Question 50: What do you think should be in the next Local Plan? Are there issues, ideas or themes that you don't feel we have yet explored?

See answer to Qu 49 above

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible and focus on key priorities. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for carbon reduction is appreciated but if additional demands are placed on the development industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into rents and values – thus potentially exacerbating some of the issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those skilled employees (professional/educated/trained) would not qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes i.e. discounted purchase.

More thought needs to be given on the needs of villages that need fostering through further growth.

I see no encouraging evidence that the climate emergency is understood and will govern future action.

See answer to last question - food growing is key!

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

I simply want to make a general point about the Local Plan as it affects Hardwick. Hardwick is a sizeable village - just over 1000 homes - but has very few facilities of any kind and very few commercial buildings or opportunities for employment. I shall not list all the ways in which the village lacks facilities as I believe this is a matter of record at SCDC. There are two housing developments in progress for 98 dwellings and 155 dwellings. S106 funds from these developments will provide for a new much needed community centre. But more needs to be done and that requires land to be made available for recreation, retail, health services, eating, offices etc. There is nowhere at present for these to go and the two developments provide only for more houses. Even the new Community Centre has to be built on the recreation field causing the loss of part of this already cramped facility. The obvious solution would be to allow some mixed development east of Cambridge Road. This is currently Green Belt but of an agricultural use. Longer term mixed development in this area to include a little housing could make very positive changes for the community, creating for the first time since the 1970s a village centre with communal buildings. At the same time further development could be restricted and the remaining green belt protected by the planting of trees in a new wood between this new area and Long Road with environmental benefits.

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

How are we going to have enough water to supply all the planned housing developments when droughts are more likely due to climate change the we are already at the limit of extraction from the Cambridge aquifer.

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible and focus on key priorities. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for carbon reduction is appreciated but if additional demands are placed on the development industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into rents and values – thus potentially exacerbating some of the issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those skilled employees (professional/educated/trained) would not qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes i.e. discounted purchase.

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible and focus on key priorities. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for carbon reduction is appreciated but if additional demands are placed on the development industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into rents and values – thus potentially exacerbating some of the issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult as a result of very high house prices. However, those skilled employees (professional/educated/trained) would not qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes i.e. discounted purchase.

In reviewing the documentation prepared by the Council we recognise that this is an early stage in the plan’s preparation and that a Sustainability Appraisal is an iterative process. At the outset we would note that recent challenges at examination of local plans have included substantive criticisms of the SA which goes well beyond the legal tests and into professional planning judgement. For example, examiners in the North Uttlesford Local Plan, North Essex Local Plan and St Albans Local Plan have recently requested information on alternatives that goes beyond the legal position of “reasonable alternatives” selected by the local authority using broad questions of judgement. The Issues and Options Report is assessed in a SA report dated November 2019. The Issues and Options Report is largely of general content without spatial or specific focus, and consequently much of the assessment is general commentary. Six spatially discernible options are provided in the "Towards a Spatial Plan" Section, which are: • Option 1: Densification. • Option 2: Edge of Cambridge – Outside the Green Belt. • Option 3: Edge of Cambridge – Green Belt. • Option 4: Dispersal – new settlements. • Option 5: Dispersal – villages. • Option 6: Public transport corridors. With only high-level options assessed at this stage, there is substantial uncertainty over the outcomes of these options. As such, the conclusions of the SA also are substantially uncertain, and more assessment is required with specific details provided on the deliverable projects which will make up these options. There is a possibility that a preferred option will be advanced with an equally valid alternative discarded at this early stage due to lack of information. Additional assessment should take place at another local plan stage, with full assessments within the SA Framework, before any options are fully dismissed. Without a full consideration of all these options which considers substantive detail of deliverable sites, there is a risk of the plan's selected alternative not being properly justified, and the plan being found unsound at examination. The options assessed in the issues and options report will likely only be achievable in combination with other options (e.g. some density within existing development, with some expansion to villages, etc). For transparency, the extent to which these options are likely to be combined in ultimate implementation should be made explicit in any future local plan documents which discuss these strategic options. None of the options put forward in the Issues and Options Report are reasonable alternatives capable of meeting the objectives of the plan, as none of them is shown to be capable of meeting housing need and economic potential on their own. As none of the options are reasonable in current form, they will need to be re-assessed at a subsequent stage when sufficient detail is available to robustly evidence the selection of a preferred option. The significant negative or positive effects given within the SA report are at this stage based on the limited information available misleading due to assumptions used and uncertainty attendant with such high level options. The SA Report notes a large number of points of uncertainty, but still identifies a number of significant effects (both positive and negative). However, there are assumptions for the significant effects identified which aren't clearly explained and which can be questioned. For example, Option 5 (Dispersal – villages) is attributed a significant negative effect to SA Objective 6 (distinctiveness of landscapes) as it is assumed that expansion of these villages could have an adverse effect on the open countryside and landscape surrounding these villages, as well as village character. As recognised in paragraph 3.61 the actual effect will depend on the final design, scale and layout of the proposed development. We recognise that SA is an iterative process which will evolve as a Local Plan progresses. More information should be provided on the approach to considering alternatives. The most substantive point we raise that this point is that the options set out in the Issues and Options Report should all be taken forward to subsequent local plan stages, where deliverable options should be assessed in detail, and transparent and objective assessment of these options provided at a subsequent SA stage. This will help ensure the Local Plan process and SA would support a hybrid of development scenarios which would underpin all development proposals at this stage.

In regard to Q 42, we have reviewed the 6 spatial strategy development options set out in the “Issues and Options” to locate new homes and jobs. We have also reviewed the accompanying Sustainability Appraisal (November 2019), which utilises 15 Sustainability Appraisal objectives by which it then “scores” the 6 spatial strategy options. The College, having prepared and continued to work up its “Call for Sites” proposal for expanding Duxford village, has reviewed the Duxford proposal against the 6 spatial options and the Sustainability Appraisal objectives. We do not consider that the Duxford “Call for Sites” proposal falls within Option 5 (i.e. dispersal – villages) as this would grossly underestimate the strategic mixed use and sustainable nature of the development opportunity at an expanded Duxford Village. As set out in the “Call for Sites” submission and in this response, the Duxford opportunity would deliver around 110,000 sqm of employment space, 800 new homes and a 40 ha country park. It cannot therefore be categorised as a dispersal and minor addition to an existing village. The College considers it is a major opportunity to help meet the development requirements of the new Local Plan and consideration should therefore be given to the opportunity as part of the emerging Plan process, to ensure that major development opportunities and different spatial distribution options such as an expanded Duxford village are not overlooked. Having reviewed all 6 potential spatial distribution options and the Sustainability Appraisal, the College considers the Duxford proposal has the benefit of being in a public transport corridor (Option 6) but also has the characteristics of Option 2 (i.e. development on the edge of Cambridge city centre – outside Green Belt). The College recognises Duxford village is beyond the Green Belt and not next to the city centre, and the quantum is not comparable in housing terms with say the potential at Cambridge airport. However, the Duxford proposal is truly strategic in size and unique in nature and has the added benefits of expanding and making sustainable the existing village, is located outside of the Green Belt, benefits from public transport connectivity and is on College land in single ownership immediately available for development, subject to planning.

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (e.g. discounted purchase).

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible and focus on key priorities. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for carbon reduction is appreciated but if additional demands are placed on the development industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into rents and values – thus potentially exacerbating some of the issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those skilled employees (professional/educated/trained) would not qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes i.e. discounted purchase.

The aims set out are ambitious and wide-ranging. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents.

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible and focus on key priorities. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for carbon reduction is appreciated but if additional demands are placed on the development industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into rents and values – thus potentially exacerbating some of the issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult as a result of very high house prices. However, those skilled employees (professional/educated/trained) would not qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes i.e. discounted purchase.

The aims set out are ambitious and wide-ranging. It is important that the plan is not overly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible and focus on key priorities. Local Plan policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Where appropriate the plan should look to grow existing allocations, such as Northstowe, to allow the viability and vitality of these settlements to be improved and allow new allocations to benefit from the economies of scale associated with the provision of infrastructure. Viability testing is important. The need for carbon reduction is appreciated but if additional demands are placed on the development industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into rents and values – thus potentially exacerbating some of the issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those skilled employees (professional/educated/trained) would not qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes i.e. discounted purchase.

9.1 In reviewing the documentation prepared by the Council we recognise that this is an early stage in the plan’s preparation and that an SA is an iterative process. At the outset we would note that recent challenges at examination of local plans have included substantive criticisms of the SA which goes well beyond the legal tests and into professional planning judgement. For example, examiners in the North Uttlesford Local Plan, North Essex Local Plan and St Albans Local Plan have recently requested information on alternatives that goes beyond the legal position of “reasonable alternatives” selected by the local authority using broad questions of judgement. 9.2 The Issues and Options Report is assessed in a SA report dated November 2019. The Issues and Options Report is largely of general content without spatial or specific focus, and consequently much of the assessment is general commentary. 9.3 Six spatially discernible options are provided in the "Towards a Spatial Plan" Section, which are: ● Option 1: Densification. ● Option 2: Edge of Cambridge – Outside the Green Belt. ● Option 3: Edge of Cambridge – Green Belt. ● Option 4: Dispersal – new settlements. ● Option 5: Dispersal – villages. ● Option 6: Public transport corridors. 9.4 With only high-level options assessed at this stage, there is substantial uncertainty over the outcomes of these options. As such, the conclusions of the SA also are substantially uncertain, and more assessment is required with specific details provided on the deliverable projects which will make up these options. 9.5 There is a possibility that a preferred option will be advanced with an equally valid alternative discarded at this early stage due to lack of information. Additional assessment should take place at another local plan stage, with full assessments within the SA Framework, before any options are fully dismissed. Without a full consideration of all these options which considers substantive detail of deliverable sites, there is a risk of the plan's selected alternative not being properly justified, and the plan being found unsound at examination. 9.6 The options assessed in the issues and options report will likely only be achievable in combination with other options (e.g. some density within existing development, with some expansion to villages, etc). For transparency, the extent to which these options are likely to be combined in ultimate implementation should be made explicit in any future local plan documents which discuss these strategic options. 9.7 None of the options put forward in the Issues and Options Report are reasonable alternatives capable of meeting the objectives of the plan, as none of them is shown to be capable of meeting housing need and economic potential on their own. As none of the options are reasonable in current form, they will need to be re-assessed at a subsequent stage when sufficient detail is available to robustly evidence the selection of a preferred option. 9.8 The significant negative or positive effects given within the SA report are at this stage based on the limited information available misleading due to assumptions used and uncertainty attendant with such high level options. The SA Report notes a large number of points of uncertainty, but still identifies a number of significant effects (both positive and negative). However, there are assumptions for the significant effects identified which aren't clearly explained and which can be questioned. For example, Option 5 (Dispersal – villages) is attributed a significant negative effect to SA Objective 6 (distinctiveness of landscapes) as it is assumed that expansion of these villages could have an adverse effect on the open countryside and landscape surrounding these villages, as well as village character. As recognised in paragraph 3.61 the actual effect will depend on the final design, scale and layout of the proposed development. 9.9 We recognise that SA is an iterative process which will evolve as a Local Plan progresses. More information should be provided on the approach to considering alternatives. The most substantive point we raise that this point is that the options set out in the Issues and Options Report should all be taken forward to subsequent local plan stages, where deliverable options should be assessed in detail, and transparent and objective assessment of these options provided at a subsequent SA stage. This will help ensure the Local Plan process and SA would support a hybrid of development scenarios which would underpin all development proposals at this stage.

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation - e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

The aims set out are ambitious and wide-ranging. It is important that the plan is not unduly long and complex. Too often, planning policies are over-prescriptive and subsequently lead to protracted debates when a planning application is submitted. The plan should be kept as simple as possible. Policies should not duplicate or repeat the scope of matters better controlled by other legislation - e.g. Building Regulations. Viability testing is important. The need for social housing is appreciated but if additional demands are placed on the house building industry in respect of climate change, public transport needs or renewable energy generation for example, then there will be additional costs which feed into house prices and rents – thus potentially exacerbating some of the very real issues identified for the Plan to address. For local employers, attracting qualified young professionals is becoming more difficult due to house prices. Those employees would never qualify for social housing and, in any event, aspire to homeownership. There is therefore a case for an element of affordable housing provision to be in the form of low-cost starter homes (i.e. discounted purchase).

• Developments should commit to implementing the Local Cycling and Walking Infrastructure Plan (LCWIP). • Maintenance and protection of cycle routes must also be included. Transport Assessments and Travel Plans should include commitments to clean, clear, de-ice and maintain cycle routes. • Policies in the Local Plan must protect existing cycle routes from being harmed by development, both during construction and after completion of the development. The convenience, safety and quality of cycle routes must be maintained or improved by development in their vicinity. • The cycling network is just as strategic as the public highway network and must be protected in the same way. In some cases, the cycling network is part of the public highway network, but where it is not, some other method of protection must be sought. This is necessary in order to achieve carbon reduction, air quality, placemaking and congestion reduction goals.

• Developments should commit to implementing the Local Cycling and Walking Infrastructure Plan (LCWIP). • Maintenance and protection of cycle routes must also be included. Transport Assessments and Travel Plans should include commitments to clean, clear, de-ice and maintain cycle routes. • Policies in the Local Plan must protect existing cycle routes from being harmed by development, both during construction and after completion of the development. The convenience, safety and quality of cycle routes must be maintained or improved by development in their vicinity. • The cycling network is just as strategic as the public highway network and must be protected in the same way. In some cases, the cycling network is part of the public highway network, but where it is not, some other method of protection must be sought. This is necessary in order to achieve carbon reduction, air quality, placemaking and congestion reduction goals.

I would like to see the development of new woodland areas, and as part of that, natural environments for people to enjoy - cycle trails, trim trails, den building, running trails. I thinks its important that we not only have a policy of tree planting, but also nurture the value of woodlands and forests in young people, so that they grow up with a respect and appreciation for green space and the outdoors. It would also be of great benefit to the health and well being of residents to have more of these spaces to enjoy

Specify the LCWIP - Local \cycling and Walking Plan. A commitment to improved maintenance of roads, cycleways etc. Policing of parking to avoid blocking of pavements (and roads).

• Developments should commit to implementing the Local Cycling and Walking Infrastructure Plan (LCWIP). • Maintenance and protection of cycle routes must also be included. Transport Assessments and Travel Plans should include commitments to clean, clear, de-ice and maintain cycle routes. • Policies in the Local Plan must protect existing cycle routes from being harmed by development, both during construction and after completion of the development. The convenience, safety and quality of cycle routes must be maintained or improved by development in their vicinity. • The cycling network is just as strategic as the public highway network and must be protected in the same way. In some cases, the cycling network is part of the public highway network, but where it is not, some other method of protection must be sought. This is necessary in order to achieve carbon reduction, air quality, placemaking and congestion reduction goals.