scott Properties. We believe the site is suitable for a sympathetic, sustainable and proportionate extension to the existing settlement of Comberton for additional housing. 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 that 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 also 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.

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 M Scott Properties' Site, Land East of Ditton Lane, it is located outside the development framework of Fen Ditton, which is a settlement located on the edge of Cambridge and has excellent public transport links into the centre, which is also accessible by cycling and walking. In addition, it benefits from a number of services and facilities, and the Site represents the first site within a distance of 0.5km of the doctor's surgery which is suitable for development. 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. Paragraph 136 of the NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation and updating of plans. The preparation of the new Local Plan therefore represents an opportunity to review the Green Belt boundary for the sites being put forward by M Scott Properties. We believe the Site is suitable for a sympathetic, sustainable and proportionate extension to the existing settlements of both Fen Ditton and Cambridge City for the provision of specialist housing for those aged 55 and over as well as those with or supporting someone with a disability. The Site is 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 the Green Belt was 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 Belt was 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 that Cambridge maintains its international reputation and the blanket protection provided by existing outdated Green Belt policy only stifles sustainable growth. However, we consider that the Green Belt review process should incorporate a finer grain assessment of specific parcels of land put forward for development, particularly smaller sites adjoining settlement boundaries, such as the land east of Ditton Lane, Fen Ditton. Cambridge as a city is also 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: The opportunity to release sites in the Green Belt should be properly considered through a finer grain Green Belt assessment of promoted sites.

2.84 See response to Q42.

Please see section 8.0 of the accompanying representations document.

The third growth option would create new homes and jobs in extensions on the edge of Cambridge, involving release of land from the Green Belt. With the exception of Marshalls Airport which is not within the Green Belt, the Cambridge Green Belt surrounds Cambridge and incorporates many of South Cambridgeshire’s larger and most sustainable villages, including Fulbourn. 3.7 In sustainability terms there are significant advantages with locating development around the larger villages such as Fulbourn, which are within a relatively short distance of Cambridge City Centre. In comparison to more remote villages outside of the Green Belt, settlements such as Fulbourn are well served by transport infrastructure, including dedicated cycle routes into the City Centre and Cambridge Biomedical Campus, including Addenbrooke’s Hospital. 3.8 As illustrated by the Preliminary Landscape and Visual Appraisal prepared by Pegasus the visibility of the Site, situated on the southern edge of Fulbourn is limited by the adjoining settlement edge, existing landform and established landscape framework of vegetation associated with the agricultural land. In the local landscape context, the site does not extend further west, east or south than the existing settlement pattern, effectively containing any perception of spread that might otherwise arise from development on the Site. A copy of the Preliminary Landscape and Visual Appraisal is provided at Appendix 4 to this Report. 3.9 In terms of visual receptors views of the Site (and potential development) tend to be limited to locations to the east and south/south-east (largely from Cambridge Road and/or Babraham Road) and from these locations will be set against the existing prominent residential edge, consequently minimising perception of the scale of change or addition to the settlement pattern. 3.10 As set out at Section 4 of the Preliminary Landscape and Visual Appraisal there are opportunities for increasing green infrastructure through improved management and diversification of existing hedgerows as well as creating new hedgerows with hedgerow trees. It is considered that, with an appropriate approach to mitigation and the implementation of a robust landscape and green infrastructure strategy, a residentially led masterplan for the wider site area will be physically contained and show clear defensible boundaries. Green infrastructure and open space as part of the proposals can also complement the existing pattern and scale of the local landscape and present an appropriate transition to the wider landscape and that development at this location would be considered acceptable in landscape and visual terms. 3.11 In addition to the landscape considerations set out above, the site is in a highly sustainable location on the main cross road linking the settlements of Fulbourn, Cambridge and Great Shelford. 3.12 Under Policy ST/4 of the previously adopted Core Strategy (January 2007) Fulbourn was identified as a ‘Rural Centre’, by virtue of its superior range of facilities and excellent public transport services to Cambridge. In terms of local amenities there are a number of shops located within a 5 minute walk of the site on School Road including; Cooperative convenience store and Post Office, takeaway restaurant, butchers, beauticians, clothes shop, and a green grocers. There is a further range of services within walking distance of the site including Fulbourn Primary School, Village Library, Community Centre and Health Centre. The Site is also within walking distance of existing bus stops on Cambridge Road, which provides direct services (Citi 1 and Citi 3) to the major local employment destinations such as Capitol Park, ARM, Addenbrookes and the city centre. They also provide routes to Cambridge Station, retail destinations such as Tesco’s and Cambridge. 3.13 In contrast to alternative growth options north of Fulbourn, the Site provides direct access onto Cambridge Road. As a result vehicles travelling towards Cambridge from the Site can avoid passing through the historic core of the village, close to the main services and facilities. From an environmental perspective, the Site will not only minimise additional transport movements through the village centre, but will promote sustainable modes of travel by virtue of its proximity to existing bus stops and dedicated cycle routes. Therefore sequentially the Site is considered the most favourable location for a sustainable extension to Fulbourn. 3.14 Beyond the main urban area of Cambridge, the larger villages within the Green Belt including Fulbourn are the most sustainable settlements with the widest range of services and amenities. For these reasons, Wallace is strongly supportive of Growth Option 3, which offers SCDC and CCC the most flexibility to meet the authorities’ housing requirements, whilst seeking to minimise potential impacts on the environment. 3.15 Similarly to the current spatial strategy in the adopted South Cambridgeshire Local Plan (2018), the fourth growth option seeks to establish a whole new town or village, providing homes, jobs and supporting infrastructure in a new location. Since the NPPF was published in 2012 SCDC has struggled to demonstrate a five year housing land supply. This issue is related to the adoption of a spatial strategy which is significantly reliant on new settlements such as Northstowe to deliver a significant proportion of the Districts housing requirement in the current plan period from 2011 - 2031. 3.16 Between 2011 and 2018 (the first eight years of the plan period for the new South Cambridgeshire Local Plan, adopted in September 2018), the most up to date five year position statement (November 2019) states that 5,866 net additional dwellings have been completed. The average annual delivery rate of 975 dwellings a year has only been achieved once in the plan period (that started in 2011). 3.17 In the last monitoring year (2018-2019), 1,152 net additional dwellings were completed in SCDC. This is an increase compared to the previous monitoring years. Over the previous ten monitoring years, annual net housing completions had been consistently around 600-700 dwellings, except for 2014-2015 in which 867 dwellings were completed. This level of housing completions partly reflects the slowdown in the housing market, but also the significant delays in regards to the delivery of housing at Northstowe. 3.18 Whilst the delivery rate in SCDC increased in the last monitoring year to 1,152 dwellings, a significant proportion of new dwellings completed over the last two monitoring years were not from the large strategic sites such as Northstowe but continued to be on sites outside of development frameworks including on two appeal sites at Waterbeach and on a site on the edge of Great Abington. 3.19 The latest Government announcement on the preferred railway route between Bedford and Cambridge brings key opportunities to plan for large strategic growth, in particular along the A428 corridor. However, given the likely lead in times involved with consenting and building a new railway, the authorities need to ensure that the emerging spatial strategy is not too heavily weighted in favour of Option 4 (New Settlements) but rather builds in sufficient flexibility, including small to medium sized sites around the Rural and Minor Rural Centres that can deliver in the short and medium term

When viewed in the context of the scale of the housing need in Greater Cambridge and its unmet need, it is critical that developing around the edges of Cambridge on land in the Green Belt is included in the review of any strategy. The NPPF indicates 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. 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, as would be the case with sites on the edge of the City. 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. As set out in the response to Question 39, Grosvenor and USS, therefore, urge the Councils to review sites for release around the edges of Cambridge in the Green Belt which are well served by public transport and well connected to key destinations such as major employment hubs, education and community facilities. Trumpington South is 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. Furthermore, the Green Belt and Landscape Appraisal prepared by Terence O’Rourke in support of these representations, assesses the local purpose of the Green Belt in Cambridge 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. 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. 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. Finally, 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”. 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.