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

‘Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area’ (Policy 25) Cambridge Local Plan 2018 8.1 Kett House 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 Brookgate and Aviva are 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. As 10 Station Road currently falls outside, but is adjacent to the Opportunity Area, this land should also be included within the Policy area. ‘Station Areas West and Clifton Road Area of Major Change’ (Policy 21) Cambridge Local Plan (2018) 8.4 The site is located in the Station Areas West and Clifton Road Area of Major Change in the adopted Cambridge Local Plan (2018) under Policy 21. The Policy supports the continued and complete regeneration of vibrant, mixed-use areas of the city, centred around and accessible to a high quality and improved transport interchange. Kett House and 10 Station Road is not identified for specific development under Policy 21. 8.5 Brookgate and Aviva 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.

Summary: The new Local Plan should take a less restrictive approach to growth within villages than the policies in the adopted South Cambridgeshire Local Plan. Full comment: Do you have any views on any specific policies in the two adopted 2018 Local Plans? If so, what are they? In view of the acute need to provide new housing, which will also be required to the support economic growth of the area, it is important to move away from the current restrictive housing limits set out in the South Cambridgeshire Local Plan for the villages. While it is important to ensure villages grow in a sustainable manner, the limitation of growth, particuarly on Minor Rural Centre (Policy S/9), which are sustainble locations for development, is too restrictive. The services and facilities offered by Minor Rural Centres will stagnate and not attract additional provision which could lead to a further loss of existing service and faciliates. It is considered that the settlement hierachy needs to be revisited to ensure that it is fit for purpose but it is clear that Rural Centres and Minor Rural Centres like Fulbourn will play a significant role in meeting future housing needs, partciuarly those that have sustainable links into Cambridge and established employment areas. Therefore, the current restrictive regime towards future growth should be removed and development should be considered on a case-by-case basis rather than by an arbitrary figure.

26. It is not clear whether the intention is to replace or review existing adopted Local Plan policies. Therefore, the abovementioned points relating to general policy strategy for the provision of education should be considered as the context for the specific policy changes proposed below. If entirely new policies are to be produced, then the below suggestions indicate the direction of travel, as well as the general themes implied above. Education Policies 27. Education provision through Free Schools seeks to provide not only school places to meet basic need and need generated by new development, but also to enhance choice, improve quality and deliver specialist education provision. Therefore, the following adopted policies relating to education are considered to be out of date in this respect, and not wholly compliant with the NPPF paragraph 94 (which seeks to ensure sufficient choice of school places) nor are the policies positively prepared. Specialist schools are a key opportunity for increasing choice, enhancing opportunity and skills and providing a high quality variety of education provision. As such, some schools may have a wider catchment area, providing a regional education offer rather than just local. This would also be the case for other types of specialist provision, including SEN schools and faith schools. 28. SCDC Policy TI/9 / CCC Policy 74: ‘Education Facilities’ as adopted, are too narrow to sufficiently support the delivery of Free Schools, in consideration of the specialist provision that they can offer, and the wider catchment associated. The policies are based on a sole Local Authority delivery model which is no longer the way in which schools are delivered. 29. Therefore, we would propose the following changes to the policy wording, in order to fully recognise this nature of provision: SCDC Policy TI/9: 1. PLEASE SEE ATTACHED DOCUMENT - PAGE 5 FOR COMMENTS TO THIS SECTION a. Improve the scale, range, quality and accessibility of education provision; b. Be appropriately located to for the existing and future communities they serve; c. Be delivered and phased appropriately alongside Mitigate the impact of any associated residential development; and d. Comply with the strategic objectives of Cambridgeshire County Council, the local Children’s Services Authority, National Policy regarding the delivery of school places and/or the ambition of the community they serve. 2. The Council will work with the County Council and the Department for Education to provide high quality and convenient local education services in all parts of the district, but particularly in areas of population growth. 3. Developers should engage with the Children’s Services Authority at the earliest opportunity and work co-operatively to ensure the phasing of residential development and appropriate mitigation is identified in a timely manner to ensure appropriate education provision can be secured. 4. PLEASE SEE ATTACHED DOCUMENT - PAGE 6 FOR COMMENTS TO THIS SECTION CCC Policy 74: New or enhanced education facilities will be permitted if: a. the scale, range, quality and accessibility of education facilities are improved; b. PLEASE SEE ATTACHED DOCUMENT - PAGE 6 FOR COMMENTS TO THIS SECTION; c. PLEASE SEE ATTACHED DOCUMENT - PAGE 6 FOR COMMENTS TO THIS SECTION; d. they comply with the strategic objectives of the Children’s Services Authority and National Policy regarding the delivery of school places. The Council will work with the Children’s Services Authority and the Department for Education to provide high quality and convenient local education services in all parts of Cambridge, but particularly in areas of population growth. Developers should engage with the Children’s Services Authority at the earliest opportunity and work cooperatively to ensure the phasing of residential development and appropriate mitigation is identified in a timely manner to ensure appropriate education provision can be secured. Planning permission will be granted for new education facilities in locations accessible by walking, cycling and public transport, where this will meet an existing deficiency, and support regeneration or new development or achieve wider educational needs for quality enhancement and/or specialist provision. Land Use Policies 30. SCDC Policy E/14: Loss of employment and CCC Policy 41: Protection of business space would prevent employment sites and uses being diversified to provide education uses. We would propose that an additional criterion is added to allow for the change of use to community uses and social infrastructure, without the need for marketing tests or viability evidence. This is to allow for the positive planning of educational establishments, in areas where land supply can be challenging. The economic and knowledge generating benefits of education provision should be considered from a policy perspective (in terms of meeting the overall aims for sustainable development) and supported through the Local Plan. 31. CCC Policy 11: Development in the City Centre Primary Shopping Area should remove the 70% requirement for A1 uses. The High Street character is changing, and therefore there is a need for planning policy to allow greater flexibility and include further uses which can enhance the town centre, such as education, more freely within the PSA. 32. CCC Site Allocations Policies for Areas of Major Change (including Policy 12: Fitzroy/Burleigh Street/Grafton Area of Major Change and Policy 15: Cambridge Northern Fringe East and new railway station Area of Major Change) do not all currently refer to the potential inclusion or acceptability of D1 uses. We would suggest that D1 uses be more expressly supported in these policies to create a more positive policy context for education provision. Development Management Policies 33. SCDC Policy SC/8: Protection of Existing Recreation Areas, Allotments and Community Orchards, as drafted, does not differentiate between publicly accessible open space and playing fields, and school playing fields which do not typically have unrestricted access by the public. 34. The NPPF (2019) sets out at paragraph 97 that: 97. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or b) 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 c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use. 35. It is important that the Local Plan allows flexibility to allow the provision of educational facilities, where there is a clear overall benefit in terms of enhanced facilities provision (taking into account local needs), despite a potential limited loss in the quantity of existing facilities, such as a new school providing indoor and outdoor facilities for sport of significantly improved quality, accessibility and availability for shared use by the local community (secured through a community use agreement if appropriate). It should be acknowledged that enhancements can take the form of both quality as well as quantity and as such, any quantitative loss may be more than compensated by qualitative enhancements. This flexibility will enable greater benefits to health and wellbeing. Policy SC/8 should be updated to reflect this context. 36. CCC Policy 67: ‘Protection of Open Space’ includes a relevant caveat for schools, which should be further reworded as follows: PLEASE SEE ATTACHED DOCUMENT - PAGE 8 FOR COMMENTS TO THIS SECTION 37. South Cambridgeshire Policy HQ/2 requires development over 1,000 sq m to provide or contribute to the provision of public art. The delivery of schools should not be burdened by challenging and onerous obligations. These requirements can add not only significant cost to projects (which does not assist in securing value for money) but it can also challenge the construction efficiencies for new schools and significant expansions. The DfE has produced guidelines for mainstream school areas, known as ‘BB103’.6 It is important that the compliance with BB103 is not hampered by additional demands made on sites at a local policy level. In relation to this, the Educational Building and Development Officers Group (EBDOG) has published Capital Efficiency Guidance (2019) with DfE, and advises against such blanket policy approaches.7 Therefore, we would propose that the policy include a caveat to expressly exclude social infrastructure from this requirement. Forward Funding 38. DfE loans to forward fund schools as part of large residential developments may be of interest, for example if viability becomes an issue. Please see the Developer Loans for Schools prospectus for more information.8 Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed. Evidence Base 39. An up to date Infrastructure Delivery Plan should be developed alongside the next iteration of the Plan, setting out clearly how the forecast housing growth at allocated sites has been translated (via an evidence based pupil yield calculation) into an identified need for specific numbers of school places and new schools over the plan period. This would help to demonstrate that the approach to the planning and delivery of education infrastructure is justified and based on proportionate evidence, and the wider Government policy context relating to the provision of school places to meet both basic need and widen choice in education. It would also be helpful if this related to the Infrastructure Funding Statement9 and Cambridgeshire County Council school place planning document, to ensure that the approach is joined up and there is a link between need, delivery and funding requirements (and funding sought) identified. The statement should be reviewed annually to report on the amount of funding received via developer contributions and how it has been used, providing transparency to all stakeholders. 40. Viability assessment should inform options analysis and site selection, with site typologies reflecting the type and size of developments that are envisaged in the borough/district. This enables an informed judgement about which developments would be able to deliver the range of infrastructure required, including schools, leading to policy requirements that are fair, realistic and evidence-based. In accordance with Planning Practice Guidance, there should be an initial assumption that applicable developments will provide both land and funding for the construction of new schools. The total cumulative cost of complying with all relevant policies should not undermine deliverability of the plan, so it is important that anticipated education needs and costs of provision are incorporated at the outset, to inform local decisions about site selection and infrastructure priorities.10 41. Given the significant cross-boundary movement of school pupils between SCDC/CCC and adjoining areas, DfE recommends that the Council covers this matter and progress in cooperating to address it, as well as engagement with Cambridgeshire County Council as part of its Statement of Common Ground.11 This should be regularly updated during the plan-making process to reflect emerging agreements between participating authorities and the Council's own plan-making progress. Developer Contributions and Community Infrastructure Levy (CIL) 42. One of the tests of soundness is that a Local Plan is ‘effective’, meaning the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments. DfE notes that there is no specific reference in the Plan to either existing or proposed Planning Obligations SPD, which should be developed/updated to reflect the new Plan priorities, and that the Councils will consider whether a review CIL rates is required to ensure appropriate rates are levied and the right infrastructure is secured across the borough. 43. DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability assessment or other evidence relevant to education which may be used to inform local planning policies and CIL charging schedules. As such, please add DfE to the database for future consultations on relevant plans and proposals.

‘Fulbourn and Ida Darwin Hospitals’ (Policy H/3) South Cambridgeshire Local Plan (2018) 9.1 The site is adjacent to but not currently within the area designated under Policy H/3 which allows for the redevelopment of the Ida Darwin Hospital comprising residential development and new mental health facilities at the Fulbourn Hospital Site. 9.2 It is requested that Policy H/3 be extended to include Land at Capital Park as it is considered a suitable and sustainable location for additional development. Above: Extract from South Cambridgeshire District Local Plan (2018)

2.37 Policy E/7 of the 2018 Local Plan is very much welcomed by the IWM as it positively supports the operation of the site and its potential to evolve.

No response proposed.

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.

Policy S/10 – Group Villages. As currently worded, the Policy does not allow villages like Orwell to grow. As a consequence, given improvements to facilities, local services and infrastructure are often a result of development, the existing policy does not allow villages to become more sustainable and/or provide for a diversity of population (for example, providing suitable properties for existing residents to downsize allowing new families to move in). We therefore suggest, the emerging Local Plan is more flexible to development on the edge of a Village which will align with the NPPF and provide opportunities for sustainable growth alongside supporting and enhancing local services.

‘Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area’ (Policy 25) Cambridge Local Plan 2018 9.1 Land to the south of Bateman Street 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 Trinity Hall are fully supportive of the aims and objectives of Policy 25 and the drive to deliver an improved public realm along Hills 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 Land south of Bateman Street is currently excluded from the ‘Station Areas West and Clifton Road Area of Major Change’, under Policy 21 (see Figure 1.3 below). 9.5 Land to the south of Bateman Street has an important role to play in the continuing redevelopment and revitalisation of the emerging central business district along Station Road and Hills 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 to the south of Bateman Street.

‘Important Countryside Frontage’ (Policy NH/13) South Cambridgeshire Local Plan (2018) 8.1 The boundary of Land off Station Road is noted as important countryside frontage in the adopted Local Plan under Policy NH/13. There is however a two-metre-tall evergreen hedge along its length that prevents visual access to the countryside. Policy NH/13 restricts planning permissions for development if it would compromise the underlying purposes of the Policy which are to provide a rural break between detached parts of a development framework. 8.2 Residential development on Land to the south of Station Road could be brought forward without compromising the purpose of this Policy. Notwithstanding this, it is proposed that a review of the Policy NH/13 (Important Countryside Frontages) should be undertaken as part of the emerging Greater Cambridge Local Plan to assess whether land currently subject to the designation still serves the purpose of Important Countryside Frontages.

4.76 The polices have provided a strict hierarchical approach to development that has not supported the growth and vitality of the rural areas. The line drawn that defines whether a site is within the development framework boundary or outside has no regard to the contribution a piece of land contributes to the area. The boundaries have not necessarily been viewed on the ground for effectiveness and yet the impact on the decision process is significant. The NPPF seeks to promote sustainable development in rural areas, paragraphs 77 to 78. Of critical importance is paragraph 78 where it states “Planning policies should identify opportunities for villages to grow and thrive, especially where there this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.” This is relevant in the case for Meldreth and Melbourn where there are a range of facilities, but the boundaries are strictly drawn. 4.77 Policy S/6 – This policy sets out the hierarchy and preference of order for development on the edge of Cambridge, new settlements and lastly the rural area, rural centres and minor rural centres. 4.78 S/9 – This policy classifies Melbourn as a minor rural centre where development up to 30 units would be allowed within the development framework boundary. 4.79 S/10 - This policy classifies Meldreth as a group village where development up to 8 dwellings within the framework may be appropriate. 4.80 The focus for the classification is based on a review of services and facilities, education, public transport, and employment available at the settlement.

4.75 The polices have provided a strict hierarchical approach to development that has not supported the growth and vitality of the rural areas. The line drawn that defines whether a site is within the development framework boundary or outside has no regard to the contribution a piece of land contributes to the area. The boundaries have not necessarily been viewed on the ground for effectiveness and yet the impact on the decision process is significant. The NPPF seeks to promote sustainable development in rural areas, paragraphs 77 to 78. Of critical importance is paragraph 78 where it states “Planning policies should identify opportunities for villages to grow and thrive, especially where there this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.” This is relevant in the case for Meldreth and Melbourn where there are a range of facilities, but the boundaries are strictly drawn. 4.76 Policy S/6 – This policy sets out the hierarchy and preference of order for development on the edge of Cambridge, new settlements and lastly the rural area, rural centres and minor rural centres. 4.77 S/9 – This policy classifies Melbourn as a minor rural centre where development up to 30 units would be allowed within the development framework boundary. 4.78 S/10 - This policy classifies Meldreth as a group village where development up to 8 dwellings within the framework may be appropriate. 4.79 The focus for the classification is based on a review of services and facilities, education, public transport, and employment available at the settlement.

Policy E/9 of the adopted South Cambridgeshire Local Plan (2018) supports the provision of existing and new emerging clusters. The policy explicitly recognises the need for flexibility to accommodate future opportunities and positively anticipates and provides for new unforeseen clusters emerging. It is considered that this is an important policy as it supports potential new clusters that may emerge during the plans lifetime that could not have reasonably been anticipated at the time of its preparation. This policy has supported the expansion to the unallocated Wellcome Trust expansion and also supports the proposals that have come forward relating to the AgriTech Park. By supporting the provision of new clusters, this policy is compliant with the NPPF and helps support a strong and diverse economy. The policy supports existing and new businesses and the benefits this can bring to both local and national economies. We consider that a policy that adopts a continued flexible approach such as this should be incorporated in the new local plan.

Policy NH/13: Important Countryside Frontage of the South Cambridgeshire Local Plan 2018 is unnecessary as a policy designation. In the interest of allowing villages flexibility to grow, the Council should look to review the need for such a restrictive policy, especially when other landscape and countryside policies apply.

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 of less, potentially over 266 sites will need to be found in the rural areas and a similar supply of medium sized site 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.

It is considered that the current Important Countryside Frontage designation (Policy NH/13 of the South Cambridgeshire Local Plan 2018) directly affects the opportunity for some villages to grow. It is requested that the current Important Countryside Frontage policy and designations are reviewed in order to determine the extent of the frontage that needs to be retained and whether some or all of the land to the rear could be developed. In most villages there are a variety of designations that prevent or limit the opportunity for development including Conservation Areas, Listed Buildings, Protected Open Space and Protected Village Amenity Areas. It is considered that the Important Countryside Frontage designation adds a further policy layer preventing the delivery of development in those villages where it applies. It is requested that the Important Countryside Frontage designations are reviewed and amended through emerging GCLP so that suitable sites are allocated and identified development needs are met. It is considered that a suitably designed development could be delivered at most sites promoted by EDBF where the Important Countryside Frontage applies, which protects and retains the character of the site frontage and provides additional landscaping at the site boundary in conjunction with additional housing and open space. This approach would allow for some small-scale growth at the villages where EDBF is promoting sites for development.

We support the delivery of the adopted Local Plans. We reiterate that we believe this Plan should have a strategic reach through to 2050, with a detailed set of plans for the delivery, in terms of zonal allocation, permission-in-principle where appropriate, and site selection, in respect of the 5-year periods from 2020 to 2040.

We strongly support existing Policy 67 in the current plan with its intention to provide for ‘the protection of Open Space of environmental and or recreational value from development.’ The principle of this policy should be retained.However we are very concerned that the validity of Policy 67 is being challenged by a would-be developer of Protected Open Space relying on a QC’s Opinion claiming the Policy is unworkable, with reference to requirement for relocation of Protected Open Space of recreational value to with 400m of the existing Protected Open Space. The Policy should be so worded, including amendment if necessary to effectively maintain Protected Open Space of environmental and or recreational value..

‘Mill Road Opportunity Area’ (Policy 24) Cambridge Local Plan 2018 9.1 The Travis Perkins site falls within the ‘Mill Road Opportunity Area’ (Policy 24) of the adopted Cambridge Local Plan (2018). 9.2 Policy 24 confirms that development proposals within the Mill Road Opportunity Area will be supported if they add to the vitality and viability of the street and protect and enhance its unique character, including the development of arts and cultural facilities. Travis Perkins, Devonshire Road is allocated as Site R9 (1.23 ha). 9.3 The supporting text to this policy states: “There are a number of sites with potential for redevelopment for residential uses, these include 315–349 Mill Road and Brookfields (R21), Mill Road Depot (R10) and the Travis Perkins site on Devonshire Road (R9).” 9.4 Within Appendix B of the Local Plan, the Travis Perkins site is proposed for an indicative number of 43 dwellings (35 dwellings per hectare). The site is in a central location with excellent transport links. It is capable of accommodating a much higher density development than currently indicated within the Local Plan. 9.5 The densification and redevelopment of brownfield sites such as the Travis Perkins site offer opportunities to maximise energy efficiency measures on site and achieving low carbon development, thereby helping to achieve the Council’s climate change targets. The opportunities for achieving low carbon development, net gain and energy efficiency development are more tangible if the indicative housing density for the site allocation is increased, and if the site allocation is expanded to include commercial uses. 9.6 First Base are supportive of the aims and objectives of Policy 24. 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. The Policy should however allow for more development on the site. ‘Station Areas West and Clifton Road Area of Major Change’ (Policy 21) Cambridge Local Plan (2018) 9.7 The site is located to the north of the Station Areas West and Clifton Road Area of Major Change. The Policy should recognise the importance of areas that contribute to the growth of Areas of such as the Travis Perkins site.

3.94 Grosvenor and USS’s key concern related to the previous assessment of the Cambridge Green Belt which formed part of the evidence base for the current Local Plan. As mentioned elsewhere in the representations, the nature of the site and its environs are changing. The alterations to the landscape will alter the contribution of the site to Green Belt purposes. This should be recognised in any Green Belt review the Council undertakes to support future stages of the Plan. Please see Terence O’Rourke’s Green Belt and Landscape Appraisal prepared in support of these representations, which makes references to the conclusions made in the LDA Inner Green Belt Assessments (2012 and 2015).

Cambridge City Local Plan Policy 31: • This is a good, strong policy that clearly outlines SuDS requirements for new developments. • Whilst the LLFA fully support part G, it is quite difficult for developers to demonstrate compliance with this. • Further detail may be required on part K, and what is considered to be 'reasonably practicable' Cambridge City Local Plan Policy 32: • Could this be stronger in line with the non-statutory technical standards and require previously developed sites to come down to greenfield surface water runoff rates and volumes unless it is not practicable? The non-statutory technical standards are going to be reviewed and updated in the near future • Part c) should perhaps say ‘up to and including a 1 in 100 year event’ Cambridge City Local Plan Policy 69 & 70: • We welcome this policy but it could be stronger by combining with SCDC policies NH/4, NH/5, NH/6 & NH7 – see our comments in relation to these policies below. South Cambridgeshire Policy CC/8: • It is good this policy refers to the non-statutory standards as this requires some reduction in surface water runoff for previously developed sites • It would be good to strengthen points on green roofs and permeable paving in line with Cambridge City Policy 31. • Section C could include further detail on what is considered to be 'practicable to do so'. South Cambridgeshire Policy NH/4: • This should be strengthened to include a requirement for all development to deliver Biodiversity Net Gain (BNG) and commit to 30 years management (in line with the emerging Environment Bill). • The policy should set a local target of 20% Biodiversity Net Gain (demonstrated using an appropriate BNG calculator) to deliver measurable Biodiversity Net Gain • The policy should include requirements for development not achieving measurable BNG as part of the development to deliver off-site BNG / contribute to habitat deliver projects • The policy should incorporate the SCDC Biodiversity SPD to give greater weight to biodiversity South Cambridgeshire Policy NH/5 & NH/7: • Supported South Cambridgeshire Policy NH/6: • Local requirements for green spaces should be identifies, such as against ANGST standards to ensure that sufficient green space is produce to avoid any impact on wildlife sites due to additional recreational pressure.

3.94 Grosvenor and USS’s key concern related to the previous assessment of the Cambridge Green Belt which formed part of the evidence base for the current Local Plan. As mentioned elsewhere in the representations, the nature of the site and its environs are changing. The alterations to the landscape will alter the contribution of the site to Green Belt purposes. This should be recognised in any Green Belt review the Council undertakes to support future stages of the Plan. Please see Terence O’Rourke’s Green Belt and Landscape Appraisal prepared in support of these representations, which makes references to the conclusions made in the LDA Inner Green Belt Assessments (2012 and 2015).

57. South Cambridgeshire Local Plan Policy SS/8 must be updated to reflect the committed develop coming forward. Cambourne West is still in the process of being delivered and as such should be carried forwarded into the Greater Cambridgeshire Local Plan with relevant amendments to reflect what has been consented. 58. The consented development includes more homes and land than that which was previously allocated, and the Policies Map should be updated to reflect the full extent of the Cambourne West development area. 59. In addition, the extant permission excludes the parcel of land to the south of Cambourne Business Park access road (U&I Land). 60. At present, Policy SS/8 approach to the U&I land is set out within criteria 7. This states that this land will be developed primarily for residential uses and will only come forward once replacement employment land. This policy is now outdated and should be amended. 61. Replacement employment land has been secured as part of the Cambourne West outline planning permission and the residential dwellings numbers set out within Policy SS/8 have been exceeded. The consented scheme also includes the provision of the pedestrian and cycle path to the south of the U&I land. 62. This leaves the U&I parcel of land free of any outstanding obligations and requirements. Therefore, an entirely flexible approach can be taken to future development on this site and criterion 7 should be amended as follows: “Land south of the Business Park access road will be developed for more than 250 dwellings as well as offices and small-scale shops and other town centre uses to serve the needs of the residents and the adjoining Business Park”.

‘Allocations for Class B1, B2 and B8 Employment Uses’ (Policy E/5) (1. Papworth Everard: Ermine Street South (residue) (2.5 ha)) South Cambridgeshire District Plan 2018 9.1 Papworth Business Park is currently allocated in the Local Plan for B1, B2 and B8 employment uses under Policy E/5. VJF support the principle of retaining this policy allocation, and also expanding the allocation to include a wider site area and incorporate land east of the Business Park. Site C is submitted as an extension to the employment allocation in the location plan which comprises 13.5 ha in order to support the success of the existing Park and cater for increasing tenant demand. The enclosed masterplan shows an indicative developable area of 4.28ha within Site C with the provision of open space and landscaping.

The adopted Local Plans acknowledged the commitment to an early review of their local plans beginning in 2019. This decision to take forward the early review of the Local Plans was made in order to establish what impact the anticipated changed infrastructure landscape and economic growth in the area might have on housing need and other aspects of spatial and transport planning. Further, during Examination of the individual plans, a number of issues were highlighted for specific attention. These related to the assessment of housing needs, progress in delivering the development strategy and in particular the proposed new settlements and provision to meet the requirements of caravan dwellers.

A. South Cambs Local Plan Policy S/5 set a target for 19,500 new homes between 2011-2031 (of which 2,735, or 14%, had already been completed between 2011-15 and more were committed within previous allocations). The delivery of the remaining housing supply relied on three major strategic site allocations which were anticipated to provide a further 13,700 (70%) of these homes, comprising: 1. A new town north of Waterbeach for 8,000 to 9,000 homes; 2. A new village based on Bourn Airfield for 3,500 homes; 3. A major expansion of Cambourne for a fourth linked village of 1,200 homes B. As stated within the response to question 46, a move away from relying a small number of large allocations is needed to a robust supply of sites is allocated which delivers growth in the right locations across the district throughout the entire Plan period. C. Furthermore, Policy S/6 sets out that the existing preference for locating new development is the edge of Cambridge in the first instance followed by within new settlements and lastly in the rural area at Rural and Minor Rural Centres. D. Gamlingay is identified as Minor Rural Centres in where residential development and redevelopment up 30 dwellings (indicative maxima) is supported within the designated development frameworks extent. However, the Plan also recognised that Minor Rural Centres have a greater level of services, facilities and employment than most other villages in South Cambridgeshire, and often perform a role in terms of providing services and facilities for a small rural hinterland. E. A more flexible policy approach to new development in or adjacent to these Rural Centres is required to deliver growth in this sustainable location and make best use of the services, facilities and employment opportunities available. Further details on this are set out within the response to Question 40.

The Cambridge Local Plan 2018, Policy 11 ‘Primary Shopping Area’. As mentioned before the Retail and Leisure Study should be reviewed and updated and Policy 11 reviewed accordingly to address the changing face of the high street. We would like to discuss the Councils aspirations for the future of the city centre in the new Plan and welcome a meeting in particular to Policy 11.

Policy S/10 Group Villages lists 32 villages in which “Residential development and redevelopment up to an indicative maximum scheme size of 8 dwellings will be permitted within the development frameworks of Group Villages”. This policy is far too restrictive, placing a huge limit on development, preventing these villages from contributing to housing supply, despite local services having capacity. This policy is something that should not be carried across or replicated in the Greater Cambridge Local Plan; both National Policy and the comments of the Planning Inspector for the South Cambridge Local Plan 2018 highlight development in villages as the most appropriate approach to development. It is our view that S/10 is too restrictive to enabling development in villages that are considered sustainable with suitable transport links and not within the Green Belt.

2.88 Nothing to add at this stage.

· 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.