Question 49. Do you have any views on any specific policies in the two adopted 2018 Local Plans? If so, what are they?

No comment.

‘Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area’ (Policy 25) Cambridge Local Plan 2018 8.1 104-112 Hills Road falls within the ‘Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area’ (Policy 25) of the adopted Cambridge Local Plan (2018). 8.2 Policy 25 confirms that development proposals within the Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area will be supported if they help promote and coordinate the use of sustainable transport modes and deliver and reinforce a sense of place and local shops and services. Development proposals are also expected to deliver a series of coordinated streetscape and public realm improvements. 8.3 Pace are fully supportive of the aims and objectives of Policy 25. This policy objective should be followed through to the new Greater Cambridge Local Plan and the Site should continue to fall within the Opportunity Area. ‘Station Areas West and Clifton Road Area of Major Change’ (Policy 21) Cambridge Local Plan (2018) 8.4 104-112 Hills Road is located within the “Station Area West (2) – Site M44” within a designated Area of Change. Policy 21 identifies Station Area West (2) as land comprising 1.17 hectares fronting Hills Road which “will include”: ● “i. B1 (a) and B1 (b) employment; ● “j. residential use; and ● “k. a mix of uses in classes A1, A2, A3, A4 and A5.” 8.5 Pace are fully supportive of the aims and objectives of Policy 21. This policy objective should be followed through to the new Greater Cambridge Local Plan and the Site should continue to fall within the Area of Major Change. 8.6 Having regard to the potential land uses identified under Policy 21 (Site M44) the Site Allocation provisions should recognise the key opportunities that exist in the redevelopment of this high profile site, located on the main route from the Railway Station and the developments along Station Road into the City Centre; a site that can deliver a development that embraces innovation, is dynamic and bold, creating the workplace of the future, whilst exploiting its highly accessible location. It is a site that has the potential to bring significant benefits to the local environment through the creation of new amenity space, public realm and enhancing public accessibility. 8.7 Since the original grant of planning permission Cambridge has seen significant new development within the station area and along Station Road, including significant amounts of new residential. There is currently limited Grade A office space available in the core city centre market. The limited space that is being built, is already identified, or which could potentially come forward, is already attracting strong interest and there are few sites available to meet the need for this standard of space. Accordingly, the lack of Grade A office space in the city centre, the limited amount of space coming forward and the lack of available sites, due to the constraints of Cambridge’s core area, makes this site highly desirable for retention of its commercial land uses. 8.8 Accordingly, it is considered that potential uses are appropriate, but that the wording of the allocation should make clear that flexibility is to be applied with regard to the mix of the proposed uses. This will ensure that the site’s redevelopment can respond most appropriately to local needs at the point of redevelopment occurring. 8.9 When considering the allocation for office development, the site has the potential to create opportunity for greater levels of access to today’s agile work environments which encourage cross fertilisation of ideas and thought. Through the activation of the ground floor of the building, the provision of high-quality public realm around the site, and through the provision of appropriate amenity space to serve future occupiers, it is expected that the ground floors of the future development, and its wider public realm will become a new place in Cambridge. 8.10 The new Greater Cambridge Local Plan therefore needs to be flexible to enable a response to changes in economic circumstances and of the importance of ensuring enough land of the right types is available in the right places and at the right time to support growth and Cambridge's commercial importance and vision at local, regional, national and international levels.

ARU's mission has always been to transform lives through innovative, inclusive and entrepreneurial education and research. It continues to play a critical role in the educational, research and economic success of the Greater Cambridge area, and has ambitious but realistic plans to ensure that it can continue to make this vital contribution. There are currently just over 11,000 students studying on campus in Cambridge, up around 120 students on the previous year, with further intakes due in May. The year on year increase in numbers is driven by doubledigit growth in both EU and International students: - The EU student population has grown to 1539, a 12% increase on 2018/9 - The International student population has grown to 1962, a 27% increase on 2018/9. Undergraduates make up two-thirds of the population in 2019/20 but Postgraduate Taught student numbers are growing (up 14% on last year). The University has aspirations for further growth, in particular, relating to International, Degree Apprenticeship and Foundation Year courses, of between 5 to 10% over the next 3 years. Higher Education continues to change, making detailed planning for the life of the new Local Plan very difficult. The University would very much welcome the opportunity to discuss its plans in more detail as the Local Plan process continues. Support for University development To ensure that the University of Cambridge and ARU can continue to modernise and maximise their contributions to the educational, research and economic success of the Greater Cambridge area, it is important that the new Local Plan recognises and makes provision for the planned growth. To do this, policies in the new Local Plan need to positively support University development. Policy 43 in the Cambridge Local Plan 2018 states that University Development in the City Centre will be permitted subject to criteria whereas University Development outside the City Centre will be treated on their merits. East Road marks the city centre boundary in that Plan with land to the northwest of the road being inside and land to the 2 southeast of the road being outside the city centre. The Local Plan 2018 acknowledges that the East Road site and area remain the most sustainable location for ARU and the University is keen to continue to concentrate its provision in this area, but the consequence of the spatial differentiation in policy 43 means that development on the University’s East Road campus, which is adjacent to but outside the city centre, and its site at Young Street site will be judged on their merits rather than being permitted (subject to criteria). The new Local Plan needs to include explicit support for modernised and enhanced provision on ARU’s East Road site and area. Student Accommodation It is important that the new Local Plan recognises, is consistent and makes provision for the expected growth in student numbers and need for accommodation. Paragraph 5.28 of the Cambridge Local Plan 2018 refers to catering for growth in student numbers (at ARU) whilst paragraph 6.14 contradicts this by stating that ARU has confirmed that it has no growth aspirations to 2026. It is acknowledged that the increasing demand for accommodation from students can put pressure on the general housing market. The National Planning Policy Framework 2019 requires sufficient land to come forward to meet the housing needs of different groups, and makes specific reference to students in this regard (paragraph 61). The implications of the wording of Policy 46 of the Cambridge Local Plan 2018 will unduly limit the opportunities to make the required provision for additional student accommodation. The policy states that “Permanent purpose built student accommodation will not be supported on sites allocated for housing, or with an extant planning permission for residential development, or sites identified as potential housing sites within the Council’s Strategic Housing Land Availability Assessment”. Such a wide ranging exclusion together with policies that seek to protect other land uses, unduly limits the opportunities to provide student accommodation. Rather than unduly limit opportunities to provide the required provision for additional student accommodation, the new Local Plan needs to ensure that it provides for sufficient land to meet all the housing needs, including Student accommodation. Masterplan The University is preparing a masterplan for its East Road campus and is keen to ensure that it has a clear, recognised standing as a material planning consideration in the determination of subsequent planning applications. We are keen to continue discussions on how this might be achieved, which could include being a supplementary planning document to a policy hook in the new Local Plan.

The settlement hierarchy of the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Local Plan. Willingham is inappropriately placed within the second tier of the adopted settlement hierarchy, which establishes the village as with lesser sustainability credentials than those placed in the top hierarchical tier. Willingham's current position within the adopted spatial hierarchy undermines the suitability of the village to accommodate moderate levels of residential development. It benefits from an established service base and is located within reasonable catchment of higher level services, such as secondary schools, within nearby villages. The site at Fen End also benefits from being within walking distance of a number of amenities within the settlement, including a medical practice and primary school which supports the suitability and sustainability and of the site and so its consideration for residential allocation. It is also important to note that whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, such as at Cambourne, the emerging Local Plan should apply inappropriate reliance on the delivery of these allocations. The National Planning Policy Framework asserts at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the Framework emphasis elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. These sites can therefore more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as at Fen End, Willingham. Supporting Comments - A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

Southern & Regional Developments (Joscelyn) considers whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, the emerging Plan should not apply inappropriate reliance on the delivery of such allocations. The National Planning Policy Framework asserts at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the Framework emphasis elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. These sites can therefore more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained therefore that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites alongside larger strategic scaled allocations, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as at Kingfisher Way, Cottenham. Although it is appropriate that Cottenham is identified as a top tier settlement and recognised in the adopted spatial strategy as one of the most sustainable villages in the District, it is maintained that this hierarchy should be reinforced and supported so that appropriate levels of new development may be achieved. This should form part of a wider ranging and comprehensive re-assessment of the spatial approach to new development within the Plan area and should acknowledge the development potential of sites at sustainable settlement such as that at Kingfisher Way, Cottenham. Currently, without a robust reassessment of the spatial strategy, such sites may be omitted from the new Plan which will undermine its ability in seeking a sufficient number of sites to meet the strategic housing need of the new Plan period. Given that approaches of South Cambridgeshire and Cambridge city will be amalgamated through the implementation of a joint Plan, the approaches of both Authorities will need to be cohesive and supplementary, ensuring that no previous appropriate or deliverable approach is excluded. Directing development towards sustainable villages, including Cottenham, should be regarded as a significant component of the new spatial strategy and demonstrates a deliverable approach to spatial planning. Summary of Comments: The most sustainable settlements recognised in the South Cambs hierarchy should be reinforced and supported to accommodate new growth.

There are a number of primary policies contained within the SCDC Local Plan (2018) relating to employment land and its delivery. Endurance would make the following comments: E/11: Large Scale Warehousing and Distribution Centres This policy is relatively restrictive on B8 development in the Local Plan area. With the delivery of the new A428 improvements there is plenty of potential for where storage and distribution warehousing can be sited. South Cambs should be willing to take its fair share of B8 development in appropriate locations. It is also myth that these types of uses do not deliver significant jobs and this reference should be removed from any new policy. Many of these uses not include their call centres and ancillary offices with employees having a range of skillsets and hold a variety of positions (e.g. managerial, data programmers and goods handling). E/13: New Employment Development on the Edges of Villages This policy allows for suitable B1,B2,B8 development to be delivered on the edge of villages subject to a number of criteria being satisfied. If the Local Plan is seeking to deliver employment growth it must provide policies which encourage businesses not restrict them. (a) The need to demonstrate there are no other buildings or sites within the settlement should be removed. Businesses require sites which are suited to their needs and available to them from the land owner. The specific site should be assessed on its merits. (b) The need for the site to be previously developed land or demonstrate there is no previously developed land available should be removed as it is far too restrictive. Many businesses require a specific site location or size suited to their needs. The criteria should ask them to justify the site in respect of their specific needs rather than asking them to consider other sites which may not be suited to them. (c.) The viability of a business in not a planning matter and should not be sought to justify a planning application (d) Requiring a named user for the development is too restrictive and should not be required and maybe restrictive if the site is to be used by another business in the future. (e) Agreed – It is likely many of these sites will be identified as allocations (f) Agreed (g) This should be an objective not a criteria E/14: Loss of Employment Land to Non Employment Uses We agree with the overall assessment of sites (Inappropriate for its use; community benefits; environmental problems) to be considered suitable for redevelopment. If the site also forms part of a wider strategic site it should also be considered for redevelopment however it is likely to form part of an allocation in this instance. If the Part 1 criteria of the policy are met then there seems little merit in seeking evidence as to why an element of employment could not be included as part of the redevelopment scheme. This criteria should be removed and the replacement scheme assessed on its own merits. Any requirement to market the site for a period should be removed. It is time consuming and could create significant delays in the planning process. If a site is not considered suitable for its current use then it's redevelopment should be open to any use and be assessed on its individual merits. It would be our recommendation that any employment site which is not suited for its existing uses (as defined in Part 1 of the policy) should be allocated for potential redevelopment in the new plan where it is identified through the call for sites exercise. E/16: Expansion of Existing Businesses in the Countryside The expansion of existing businesses should be supported and the criteria of this policy are generally supported. (a) The need to have been operating for two years should be removed. Some businesses undertake rapid growth and the local plan should be able to accommodate these situations without applying a minimum operating time restriction. (b) Why is there a need to have a named operator. This will change if a business is sold or sublet. It is unclear what this criteria is seeking to achieve. (c.) Agreed (d) Agreed (e) Agreed (F) Agreed

‘Protection of Open Space’ (Policy 67) Cambridge Local Plan 2018 8.5 Policy 67 of the Cambridge Local Plan (2018) currently requires the following when considering development proposals on areas of land protected as open space: “Development proposals will not be permitted which would harm the character of, or lead to the loss of, open space of environmental and/or recreational importance unless: a. the open space can be satisfactorily replaced in terms of quality, quantity and access with an equal or better standard than that which is proposed to be lost; and b. the re-provision is located within a short walk (400m) of the original site. In the case of school, college and university grounds, development may be permitted where it meets a demonstrable educational need and does not adversely affect playing fields or other formal sports provision on the site. Where replacement open space is to be provided in an alternative location, the replacement site/facility must be fully available for use before the area of open space to be lost can be redeveloped.” 8.6 The designation of protected open spaces within the Cambridge Local Plan is too broad, the policy serves to protect most spaces in the City for recreation and environmental ‘importance’, using a broad ‘catch all’ assessment criteria and then applies an overly restrictive 400m distance restriction to any relocation. The 400m restriction does not allow for any balance of the issues, or benefits that may be accrued from a relocation that happened to be over 400m away. 8.7 This is highlighted by Emmanuel College Sports Ground which is identified within the Local Plan as a Protected Open Space and an Outdoor Sports Facility ‘Emmanuel College Playing Field (REF: SPO 16). The site is identified as having both environmental and recreational importance within the Open Space and Recreation Strategy (2011), however, the Strategy does not set out in any further detail as to how this assessment has been made. It is therefore not clear how the Council have determined that the site is of environmental and recreational importance. 8.8 Paragraph 7.48 of the Local Plan requires that replacement sites / facilities should be no more than a short walk (400m) from the site that is to be replaced. The plan in Appendix 1 shows that the 400 metre radius around the site is heavily constrained and already features residential development, Green Belt land and other protected spaces. There is limited opportunity to reproviding the open space within a 400-metre radius of the site, if that was the appropriate response. Major benefits could be achieved, in theory, by providing for a new purpose-built facility that was more than 400m away, but the policy is overly-restrictive to not allow a judgement to be made. 8.9 The Appendix 1 Plan shows all the currently Protected Open Spaces and their 400m isochrones to reflect the 400m described in adopted Cambridge Policy 67. This vast protection of spaces arises through an assessment criteria that is too broad and essentially forms a ‘catch all’ approach, protecting whole sites, when for example the environmental ‘importance’ only applies to a part of the site; such as with Emmanuel College Sports Ground and its planted boundaries, but yet the whole site is protected. 8.10 The approach to recreation protection is also not a robust policy position. Emmanuel College Sports Ground is now surplus to requirements following the land at Rutherford Road being secured as an alternative, larger location for College sports provision (REF: 08/0873/FUL), yet it is given the full protection of Policy 67 for its recreational importance. The Local Plan also requires that replacement sites/facilities should be provided so as not to increase any identified deficiencies in open space in the ward where the site is located. In the case of Emmanuel College Sports Ground, the site is located within the Newnham Ward, where no deficiencies are identified within the Open Space Strategy (2011). In this case the site would not lead to increasing deficiencies within Newnham, but this matter is not taken into account in making the designation, nor does Policy 67 allow for the same matter to be taken into account in application decision-making. On a related issue, Policy 67 does not relate well to NPPF paragraph 97 and its criterion (a) which allows for an assessment to be made to ascertain if the open space is surplus to requirements. 8.11 Paragraph 7.47 of the Local Plan identifies that there is a ‘clear presumption’ against the loss of open space of environmental or recreational importance, and that: “Any proposal involving the loss of open space must include an assessment (using the criteria listed in Appendix I) to determine the important aspects of the site that should be retained within the new development, in agreement with the Council. As part of any planning application, applicants will need to clearly demonstrate how the proposal will minimise its impact on the site’s intrinsic qualities and where possible enhance the remaining part of the site. Due regard must also be given to any potential impact on the character and wider setting of the site.” 8.12 The criteria used to assess open space in Cambridge are currently set out in Appendix I in the Local Plan. The criteria are summarised below alongside an assessment as to why the criteria are not useful in their current state, highlighted by example with Emmanuel College Sports Ground. CRITERIA FOR ENVIRONMENTAL IMPORTANCE OUR ASSESSMENT a. Does the site make a major contribution to the setting, character, structure and the environmental quality of the city? The site does not make a major contribution. The site is not referenced in the West Cambridge Conservation Area Appraisal in terms of its heritage contribution to the area. The tree line along the western boundary is identified as an important tree group on the Townscape Analysis map in Appendix 3 of the Appraisal, and this tree line can be retained without the need to protect the entire site as open space. The Townscape Analysis map also notes that there are Important Positive Views from the south-western boundary looking to the east and north-east. However, such views can be addressed without the need to protect the entire site as open space. b. Does the site make a major contribution to the character and environmental quality of the local area? The site is inaccessible to the public and is screened by existing trees along the western boundary. c. Does the site contribute to the wildlife value and biodiversity of the city? The accompanying Ecological Appraisal indicates that the site has the potential to accommodate bats, birds and great crested newts. QUESTIONS USED TO ASSESS ENVIRONMENTAL IMPORTANCE OUR ASSESSMENT i. Does it make a major contribution to the setting of Cambridge? ii. Does it have positive landscape features and/or a sense of place sufficient for it to make a major contribution to the character of the city? iii. Is the site an important green break in the urban framework? iv. Does it have significant historical, cultural or known archaeological interest? i. The site does not make a major contribution. ii. The site is not referenced in the West Cambridge Conservation Area Appraisal in terms of its heritage contribution to the area. The tree line along the eastern boundary is identified as an important tree group on the Townscape Analysis map in Appendix 3 of the Appraisal. This tree line can be retained without the need to protect the entire site as open space. The Townscape Analysis map also notes that there are Important Positive Views from the south-western boundary looking to the east and north-east. However, such views can be addressed without the need to protect the entire site as open space. iii. The site does not represent an important green break. The site is inaccessible to the public and is screened by existing trees along the western boundary. Further greenfield land can be found to the south of Emmanuel College Sports Ground and beyond the University Athletics Track. QUESTIONS USED TO ASSESS ENVIRONMENTAL IMPORTANCE OUR ASSESSMENT iv. The site is not referenced in the Cambridge Conservation Area Appraisal as being valuable in terms of its heritage status although it does contain a Grade II listed building. This listed building, however, can still be retained without the need to protect the entire site as open space. i. Does it have positive features such as streams, trees, hedgerows or meadowlands which give it a sense of place sufficient to make a major contribution to the character of the local area? ii. Is it an important green break in the framework of the local area? iii. Does it form part of a network of open spaces in the local area? iv. Is it enjoyed visually on a daily basis from public places (e.g. footpaths, vantage points)? v. Does it have local historical or cultural interest? i. The site does not contain any of these positive features, other than the tree line along the eastern and northern boundary. These can be retained without needing to maintain its designation as a protected open space. ii. The site is not an important green break. It is largely closed off from public access. iii. As above. iv. The site can be viewed along Wilberforce Road. v. The site is not considered to be important in terms of its historical or cultural interest. The site is not referenced in the West Cambridge Conservation Area Appraisal in terms of its contribution in heritage terms. i. Does it have any nature conservation designation? ii. Is it adjacent to or an important link to sites with nature conservation designation? iii. Does it contain important habitats or species sufficient to make it worthy of consideration for any nature conservation designation? iv. Is it an important wildlife oasis in an area with limited wildlife value? i. The site is not designated as a nature site. ii. The site is not adjacent to a nature conservation site. iii. The accompanying Ecological Appraisal indicates that the site has the potential to accommodate bats, birds and great crested newts. iv. The site is surrounded by residential development to the west, north and east. CRITERIA FOR RECREATIONAL IMPORTANCE OUR ASSESSMENT d. Does the site make a major contribution to the recreational resources of the city? The site does not make a major contribution to recreational resources of the city. e. Does the site make a major contribution to the recreational resources of the local area? The site does not make a major contribution to the recreational resources of the local area. The site is located within the Newnham Ward and whilst a detailed assessment of Newnham’s open space provision has not been undertaken, no deficiencies are identified within the Open Space Strategy (2011). It is therefore considered that the loss of the playing field on the site would not lead to increasing deficiencies within Newnham. QUESTIONS USED TO ASSESS RECREATIONAL IMPORTANCE OUR ASSESSMENT i. Is it of a size, quality and accessibility such that people would travel to use it for recreational purposes, no matter where they live, work or study in the city? ii. Is it an important part of the network of significant recreational open spaces? iii. Is it part of the sports provision which help to meet demand from people throughout the city, no matter where they live, work or study? The site has been surplus to requirements since Emmanuel College acquired and secured planning for a much larger playing field at land off Rutherford Road (REF: 08/0873/FUL), which was implemented in 2011. The site is therefore not an important part of the network of recreational open spaces. i. Is it of a size and accessibility such that people who live, work or study in the local area do or could use it for recreational purposes? ii. Is it an important part of the network and hierarchy of recreational facilities in the local area? iii. Is it a significant linkage between recreational areas? The site has been surplus to requirements since Emmanuel College acquired and secured planning for a much larger playing field at land off Rutherford Road (REF: 08/0873/FUL), which was implemented in 2011. The site is therefore not an important part of the network of recreational open spaces. 8.13 As set out above, removing the site’s designation as a Protected Open Space will not lead to the loss of any sports/recreation facilities. ‘Community, Sports and Leisure Facilities’ (Policy 73) Cambridge Local Plan 2018 8.14 Policy 73 of the Cambridge Local Plan (2018) states the following: “The loss of a facility or site that was last in use as a community, sports or leisure facility will only be permitted if it is demonstrated that: i. the facility/site can be replaced within the new development or relocated to at least its existing scale, range, quality and accessibility for its users. For leisure uses, it should satisfy peak period need; or j. the facility/site is no longer needed.’’ ‘’In providing evidence that a facility/site is no longer needed, the guidance in Appendix K of the plan should be adhered to. The redevelopment of school sites for other uses will be permitted only if it can be demonstrated that they are not required in the longer term for continued educational use.’’ 8.15 In terms of the site, criterion j is considered to apply given that the site has been surplus to requirements since 2011 and the facilities are no longer required. Paragraph K.3 of Appendix K requires that: “Proposals for either replacement or relocated facilities should demonstrate: a. equal or improved site accessibility to users by all means of transport including foot and cycle; and b. sufficient spare capacity or agreement to accommodate displaced users at other equivalent community/leisure facilities with similar accessibility for users. For existing leisure facilities, in the absence of a robust district-wide needs assessment/capacity assessment, applicants will be expected to carry out such an assessment at their own cost; and c. through local consultation, the level of interest in and viability of the continued use of the premises as a community/leisure facility.” 8.16 The Open Space and Recreation Strategy 2011 includes an assessment of sites identified on the Policies Map, including an assessment as to whether each site is important for environmental and/or recreational reasons, according to the assessment criteria listed in Appendix I of the Local Plan. It also identifies those wards with deficiencies in open space provision. The Site is referenced to as site SPO 16 in the Newnham Ward profile, comprising 4.02 hectares. The site is assessed as having both environmental and recreational importance. 8.17 An updated Open Space Assessment is required for Cambridge, in accordance with Paragraph 96 of the National Planning Policy Framework (NPPF) which requires the following: ‘’Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate.’’ 8.18 Paragraph 97 of the NPPF requires the following: “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: ● An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or ● The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or ● The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss. 8.19 NPPF Paragraph 97 is considered to be the basis to assess this policy matter. This Policy sets out three criteria, but these are a series of ‘or’, so only one criterion has to be engaged and compliant. The second criterion is the appropriate test for the development proposal because the open space is considered to be surplus to requirements, with a replacement provision being located at Rutherford Road, Cambridge, which comprises a greater quantity of land used as playing fields. Consequently, this NPPF matter is not reflected in adopted Policy 67. Summary 8.20 Policy 67 requires an overhaul so that it allows for a clearer NPPF para 97 structure and criteria assessment and to remove the 400m restriction, which is too onerous and could prevent a planning judgement being made to account for benefits of a relocation. The assessment criteria to determine whether an open space should be designated is based on PPG17 and should have an overhaul to ensure there is a robust assessment criteria, to underpin the Big Theme around biodiversity and green spaces. By example, Emmanuel College Sports Ground should not be a protected open space; it has only planted boundaries to the west and north; comprises two Important Positive Views based in the southern portion of the site; and is surplus to requirements following the land at Rutherford Road being used as a larger, alternative playing field by Emmanuel College.

Q49: Do you have any views on any specific policies in the two adopted 2018 Local Plans? If so, what are they? It is considered that the development strategy and settlement hierarchy policies in the South Cambridgeshire Local Plan: S/6, S/7, S/8, S/9, S10 & S/11 are unnecessarily restrictive and do not promote sustainable patterns of growth or allow appropriate levels of growth in rural areas, as required to support a prosperous rural economy. The NPPF recognises that rural settlements operate in a more complex way then a simple hierarchy, based on the presence/location of services and facilities. Often, a larger centre acts as a focus for a network of surrounding hinterland villages and it would be more appropriate for these groupings to be considered as a whole. It may be more appropriate that development in a number of hinterland villages, which would support, and be supported by, services and facilities in a larger settlement, would represent a more sustainable pattern of growth. It is not always the best solution to be adding growth to larger settlements where smaller settlements may be able to accommodate growth with less environmental harm. The new Local Plan should be more flexible and not apply upper limits to levels of growth, rather look to allocate a significant range of small and medium sized sites throughout the rural group areas, selecting the most appropriate sites, rather than those simply closest to services and facilities. As set out in question 31, in order to deliver 10% of small sites of one hectare or less, potentially over 266 sites will need to be found in the rural areas and a similar supply of medium sized sites will also need to be found to maintain delivery and provide flexibility. It needs to be recognised that opportunities to maximise sustainable transport solutions are different in rural areas (NPPF paragraph 103). Reduced sustainable transport opportunities should not simply be used as a reason to rule out growth which may have greater benefits in terms of enhancing the vitality of rural communities. It is important that opportunities for villages to grow and thrive are identified rather than stifled by overly rigid policies. Summary of Comments: Support for a blended spatial strategy that includes growth in the villages.

83. South Cambridgeshire Local Plan Policy S/5 set a target for 19,500 new homes between 20112031. Some of this target had already been completed/committed at the time of adoption but the remainder of housing delivery supply relied on three major strategic site allocations which were anticipated to provide a further 13,700 (70%) of these homes. 84. As stated within the response to Question 46, a move away from simply relying a small number of large allocations is needed. Smaller and medium sized sites must also be considered to ensure that a robust supply of sites are allocated which delivers growth in the right locations across the district throughout the entire Plan period. 85. Furthermore, the reference within Policy S/6 to limiting residential development and redevelopment to up 30 dwellings in Minor Rural Centres should be removed. It would be more appropriate to consider housing numbers and densities on a case-by-case basis taking into account the local context and need for housing. This is particularly the case as the range and number of services, facilities and employment vary amongst different rural centres. A more flexible policy approach should be taken to new development in or adjacent to these better serviced rural centres as they can deliver growth in sustainable locations and make best use of existing services, facilities and employment opportunities.

‘Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area’ (Policy 25) Cambridge Local Plan 2018 9.1 Land to the north of Station Road falls within the ‘Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area’ (Policy 25) of the adopted Cambridge Local Plan (2018). 9.2 Policy 25 confirms that development proposals within the Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area will be supported if they help promote and coordinate the use of sustainable transport modes, and deliver and reinforce a sense of place and local shops and services. Development proposals are also expected to deliver a series of coordinated streetscape and public realm improvements. 9.3 The College is fully supportive of the aims and objectives of Policy 25 and the drive to deliver an improved public realm along Station Road. This policy objective should be followed through to the new Greater Cambridge Local Plan and the Site should continue to fall within the Opportunity Area. ‘Station Areas West and Clifton Road Area of Major Change’ (Policy 21) Cambridge Local Plan (2018) 9.4 Within the Local Plan 2006, the Site was located within the identified Station Area ‘Area of Major Change’ under Policy 9/9. This Area of Major Change was taken forward into the adopted Cambridge Local Plan (2018) under Policy 21 – the ‘Station Areas West and Clifton Road Area of Major Change’. However, Land to the north of Station Road was excluded from the designation at because it was not a central focus of the masterplan at that time. (see Figure 1.1 below). 9.5 Land to the north of Station Road has an important role to play in the continuing redevelopment and revitalisation of the emerging central business district along Station Road. It is therefore requested that the boundaries of the ‘Station Areas West and Clifton Road Area of Major Change’, under Policy 21 of the adopted Cambridge Local Plan 2018, is reviewed as part of the emerging Greater Cambridge Local Plan, to include for Land on north side of Station Road to make sure its long-term future is properly considered to best support the Cambridge Station Area.

62. We feel as though Policy S/10 of the South Cambridgeshire Local Plan 2018 is restrictive to enabling development to villages that are considered sustainable with suitable transport links and not within the Green Belt.

Souther & Regional Developments (Cottenham) considers whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, the emerging Plan should not apply inappropriate reliance on the delivery of such allocations. The National Planning Policy Framework asserts at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the Framework emphasis elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. These sites can therefore more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained therefore that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites alongside larger strategic scaled allocations, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as to the north east of Cottenham. Although it is appropriate that Cottenham is identified as a top tier settlement and recognised in the adopted spatial strategy as one of the most sustainable villages in the District, it is maintained that this hierarchy should be reinforced and supported so that appropriate levels of new development may be achieved. This should form part of a wider ranging and comprehensive re-assessment of the spatial approach to new development within the Plan area and should acknowledge the development potential of sites at sustainable settlement such as that to the north east of Cottenham. Currently, without a robust reassessment of the spatial strategy, such sites may be omitted from the new Plan which will undermine its ability in seeking a sufficient number of sites to meet the strategic housing need of the new Plan period. Given that approaches of South Cambridgeshire and Cambridge city will be amalgamated through the implementation of a joint Plan, the approaches of both Authorities will need to be cohesive and supplementary, ensuring that no previous appropriate or deliverable approach is excluded. Directing development towards sustainable villages, including Cottenham, should be regarded as a significant component of the new spatial strategy and demonstrates a deliverable approach to spatial planning. Summary of Comments: The most sustainable settlements recognised in the South Cambs hierarchy should be reinforced and supported to accommodate new growth.

46. It is our view that S/10 of the South Cambridgeshire Local Plan 2018 is restrictive to enabling development to villages that are considered sustainable with suitable transport links and not within the Green Belt.

49. Policy S/10 of the South Cambridgeshire Local Plan 2018 is far too restrictive and inflexible, and prevents appropriate-sized development in medium-sized villages such as Orwell. A much less restrictive approach to development in medium-sized villages like Orwell should be adopted, together with a much broader definition of what constitutes sustainability, focusing on the potential to enhance the sustainability of a place through allowing appropriate levels of development on the edges of villages. 50. Summary: Support for a more flexible and less restrictive approach to appropriate residential development within and on the edges of villages.

It is considered that the settlement hierarchy for the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Local Plan. Southern and Regional Developments (Willingham) believe that Willingham is inappropriately placed within the second tier of the adopted settlement hierarchy, which establishes the village as with lesser sustainability credentials than those placed in the top hierarchical tier. Willingham's current position within the adopted spatial hierarchy undermines the suitability of the village to accommodate moderate levels of residential development. It benefits from an established service base and is located within reasonable catchment of higher level services, such as secondary schools, within nearby villages. The site at Priest Lane also benefits from being within walking distance of a number of amenities within the settlement, including a medical practice and primary school which supports the suitability and sustainability and of the site and so its consideration for residential allocation. It is important to note that whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, the emerging Local Plan should avoid applying inappropriate reliance on the delivery of these allocations. The National Planning Policy Framework asserts at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the NPPF emphasises elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. Such sites can more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as at that identified at Priest Lane, Willingham. The delivery of such suitable sites should be encouraged through the strategy of the plan by affording a development quantum toward sustainable village. This policy requirement would required the development framework extents to be revised and the necessary market and affordable homes provided. It is essential for the emerging plan to requires such a review of village settlement limits, particualrly where they do not relate to Green Belt revision. Summary of Comments: A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

It is considered that the settlement hierarchy of the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Plan. Southern and Regional Developments (Waterbeach) believe that Waterbeach is inappropriately placed in the second tier of the hierarchy, which establishes that it is has lesser sustainability credentials than those villages placed in the highest tier. This downplays the impact that the railway station has on the accessibility of the village to public transport as well as the potential new services that will be delivered as part of the strategic New Town development. The emerging Greater Cambridge Plan therefore should review the position of Waterbeach within the settlement hierarchy and it is recommended that the settlement should be moved up within it, to better recognise that the village is a sustainable location for development. It is considered that if Waterbeach's position within the hierarchy is reviewed, it will allow suitable and appropriate opportunities to come forward at the village for residential development. This includes the site at Bannold Road, Waterbeach which is under control by Southern and Regional Developments (Waterbeach). Currently, the development potential of the site is limited by policy designations, including Green Belt, open countryside and the spatial strategy. However, if the Plan is to robustly review the new spatial strategy, including securing suitable and deliverable sites at sustainable settlement such as Waterbeach, a comprehensive re-assessment is required. Summary of Comments: A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

‘Protection of Open Space’ (Policy 67) Cambridge Local Plan 2018 4.1 Policy 67 of the Cambridge Local Plan (2018) currently requires the following when considering development proposals on areas of land protected as open space: “Development proposals will not be permitted which would harm the character of, or lead to the loss of, open space of environmental and/or recreational importance unless: a. the open space can be satisfactorily replaced in terms of quality, quantity and access with an equal or better standard than that which is proposed to be lost; and b. the re-provision is located within a short walk (400m) of the original site. In the case of school, college and university grounds, development may be permitted where it meets a demonstrable educational need and does not adversely affect playing fields or other formal sports provision on the site. Where replacement open space is to be provided in an alternative location, the replacement site/facility must be fully available for use before the area of open space to be lost can be redeveloped.” 4.2 The designation of protected open spaces within the Cambridge Local Plan is too broad, the policy serves to protect most spaces in the City for recreation and environmental ‘importance’, using a broad ‘catch all’ assessment criteria and then applies an overly restrictive 400m distance restriction to any relocation. The 400m restriction does not allow for any balance of the issues, or benefits that may be accrued from a relocation that happened to be over 400m away. 4.3 This is highlighted by land East of The Lawns which is identified within the Local Plan as a Protected Open Space and an Outdoor Sports Facility ‘Cambridge Tennis and Hockey Club’ (ref: SPO 06) (2.41 hectares). The site is identified as having both environmental and recreational importance within the Open Space and Recreation Strategy (2011), however, the Strategy does not set out in any further detail as to how this assessment has been made. It is therefore not clear how the Council have determined that the site is of environmental and recreational importance. 4.4 Para 7.48 of the Local Plan requires that replacement sites / facilities should be no more than a short walk (400m) from the site that is to be replaced. As shown on the map included at Appendix 2, the 400 metre radius around the site is heavily constrained and already features residential development, Green Belt land and other protected spaces. There is limited to no opportunity for re-providing the open space within a 400-metre radius of the site, if that was the appropriate response. Major benefits could be achieved, in theory, by providing for a new purpose-built facility that was more than 400m away, but the policy is overly-restrictive to not allow a judgement to be made. 4.5 The Appendix 2 Plan shows all the currently Protected Open Spaces and their 400m isochrones to reflect the 400m described in adopted Cambridge Policy 67. This vast protection of spaces arises through an assessment criteria that is too broad and essentially forms a ‘catch all’ approach, protecting whole sites, when for example the environmental ‘importance’ only applies to a part of the site; such as with the land east of The Lawns and its planted boundaries, but yet the whole site is protected. 4.6 The approach to recreation protection is also not a robust policy position. The land east of The Lawns has not been actively used since 2003, yet it is given the full protection of Policy 67 for its recreational importance. The Local Plan also requires that replacement sites/facilities should be provided so as not to increase any identified deficiencies in open space in the ward where the site is located. In the case of the land east of The Lawns, the site is located within the Newnham Ward, where no deficiencies are identified within the Open Space Strategy (2011). In this case the site would not lead to increasing deficiencies within Newnham, but this matter is not taken into account in making the designation, nor does Policy 67 allow for the same matter to be taken into account in application decision-making. On a related issue, Policy 67 does not relate well to NPPF paragraph 97 and its criterion (a) which allows for an assessment to be made to ascertain if the open space is surplus to requirements. 4.7 Paragraph 7.47 of the Local Plan identifies that there is a ‘clear presumption’ against the loss of open space of environmental or recreational importance, and that: “Any proposal involving the loss of open space must include an assessment (using the criteria listed in Appendix I) to determine the important aspects of the site that should be retained within the new development, in agreement with the Council. As part of any planning application, applicants will need to clearly demonstrate how the proposal will minimise its impact on the site’s intrinsic qualities and where possible enhance the remaining part of the site. Due regard must also be given to any potential impact on the character and wider setting of the site.” 4.8 The criteria used to assess open space in Cambridge are currently set out in Appendix I in the Local Plan. The criteria are summarised below alongside an assessment as to why the criteria are not useful in their current state, highlighted by example with land east of The Lawns. 4.9 As set out above, removing the site’s designation as a Protected Open Space will not lead to the loss of any sports/recreation facilities. ‘Community, Sports and Leisure Facilities’ (Policy 73) Cambridge Local Plan 2018 4.10 Policy 73 of the Cambridge Local Plan (2018) states the following: “The loss of a facility or site that was last in use as a community, sports or leisure facility will only be permitted if it is demonstrated that: i. the facility/site can be replaced within the new development or relocated to at least its existing scale, range, quality and accessibility for its users. For leisure uses, it should satisfy peak period need; or j. the facility/site is no longer needed.’’ ‘’In providing evidence that a facility/site is no longer needed, the guidance in Appendix K of the plan should be adhered to. The redevelopment of school sites for other uses will be permitted only if it can be demonstrated that they are not required in the longer term for continued educational use.’’ 4.11 In terms of the site, criterion j is considered to apply given that the site has not been used since 2003 and the facilities are no longer required. Paragraph K.3 of Appendix K requires that: “Proposals for either replacement or relocated facilities should demonstrate: a. equal or improved site accessibility to users by all means of transport including foot and cycle; and b. sufficient spare capacity or agreement to accommodate displaced users at other equivalent community/leisure facilities with similar accessibility for users. For existing leisure facilities, in the absence of a robust district-wide needs assessment/capacity assessment, applicants will be expected to carry out such an assessment at their own cost; and c. through local consultation, the level of interest in and viability of the continued use of the premises as a community/leisure facility.” 4.12 The Open Space and Recreation Strategy 2011 includes an assessment of sites identified on the Policies Map, including an assessment as to whether each site is important for environmental Page 10 and/or recreational reasons, according to the assessment criteria listed in Appendix I of the Local Plan. It also identifies those wards with deficiencies in open space provision. The Site is referenced to as site SPO 06 in the Newnham Ward profile, comprising 2.41 hectares. This includes the tennis courts to the south of the site. The site is assessed as having both environmental and recreational importance. 4.13 An updated Open Space Assessment is required for Cambridge, in accordance with Paragraph 96 of the National Planning Policy Framework (NPPF) which requires the following: ‘’Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate.’’ 4.14 Paragraph 97 of the NPPF requires the following: “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: ● An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or ● The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or ● The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss. 4.15 NPPF Paragraph 97 is considered to be the basis to assess this policy matter. This Policy sets out three criteria, but these are a series of ‘or’, so only one criterion has to be engaged and compliant. The first criterion is the appropriate test for the development proposal because the open space is considered to be surplus to requirements, in that the land has been unused since 2003 and has not contributed to the recreation offer in the area. An NPPF matter not reflected in adopted Policy 67. Summary 4.16 Policy 67 requires an overhaul so that it allows for a clearer NPPF para 97 structure and criteria assessment and to remove the 400m restriction, which is too onerous and could prevent a planning judgement being made to account for benefits of a relocation. The assessment criteria to determine whether an open space should be designated is based on PPG17 and should have an overhaul to ensure there is a robust assessment criteria, to underpin the Big Theme around biodiversity and green spaces. By example, Land east of the Lawns, Clerk Maxwell Road should not be a protected open space; it has only planted boundaries and has not been used since 2003; its continued designation undermines the policy.

• Policy 61: the lack of any Historic Environment Strategy should be a source of embarrassment for an historic city like Cambridge that is facing such profound change. It is also in breach of the NPPF. • The abuse of economic Viability Assessments by some developers to reduce the proportion of affordable housing agreed in the planning permission. Councils will need to develop policies that ensure much tighter regulation of the use of such assessments • It is CambridgePPF’s view that there are sound policies in the 2018 Plan that are becoming ineffectual because of inadequate enforcement and because of the government’s relaxation of permitted development rights. To address these the Councils need to invest in more resources. For example, South Cambs does not have a list of Buildings of Local Interest and Conservation Area Appraisals are non-existent or not up-to-date. This means there is a risk that heritage is not being adequately protected even though there are adequate policies in the Local Plan to protect heritage.

• Policy 80 in the Cambridge Local Plan is repeatedly ignored by the county council highway authority, who force car-dominant road schemes onto developments, thus killing any chances of walking and cycling priority or quality. This must be fixed. We cannot continue to allow developments to become dominated by car-centric highway designs. • Policy TI/2 in the South Cambridgeshire Local Plan is even worse because it does not commit to walking or cycling priority at all. That is not acceptable going forward. • Policy 82, Appendix L and the Cycle Parking Guide SPD together form the Cambridge cycle parking policies and guidance. However, it has clearly grown a bit unwieldy over the years, being spread across two documents in such a fashion. Furthermore, neither document accounts for inclusive cycle parking. Therefore, the cycle parking policies should be refactored, brought up to date with inclusive guidance, and presented in a clear and unambiguous fashion. There are numerous points that are poorly defined by the current Local Plan, including problems with diagonal cycle parking, multi-car garages, different types of cycle sheds, and two-tier racks. • The South Cambridgeshire Local Plan does not have a cycle parking guide at all, which means that developments in South Cambridgeshire often produce very poor quality cycle parking. • The observations and recommendations of Carmona (2020) should be given strong consideration as we develop the future Local Plan. Evidence for our response to Question 49. • Carmona, Matthew, et al (2020). A Housing Design Audit for England. Place Alliance.

In our village we now have four developments with roads built to adoptable standards but for which there is no Section 38 agreement and funding agreed. This leaves the dwellers (or in the case of affordable rent properties, the Housing Association) with the ongoing costs of road maintenance. This is a trend we deplore but are not sure if a Local Plan can include measures to alleviate this problem.

S/7: Development Frameworks 1.65 Policy S/7 is overly restrictive and can prevent small windfall sites on the edges of some of the districts more sustainable rural locations from coming forward. The approach to directing new residential development to the most sustainable locations in the district is a sound planning principle. However, as presently worded Policy S/7 does not allow for the most effective use of land in sustainable locations where the impact upon the countryside would be limited. 1.66 For example, an application for a dwelling outside the development framework of Cottenham, which could be outside the Green Belt and in close proximity to the services of this Rural Centre, would be refused under Policy S/7. Whereas, a dwelling within the development framework of Knapwell, an Infill Village with no services, would be approved. The need to prevent gradual encroachment into the countryside is acknowledged but where edge of village development is sensitive to its locality then planners should have greater flexibility to look at the individual merits of a site based on proximity to services, degree of enclosure, etc. This would allow them to exercise their own planning judgement as to whether the proposal result in a sustainable form of development that would outweigh any impact upon the rural landscape. 1.67 Other Local Planning Authorities are proposing policies that are more flexible when it comes to considering developments on the edges of settlements. As part of the 2019 review of its Local Plan West Norfolk and Kings Lynn Borough Council has included the following Policy LP26 (Residential Development Adjacent to Existing Settlements). This policy allows greater flexibility to the development of land on the edges of settlements, outside development boundaries, where the criteria of the policy are met. It also attaches weight to the use of such land to accommodate self-build dwellings. 1.68 The Greater Cambridge Local plan should consider a similarly worded policy that identifies the criteria for small-scale developments on the edges of settlements, outside development frameworks, that infill gaps or are sensitive to the locality. By attaching weight to the provision of plots for self-build such a policy could boost the supply of housing and address the needs of people on the Councils’ self-build registers. H/16: Development of Residential Gardens 1.69 The criteria of policy H/16 do not specifically preclude the development of land outside of development frameworks. However, developments within existing gardens, or land last used as residential garden, are being refused based on not being compliant with Policy S/7. Therefore, the wording of this Policy needs to be updated to clarify that the development of existing residential gardens outside of development frameworks, where encroachment of residential uses has already occurred, is acceptable in sustainable locations. These are also ideal locations where an amended wording of the Policy could encourage the effective use of land to accommodate self-build plots. E/14: Loss of Employment Land to Non-Employment Uses 1.70 Policy E/14 is a useful tool in retaining employment sites but there are examples of where the strict interpretation of the criteria of the policy have delayed acceptable developments from coming forward. The former Plumbs Dairy site in Balsham is a site that would never have been suitable as a modern employment site. However, an application for residential use of the site was almost refused due to a lack of marketing of the site (S/0460/17/FL). The site had significant constraints that meant a residential use was the only option for the redevelopment of the site. The case officer successfully argued that the development of the site for residential was acceptable without it being marketed as an employment site. The use of the site for employment had ceased after the dairy relocated to Linton and the site was only viable as a development site with the addition of adjacent garden land. However, if the case officer had blindly adhered to the strict criteria of Policy E/14 the site would not have been developed and would most likely have remained vacant for a further 12 months until it had been marketed as an employment site. 1.71 The criteria of Policy E/14 should be amended so that officers have greater flexibility to take other material considerations, such as the commercial viability of redeveloping existing employment sites to meet modern employment requirements, into account when determining planning applications. Where such sites are in sustainable locations a more flexible approach to loss of out-dated and constrained employment sites will help to boost the supply of new homes by making the most efficient use of previously developed land.

S/7: Development Frameworks 1.63 Policy S/7 is overly restrictive and can prevent small windfall sites on the edges of some of the districts more sustainable rural locations from coming forward. The approach to directing new residential development to the most sustainable locations in the district is a sound planning principle. However, as presently worded Policy S/7 does not allow for the most effective use of land in sustainable locations where the impact upon the countryside would be limited. 1.64 For example, an application for a dwelling outside the development framework of Cottenham, which could be outside the Green Belt and in close proximity to the services of this Rural Centre, would be refused under Policy S/7. Whereas, a dwelling within the development framework of Knapwell, an Infill Village with no services, would be approved. The need to prevent gradual encroachment into the countryside is acknowledged but where edge of village development is sensitive to its locality then planners should have greater flexibility to look at the individual merits of a site based on proximity to services, degree of enclosure, etc. This would allow them to exercise their own planning judgement as to whether the proposal result in a sustainable form of development that would outweigh any impact upon the rural landscape. 1.65 Other Local Planning Authorities are proposing policies that are more flexible when it comes to considering developments on the edges of settlements. As part of the 2019 review of its Local Plan West Norfolk and Kings Lynn Borough Council has included the following Policy LP26 (Residential Development Adjacent to Existing Settlements). This policy allows greater flexibility to the development of land on the edges of settlements, outside development boundaries, where the criteria of the policy are met. It also attaches weight to the use of such land to accommodate self-build dwellings. 1.66 The Greater Cambridge Local plan should consider a similarly worded policy that identifies the criteria for small-scale developments on the edges of settlements, outside development frameworks, that infill gaps or are sensitive to the locality. By attaching weight to the provision of plots for self-build such a policy could boost the supply of housing and address the needs of people on the Councils’ self-build registers. H/16: Development of Residential Gardens 1.67 The criteria of policy H/16 do not specifically preclude the development of land outside of development frameworks. However, developments within existing gardens, or land last used as residential garden, are being refused based on not being compliant with Policy S/7. Therefore, the wording of this Policy needs to be updated to clarify that the development of existing residential gardens outside of development frameworks, where encroachment of residential uses has already occurred, is acceptable in sustainable locations. These are also ideal locations where an amended wording of the Policy could encourage the effective use of land to accommodate self-build plots. E/14: Loss of Employment Land to Non-Employment Uses 1.68 Policy E/14 is a useful tool in retaining employment sites but there are examples of where the strict interpretation of the criteria of the policy have delayed acceptable developments from coming forward. The former Plumbs Dairy site in Balsham is a site that would never have been suitable as a modern employment site. However, an application for residential use of the site was almost refused due to a lack of marketing of the site (S/0460/17/FL). The site had significant constraints that meant a residential use was the only option for the redevelopment of the site. The case officer successfully argued that the development of the site for residential was acceptable without it being marketed as an employment site. The use of the site for employment had ceased after the dairy relocated to Linton and the site was only viable as a development site with the addition of adjacent garden land. However, if the case officer had blindly adhered to the strict criteria of Policy E/14 the site would not have been developed and would most likely have remained vacant for a further 12 months until it had been marketed as an employment site. 1.69 The criteria of Policy E/14 should be amended so that officers have greater flexibility to take other material considerations, such as the commercial viability of redeveloping existing employment sites to meet modern employment requirements, into account when determining planning applications. Where such sites are in sustainable locations a more flexible approach to loss of out-dated and constrained employment sites will help to boost the supply of new homes by making the most efficient use of previously developed land.

• Policy 80 in the Cambridge Local Plan is continually ignored by the county council highway authority, who force car-dominant road schemes onto developments, thus killing any chances of walking and cycling priority or quality. This must be fixed. We cannot continue to allow developments to become dominated by car-centric highway designs. • Policy TI/2 in the South Cambridgeshire Local Plan is even worse because it does not commit to walking or cycling priority at all. That is not acceptable going forward. • Policy 82, Appendix L and the Cycle Parking Guide SPD together form the Cambridge cycle parking policies and guidance. These should be updated to be brought up to date with inclusive guidance and presented in a clear and unambiguous fashion. Camcycle must be consulted during the updating process. • The South Cambridgeshire Local Plan does not have a cycle parking guide at all, which means that developments in South Cambridgeshire often produce very poor quality cycle parking.

SCDC Local Plan 2018 policy S/7 appears to be interpreted by the Council's officers as repeating the former LDF policy DP/7. However S/7 has an additional criterion, whereby outside development frameworks "other uses which need to be located in the countryside or where supported by other policies in this plan will be permitted." One such policy in the SCDC Local Plan 2018 is H/16: Development of Residential Gardens. This states that development of land used or last used as residential gardens for new dwellings will be permitted subject to criteria relating to character, highway and amenity impacts. There is nothing in the wording of the policy or its sub-text to suggest that the policy does not apply to the whole District. The wording of the policy itself protects all potential sites (whether inside or outside village frameworks) from inappropriate development, as required by, and in compliance with NPPF paragraph 70.

It is considered that the settlement hierarchy for the adopted South Cambridgeshire Local Plan should be comprehensively reviewed as part of the emerging Greater Cambridge Local Plan. Southern and Regional Developments (Swavesey) believe that Swavesey is inappropriately placed within the second tier of the adopted settlement hierarchy, which establishes the village as with lesser sustainability credentials than those placed in the top hierarchical tier. Swaveseys's current position within the adopted spatial hierarchy undermines the suitability of the village to accommodate moderate levels of residential development. It benefits from an established service base, which includes services such as a secondary school which minimises the need to travel beyond the village to access amenities. Southern and Regional Development's site at Boxworth End benefits from being within walking distance of a number of amenities within the settlement, including a medical practice, primary and secondary schools which supports the suitability and sustainability of the site and so its consideration for residential allocation. It is also important to note that whilst it has been historically demonstrated that strategic allocations and delivery of new settlements has contributed significantly to achieving the housing requirement for South Cambridgeshire, such as at Cambourne, the emerging Local Plan should apply inappropriate reliance on the delivery of these allocations. The National Planning Policy Framework sets out at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the Framework emphasis elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. These sites can therefore more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. It is maintained that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as that at Boxworth End, Swavesey. Summary of Comments: A review of the South Cambridgeshire settlement hierarchy is recommended to ensure that an appropriate new spatial strategy is established.

See comments above in relation to historic environment policies and tall buildings policies.

4.102 As highlighted in Section 6 of the Logistics Need Report the Adopted Local Plan aims to “ensure there is sufficient employment land available, in the right places to support the economy”14 and support a target of 22,000 new jobs being provided in the district by 2031. 4.103 Reflecting the role of research and development in the economy, the Plan rightly places a strong emphasis on providing opportunities for new high technology and research and development at various locations close to the boundary with Cambridge City including Granta Park, Babraham Institute and the Wellcome Trust Genome Campus, in addition to Cambridge Science Park through Policy E/1. 4.104 In addition to the sites identified above, the Plan allocates further land for B1 uses at the following sites: • Policy E/2 - Extension to Cambridge Biomedical Campus to provide for biomedical and biotechnology research and development; 14 South Cambridgeshire District Council (2018) South Cambridgeshire Local Plan, p. 171 • Policy E/3 - Land adjoining Peterhouse Technology Park for B1 employment uses; • Policy E/4 – Land North of Hatton Road, Longstanton and Pampisford for B1 employment uses; and • Policy E/5 – Land at Norman Way, Over (1.7 ha.) and Land at Papworth Everard (2.5 ha.) for B1, B2 and B8 employment uses. 4.105 Policy E/9 of the Local Plan places importance on the promotion of employment clusters in the following sectors: • Biotechnology and biomedical; • Computer services; • Electronic engineering; • High-technology manufacturing; • Information technology / telecommunications; • Healthcare, teaching and research; • Research and development; • Clean Technology; and • Other locally driven clusters as they emerge. 4.106 The adopted Local Plan also aims to provide opportunities for a wider range of other employment that supports sustainable economic growth. However, whilst proposals for warehousing that supports other employment uses or meets local needs are supported, it is of note currently only two sites are allocated for B1, B2 and B8 use under policy Policy E/5: • Land at Norman Way, Over (1.7 ha); and • Land at Papworth Everard (2.5 ha). 4.107 Furthermore, in terms of logistics Policy E/11 explicitly states that ‘Large scale warehousing and distribution centres will not be permitted in the district’. The Council justify this approach at Paragraph 8.51 of the supporting text to the policy on the basis that: “These uses require a large land area, but generate relatively low numbers of jobs. They could quickly reduce the available land supply, and increase pressure on transport networks, which could harm the continued prosperity of the high technology clusters” 4.108 Moreover and despite having only been adopted in the last two years it is of note that the above Local Plan policies are informed by evidence15 produced nearly 8 years ago 15 SQW (2012) Employment Land Review Update and Review of Selective Management of Employment Policies: Report to South Cambridgeshire District Council and Cambridge City Council in 2012. In the intervening period the economic context has changed substantively, not least as a consequence of the strong growth in e-commerce. 4.109 Whilst growth on the scale witnessed in the intervening period might not have been foreseen in 2012, this evidence did identify the industrial and distribution sector as being an essential component of the local economy, which at the time was predominantly tied to servicing the R&D sector, Offices and Colleges. Although the market was perceived to be smaller than the regional key large scale distribution hubs of Peterborough and Bedford, there was also evidence of medium size requirements extending along the A1, A10 and A14 corridors, many of which at the time were not being satisfied. It is also notable that although there were fewer large scale occupiers in comparison to the wider region, this was primarily due to the shortage of large buildings to take up this demand16. 4.110 It follows that whilst the role of the sector was evidently apparent, the adopted Local Plan currently does very little to accommodate these needs. Whilst no evidence has yet been published by the Councils to confirm the extent of the shortage of industrial and warehouse land, the earlier sections of this report present unequivocal evidence that a growing need for such land in the Greater Cambridge area does in fact still exist. 4.111 In view of the need to maintain the economic buoyancy of the area, and in the context of the updated requirements of the NPPF and PPG, this evidently represents an important consideration for the emerging Joint Local Plan. 4.112 Indeed, failing to respond positively to identified needs will only serve to further constrain demand and sustainable logistics responses to satisfy consumer demand and the needs of businesses which form a critical part of the areas supply chain. 4.113 The Greater Cambridge Sustainable Design and Construction Supplementary Planning Document provides guidance on achieving the relevant sustainability policy the requirements of Sustainability Statements. The SPD acknowledges that current policy (in particular Policy 28) does not take a life cycle approach to reducing carbon emissions and focuses only on the operation of completed development. The SPD therefore introduces a suggestion for new development to strive to reduce carbon emissions from construction. 4.114 As set out within our response to Question 8, we would welcome a fair and flexible approach to net zero carbon which also includes consideration of embodied carbon. 4.115 One of the requirements within the SPD is for non-residential development to achieve BREEAM ‘Excellent’ rating. Whilst Newlands acknowledges that BREEAM can be an effective marketing tool, it does not necessarily deliver (or reward) sustainable buildings. The recent delivery of the BREEAM New Construction 2018 update was marred with issues including the oversight of SAP10 factors and a re-write of Land Use and Ecology credits after ecologists voiced concern over the feasibility and implementation of this section. The issues relating to energy have been partially fixed as they now include SAP10 factors, however there have been instances where all 16 Ibid, pX electric buildings which achieve a 30% carbon reduction on site under current building regulations do not meet the mandatory number of credits under Ene 01. These issues are largely related to the BRE methodology disproportionally awarding credits based on low energy demands rather than on-site energy generation which can negatively impact buildings with large on-site energy loads such as process and manufacturing industrial units. Requiring BREEAM ‘Excellent’ can also affect the viability of a development, with inflexible credit criteria requiring additional consultants to be appointed prior to Planning Submission. An example of this is within credit Hea 06 (exemplary criteria) which requires SABRE assessments (a new standard developed by the BRE) to be undertaken at an early stage in the development. 4.116 Instead of requiring BREEAM, it is suggested that the approach to sustainable development is communicated by the developer through a Sustainability Statement, which clearly outlines the credentials of the proposed development in line with policy. Delivering net zero carbon buildings should not come at the expense of the implementation and cost of BREEAM given the current state of Climate Emergency. Furthermore, implementing policies requiring a net biodiversity gain, climate resilience, and consideration of public health and well-being will deliver buildings with a holistic approach to sustainability in support of Greater Cambridge’s aspirations to be a sustainable and net zero carbon society.

Policy 61: Lack of any Historic Environment Strategy: a disgrace for an historic city like Cambridge that is facing such profound change: also in breach of the NPPF.

European Property Ventures (Cambridgehire) maitnain that whilst it has been historically demonstrated that strategic allocations and delivery of new settlements can contribute significantly to achieving the housing requirement for South Cambridgeshire, the emerging Local Plan should not apply inappropriate reliance on the delivery of further largescale allocations. The National Planning Policy Framework asserts at Paragraph 72 that strategic allocations can deliver a substantial number of homes and make a valuable contribution to the supply of housing to a Local Plan. However, it also advises that these allocations must include realistic delivery rates due to their long lead-in times. As such, the Framework emphasis elsewhere at Paragraph 68 that spatial strategies must also include small to medium sites for development, given that they experience faster build-out rates and therefore can make more rapid contributions to the housing requirement of the Plan. These sites can therefore can more robustly maintain a housing trajectory in circumstances where delays to the delivery of strategic allocations may result in significant detriment to the housing position of a Planning Authority. Euopean Property Ventures (Cambridgeshire) instead content that the emerging Greater Cambridge Local Plan should consider a range of small to medium sites, to ensure that the housing supply position of the new Plan is maintained. This should include consideration of sites such as Dry Drayton Road, Oakington. The current adopted spatial strategy and settlement hierarchy of the South Cambridgeshire Local Plan should be comprehensively reviewed to ensure that appropriate villages can be identified to accommodate additional levels of growth to meet the needs of the new Plan period. Although the dopte development plan identifies somesmaller settlements as appropriate in accommodating development, the new plan should go further by actively dsitributing development quantum amongst lower order settlements, including thorugh re-asessment of settlements which are currently regarded as unsuitable. Oakington is not currently recognised as a sustainable location to accommodate levels of development being promoted by European Property Ventures(Cambridgeshire) as their site on Dry Drayton Road. This is not an effective approach, as it undermines the practical sustainability credentials that are identifiable within the village, such as its service base and accessibility to public transport given the close relationhip to Northstowe. The spatial strategy should ensure that appropriate consideration is given to the new Plan to identify where moderate levels of growth can be achieved. This will in turn contribute towards meeting the strategic requirements of the new Local Plan, in particular the residential need of Plan area, as well as the local need within Oakington. Currently, without a robust re-assessment of the spatial strategy, such sites may be omitted from the new Plan which will undermine its ability in seeking a sufficient number of sites to meet the strategic housing need of the new Plan period. Directing development towards sustainable villages, including Oakington, should be regarded as a significant component of the new spatial strategy that demonstrates a deliverable approach to spatial planning. Summary of Comments: The most sustainable settlements recognised in the South Cambs hierarchy should be reinforced and supported to accommodate new growth.

It is unclear for the adopted 2018 Local Plan, how the Inspectors recommendations and main modifications are being implemented, managed and monitored. Is this is being undertaken by the LPA's or are the main modifications being implemented? It is unclear what status the existing adopted Local Plan holds with the Local Authorities in it's importance when deciding planning applications and Supplementary Planning Documents: https://www.scambs.gov.uk/media/12102/south-cambs-report-final.pdf https://www.scambs.gov.uk/media/12103/south-cambs-report-appendix-1.pdf