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?

• 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.

Even more focus on climate emergency and how to incorporate into every area of the plan.

See above answers.

• 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.

The issues have been largely correctly identified. The plan will need to be flexible given the work being undertaken by the Combined Authority.

Looking after children, supermarkets food and the long term strategy, ability to safely lock up bikes which might require one village providing facilities for another on their land – how does that happen not impossible but needs leadership from above. A more developed list of the factors which influence for example what forces us to make car journeys and what could reduce journeys by delivery drivers.

No comment.

The Greater Cambridgeshire Local Plan should consist of a range of methods to ensure that the Councils have consistent housing delivery throughout the Plan period. This includes allocating sites that are less than 1ha, which is required by national planning policy (paragraph 68 (a) of the National Planning Policy Framework (NPPF)). Three of the four sites that Telereal submitted as part of the Call for Sites process in March 2019 (Henry Giles House, Chesterton Road, Cherry Hinton Telephone Exchange, Coleridge Road and Trumpington Telephone Exchange, High Street) are less than 1ha in size and can contribute to this need. One of the ways Greater Cambridgeshire can meet its housing needs is through utilising brownfield sites. Paragraph 118 (c) of the NPPF states that planning policies should give "substantial weight" to allocating brownfield sites for housing. All the sites that Telereal submitted as part of the Call for Sites, including the 2ha BT Telephone Exchange, Long Road, are considered brownfield sites. In addition, all four submitted sites are considered sustainable as they are located in close proximity to services and facilities and good public transport links. Therefore, they should be allocated in the Greater Cambridgeshire Local Plan. All four will be available for development during the Plan period (now up to 2040) with Trumpington Telephone Exchange and Henry Giles House being made available earlier.

A review of all spatial options into include in the emerging Greater Cambridge Local Plan is required to ensure that needs of the new Plan period can be met. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply, which will result in the Councils from being vulnerable to speculative development which deviates from the preferred growth strategy of the emerging Plan. It is considered that a sustainable and appropriate strategy approach to achieve the requisite levels of residential development is identifying sufficient sites at village locations within South Cambridgeshire. This has formed an element of the adopted spatial strategy of the District and it would be a logical step to consider incorporating this into the new spatial strategy of the emerging Greater Cambridge Plan. Furthermore, given that there is land located outside the Green Belt at sustainable settlements such as Willingham, it would be inappropriate of the new Plan to exclude this approach. If new development is not considered at village locations, this would result in a spatial strategy that would be inappropriately attributing weight towards alternative development avenues, such as strategic sites and Green Belt release. Whilst it is considered that these strategies demonstrate a reasonable and deliverable approach to growth, it would not be appropriate if these strategies were not complemented by development directed towards the villages. This would provide a comprehensive spatial strategy which would achieve moderate levels of growth, but that which can contribute towards the strategic requirement of the new Plan period. Consideration of sites at the villages, such as the site at Fen End, Willingham demonstrate a reasonable and sustainable approach to strategic development. The site at Willingham is located within walking distance to a range of services that are established within the village, including a primary school as well as benefitting from access to public transport provision which provides linkages to nearby secondary schools at adjacent settlements and to Cambridge. Therefore, it is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages if it is to adopt a comprehensive and deliverable spatial strategy. If it does not do so, it will risk implementing a poorly deliverable strategy which will not be able to meet the identified needs of the Plan area over the new time period. Summary of Comments - The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including the identification of sites at villages.

Southern & Regional Developments (Joscelyn) require a review of the spatial options included in the emerging Greater Cambridge Local Plan to ensure that needs of the new Plan period can be satisfied. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply position, which will result in vulnerability of the Councils to speculative development which will deviate from the preferred growth strategy of the emerging Plan. It is considered that a sustainable and appropriate strategy approach to achieve the requisite levels of residential development is identifying sufficient sites at village locations within South Cambridgeshire. This has formed an element of the adopted spatial strategy of the District and it would be a logical step to consider incorporating this into the new spatial strategy of the emerging Greater Cambridge Plan. Furthermore, given that there is land located outside the Green Belt at sustainable settlements such as Swavesey, it would be inappropriate of the new Plan to exclude this approach. If new development is not considered at village locations, this would result in a spatial strategy that would be inappropriately attributing weight towards alternative development avenues, such as strategic sites and Green Belt release. Whilst it is considered that these strategies demonstrate a reasonable and deliverable approach to growth, it would not be appropriate if these strategies were not complemented by development directed towards the villages. This would provide a comprehensive spatial strategy which would achieve moderate levels of growth, but that which can contribute towards the strategic requirement of the new Plan period. Consideration of sites at the villages, such as the land off Kingfisher Way at Cottenham that is demonstrated as a reasonable and sustainable approach to strategic development. Consideration of sites at villages, such as the site at Kingfisher Way Cottenham demonstrate a reasonable and sustainable approach to strategic development. The site at Kingfisher Way, Cottenham benefits convenient walking distance from a wide range and establish level of services, which supports the sustainability of the village as a top tier settlement in the adopted hierarchy of South Cambridgeshire. Cottenham, as one of the most sustainable existing settlements in the District, should be robustly considered for additional growth given the level of services available within the settlement which provides a level of capacity which should be exploited through the new Plan period. Therefore, it is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages if it is to adopt a comprehensive and deliverable spatial strategy. If it does not do so, it will risk implementing a poorly deliverable strategy which will not be able to meet the identified needs of the Plan area over the new time period. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including the identification of sites at villages.

86. The next iteration of the Sustainability Appraisal (SA) for the Local Plan must ensure that it considers a wide range of development scenarios and that these are all taken through the subsequent stages of the Local Plan-making process. This will help ensure that the Local Plan process and its SA support the Submission Local Plan, which is highly likely to contain a hybrid of development scenarios. 87. Six different spatial growth options are considered within the SA and Issues and Option consultation but with only high-level options assessed at this stage, there is substantial uncertainty over the outcomes of these options. 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 as well as broader locations for growth, there is a risk of the plans’ selected approach not being properly justified, and the plan being found unsound at examination.

3.47 The next Local Plan should be a well-informed plan, both from national policy and address the comments from the Planning Inspector on the 2018 Local Plan to allocate more small to medium sized sites. The next Local Plan will be active for many years in a period of uncertainty, and undoubtedly considerable change. Therefore, the plan must have a varied approach to development; with a more holistic approach, ensuring a mixed approach to development, drawing on large, medium and small scale sites, in sustainable location that create a sense of place and community. 3.48 The GCP is in the process of preparing significant infrastructure projects, in order to improve connectivity and regenerate the way people perceive transport, resulting in public transport being the easiest and most logical way to travel. Development should take advantage of this much needed update of public transport and located development in these sustainable locations.

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 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.

63. As stated within the response provided at Question 40 and further to our above response to Question 49, the new Local Plan needs to be more flexible in its approach to the settlement hierarchy. A new village group should be provided and include the less sustainable Minor Rural Centres and more sustainable Group Villages and allow for development of up to 20 dwellings.

Southern & Regional Developments (Cottenham) require a review of the spatial options included in the emerging Greater Cambridge Local Plan to ensure that needs of the new Plan period can be satisfied. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply position, which will result in vulnerability of the Councils to speculative development which will deviate from the preferred growth strategy of the emerging Plan. It is considered that a sustainable and appropriate strategy approach to achieve the requisite levels of residential development is identifying sufficient sites at village locations within South Cambridgeshire. This has formed an element of the adopted spatial strategy of the District and it would be a logical step to consider incorporating this into the new spatial strategy of the emerging Greater Cambridge Plan. Furthermore, given that there is land located outside the Green Belt at sustainable settlements such as Cottenham, it would be inappropriate of the new Plan to exclude this approach. If new development is not considered at village locations, this would result in a spatial strategy that would be inappropriately attributing weight towards alternative development avenues, such as strategic sites and Green Belt release. Whilst it is considered that these strategies demonstrate a reasonable and deliverable approach to growth, it would not be appropriate if these strategies were not complemented by development directed towards the villages. This would provide a comprehensive spatial strategy which would achieve moderate levels of growth, but that which can contribute towards the strategic requirement of the new Plan period. Consideration of sites at the villages, such as the land to the north east of Cottenham that is demonstrated as a reasonable and sustainable approach to strategic development. Consideration of sites at villages, such as the site to the north east of Cottenham demonstrate a reasonable and sustainable approach to strategic development. The site to the north east of Cottenham benefits convenient walking distance from a wide range and establish level of services, which supports the sustainability of the village as a top tier settlement in the adopted hierarchy of South Cambridgeshire. Cottenham, as one of the most sustainable existing settlements in the District, should be robustly considered for additional growth given the level of services available within the settlement which provides a level of capacity which should be exploited through the new Plan period. Therefore, it is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages if it is to adopt a comprehensive and deliverable spatial strategy. If it does not do so, it will risk implementing a poorly deliverable strategy which will not be able to meet the identified needs of the Plan area over the new time period. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including the identification of sites at villages.

47. As stated within the response provided at Question 40 and further to our above response to Question 49, the new Local Plan needs to be more flexible in its approach to the settlement hierarchy. A new village group should be provided and include the less sustainable Minor Rural Centres and more sustainable Group Villages and allow for a higher level of development than is currently allowed in Group Villages.

Southern & Regional Developments (Willingham) require a review of all spatial options included in the emerging Greater Cambridge Local Plan to ensure that needs of the new Plan period can be met. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply, which will result in the Councils from being vulnerable to speculative development which deviates from the preferred growth strategy of the emerging Plan. It is considered that a sustainable and appropriate strategy approach to achieve the requisite levels of residential development is identifying sufficient sites at village locations within South Cambridgeshire, including further provision of development at Willingham. This has formed an element of the adopted spatial strategy of the District and it would be a logical step to consider incorporating this into the new spatial strategy of the emerging Greater Cambridge Plan. Given that there is land located outside of the Green Belt at sustainable settlements such as Willingham, it would be inappropriate of the new Plan to exclude this approach. If new development is not considered at village locations, this would result in a spatial strategy that would be inappropriately attributing weight towards alternative development avenues, such as strategic sites and Green Belt release. Whilst it is considered that these strategies demonstrate a reasonable and deliverable approach to growth, it would not be appropriate if these strategies were not complemented by development directed towards the villages. This would provide a comprehensive spatial strategy which would achieve moderate levels of growth, but that which can contribute towards the strategic requirement of the new Plan period. Consideration of sites at the villages, such as the site at Priest Lane, Willingham demonstrate a reasonable and sustainable approach to strategic development. The site at Willingham is located within walking distance to a range of services that are established within the village, including a primary school as well as benefitting from access to public transport provision which provides linkages to nearby secondary schools at adjacent settlements and to Cambridge. Therefore, it is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages if it is to adopt a comprehensive and deliverable spatial strategy. If it does not do so, it will risk implementing a poorly deliverable strategy which will not be able to meet the identified needs of the Plan area over the new time period. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including the identification of sites at villages.

A review of all spatial options into include in the emerging Greater Cambridge Local Plan is required to ensure that needs of the new Plan period can be met. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply, which will result in the Councils from being vulnerable to speculative development which deviates from the preferred growth strategy of the emerging Plan. The release of land from the Green Belt should also be a significant consideration of the emerging Greater Cambridge Plan. It is maintained that there are sites within the Green Belt that exist which do not contribute towards its wider strategic function. This includes the land at Bannold Road, Waterbeach which is a Green Belt site that is well enclosed by strong boundary features and therefore, its release from the Green Belt would not result in detrimental or significant impacts to it. The site is a sustainable location of growth which is able to capitalise on the strong accessibility credentials of the village as established by the train station, as well as the potential of new services being delivered nearby within the Waterbeach New Town strategic allocation. Opportunities such as the site at Bannold Road must be a consideration of the preparation of the new Plan, without any review of the Green Belt, such appropriate development opportunities will be missed and not contribute towards meeting the strategic need of the new Plan period. Given the significant development and housing pressures that are being experienced in the area, the emerging Plan cannot afford to inappropriately omit such deliverable and suitable strategies that can help achieve the objectives of the new Plan. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including review of the Cambridge Green Belt.

This form stands as a representation to the Issues and Options Consultation of the Greater Cambridge Local Plan, submitted on behalf of The Caravan and Motorhome Club (The Club). The Club has one site located in Greater Cambridge, that being the Cambridge Cherry Hinton Caravan Club Site. The site is currently well performing and open to visitors all year round. A brief description of the site is presented below. In respect of their site, The Club would like to diversify their offer to provide pods and lodges. The Cambridge Cherry Hinton site is set in an ancient quarry and a SSSI. The site is strategically located to provide access to local colleges, the River Cam as well as nearby shops and services. The site benefits from strong access links to Cambridge City Centre. The site comprises 67 total pitches, 48 on hardstanding, for both touring caravans and tents. The site includes internal roads, a reception block, a warden block, a toilet block and numerous service points. The site benefits from substantial planting around its perimeter and is well screened from the surrounding area. The site is located in Flood Zone 1, the Green Belt and Protected Open Space. The site is well screened and therefore, static pods and lodges will have a limited impact on the surrounding landscape and ecology. There are existing touring pitches and therefore, the diversification to lodges will not impact on the surrounding landscape. By being able to offer a variety of accommodation on their sites, the Club are best placed to ensure the long term viability of the sites. For the purposes of clarity, The Club may wish, in the future, to diversify the accommodation provided at their sites in your authority area by adding Lodges or Camping Pods. These are generally small scale, permanent or semi-permanent structures of varying sizes, typically of timber construction and containing a bedroom as well as cooking facilities and/or bathroom facilities depending on their size. The provision of this type of accommodation ensures that The Caravan Club can continue to meet the changing needs of their members and the visitor economy as a whole. Paragraph 145 of the NPPF (2019) sets out that an exception to inappropriate development in the Green Belt is the provision of appropriate facilities for outdoor recreation; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it. At the above site it is believed that the development of pods and lodges would not conflict with the five purposes of including land within the Green Belt, as set out within national policy. The site benefits from substantial screening meaning that the impact on the surrounding landscape of developing pods and lodges on part of the site would not be significant. Appropriately designed pods or lodges would be more sympathetic to the Green Belt than touring caravans that currently use the site. Given the Club’s ambition to ensure that they are able to operate in Greater Cambridge, by guaranteeing the economic viability of their sites, we wish to see the Council develop a policy to support the expansions and diversifications of holiday and caravan sites. Overall, and considering the above, polices must be sufficiently flexible to allow businesses to adapt to changing economic trends and changes in the demands of tourists. As such, policy must enable the Caravan and Motorhome Club to support the growth of the local economy by ensuring the ability of its existing sites to be developed and enhanced. Overall, this ensures the future viability of the business, and supports the tourist industry within Greater Cambridge.

Green Infrastructure Delivery Provision for local access to multi-functional green space is rightly considered as essential infrastructure. Adopted Local Plan policies rely chiefly on requirements for onsite green infrastructure provision. The National Trust fully supports such policies, however, development on the scale proposed in South Cambridgeshire should also take account of the interface between new communities and their wider surroundings, including the National Trust’s properties at Wimpole Hall Estate and Anglesey Abbey. As a responsible provider the Trust supports policies which encourage sustainable travel to leisure destinations and encourages sustainable recreation activity. However, managing increased visitor pressures brings significant challenges and we would welcome a dialogue with planning authority, developer and community representatives around policies aimed at identifying where contributions to off-site infrastructure provision may be appropriate. The Bigger Vision Within the Greater Cambridge area there is an opportunity to create a legacy for the people and nature of Cambridgeshire that ensures Cambridge and its surrounds remain a desirable place to live, work and visit forever. By thinking across boundaries, we can create a network of greenspaces that includes the Wicken Fen Vision, the Cambridge Green Belt and a green corridor that extends through the existing airport site connecting with Coldham’s Common. On its 125th anniversary in January 2020, the National Trust committed to support the creation of 20 such corridors to link up cities and the countryside. We see Greater Cambridge as an ideal location to deliver this ambitious vision and are keen to engage with interested partners, and to ensure the Local Plan can help make this happen.

• The 2018 Plans from both Councils included a strong and clear statement of their future Vision of the Greater Cambridge area. This is lacking in this consultation. The Plan must include a comprehensive overview of the sort of place we want Greater Cambridge to be in 20, 30 or even 50 years’ time. • An assessment must be made of the environmental capacity of Great Cambridge to absorb the scale of growth proposed in the consultation as a key document in the supporting evidence-base. Simply adding additional housing to an already stretched resource capacity is plain bad planning. • Greater Cambridge already faces a massive infrastructure deficit. If the level of the Objectively Assessed Housing Needs is determined by the Councils at a level greater than the minimum proposed by the government, then it must first show how the extra infrastructure is to be funded. Lacking any such financial analysis, including an assessment of the willingness of the private sector to take up the challenge, then the Plan will lack any sense of reality • The impact of London on Greater Cambridge’s development must be assessed. To what extent are housing pressures for the Greater Cambridge area being driven by increasing demand by London commuters, and the market’s ambition to make profit by meeting that demand? This trend will accelerate with the opening of Cambridge South station (see our response to Q4). To what extent can the Councils influence this issue?

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. In particular, we can think of two motivating types of examples: (1) where works to the highway cut through a cycleway or cycle route and degrade its quality or accessibility, it must be fixed; (2) landowners, leaseholders or statutory undertakers must not be allowed to install barriers or obstacles into cycle routes such as fences or poles; cycle routes should be protected either as public rights-of-way or under terms of access that forbid such alterations. • Developments should commit to implementing the Local Cycling and Walking Infrastructure Plan (LCWIP) as they come forward, building up the cycling network in the city and district. • Maintenance and protection of cycle routes is a theme that has not come forward yet. Transport Assessments and Travel Plans should include commitments to clean, clear, de-ice and maintain the usability and accessibility of cycle routes. • 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.

With the Director of the IMF saying that conditions are worse than in the lead up to the great depression, (and possibly the effects of Brexit on the Science community) we have not had a recession for 12 years, we need to be very wary of an economic forecast showing ever increasing growth, accepting that Cambridge continued to grow through the last recession. Granted we have a backlog to catch up, but the plan needs some mechanism to be able to adjust if the predicted growth disappears. Maybe this is an issue (thanks to the existing backlog) past the next 5 years with the existing plan, but some mechanism for adjustment should be included, so if reduced development is required it goes where required, not where developers choose to proceed.

• There is, as yet, no clear Vision of the sort of place Greater Cambridge should be in 30 or more years. We support the vision of retaining Cambridge as a compact city surrounded by Green Belt within which independent villages are located. Greater Cambridge should not be allowed to just grow and grow, even if better transport infrastructure is put in place. There must be a limit to growth if the area is to retain the character and benefits that are appreciated by existing residents, and make it attractive to others. This reality has not yet been addressed but is essential as it will inform all other decisions.

• 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.

A strategy for making communities accessible and inclusive otherwise it’s just words. Meaning consultation to understand what communities and businesses need to grow; this may be area specific. A good quality of life, wellness and resilience should be the outcome for communities and the measure of success. Youth Provision and Sport provision should have a strong weighting in the Local plan. Buildings for Youth Provision should be calculated separately from community space to ensure it is solely for youth rather than shared with other community uses which deter the youth from using the building. Sport space provision should be separate to Schools provision and Strong Local Governance at an early stage as elements. It is worth suggesting what the planning process should be for new developments or extension to existing towns or villages to involve the communities through the planning process.

Southern & Regional Developments (Swavesey) require a review of the spatial options included in the emerging Greater Cambridge Local Plan to ensure that needs of the new Plan period can be satisfied. Given that the growth of the local economy has significantly exceeded forecasts and expectations (Cambridgeshire and Peterborough Independent Economic Review), it is vital that the new Plan makes provisions to support this growth to continue through the next Plan period. This will need to include making appropriate directions to ensure that an adequate number of homes can be delivered to support this economic growth, given that this will result in a substantial increase in demand and increase in housing costs. To avoid an uncontrolled growth which will exacerbate housing pressures, the Plan should ensure it takes robust action in identifying sufficient sites to meet this demand. This should include consideration of all options as identified in the Issues and Options draft of the new Plan. If the new spatial strategy inappropriately focusses on limited options to achieve this growth, this will limit the flexibility that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, this will risk demonstrating a strong 5-year housing land supply position, which will result in vulnerability of the Councils to speculative development which will deviate from the preferred growth strategy of the emerging Plan. It is considered that a sustainable and appropriate strategy approach to achieve the requisite levels of residential development is identifying sufficient sites at village locations within South Cambridgeshire. This has formed an element of the adopted spatial strategy of the District and it would be a logical step to consider incorporating this into the new spatial strategy of the emerging Greater Cambridge Plan. Furthermore, given that there is land located outside the Green Belt at sustainable settlements such as Swavesey, it would be inappropriate of the new Plan to exclude this approach. If new development is not considered at village locations, this would result in a spatial strategy that would be inappropriately attributing weight towards alternative development avenues, such as strategic sites and Green Belt release. Whilst it is considered that these strategies demonstrate a reasonable and deliverable approach to growth, it would not be appropriate if these strategies were not complemented by development directed towards the villages. This would provide a comprehensive spatial strategy which would achieve moderate levels of growth, but that which can contribute towards the strategic requirement of the new Plan period. Consideration of sites at the villages, such as the Dairy Farm site at Boxworth End, Swavesey demonstrates a reasonable and sustainable approach to strategic development. The identified site at Swavesey is located within walking distance to a range of services that are established within the village, including a secondary school, primary school, shops, GP Surgery and benefitting from access to excellent public transport services that link to nearby employment destinations such as Cambridge and Huntingdon. It is maintained that the emerging Greater Cambridge Plan must consider the development potential of sites located at villages such as Swavesey for it to adopt an effecive, comprehensive and deliverable spatial strategy. If it does not do so, it will risk implementing a poorly deliverable strategy which will not be able to meet the identified needs of the Plan area over the new time period. Planning permission S/3391/16/OL was also considered for residential development of the site, through which the location was assessed as being suitable to accommodate residential development with a sensitive layout capable of being achieved without an adverse impact on the character of the surrounding landscape, with the site’s suitable for housing considered to outweigh the limited harm that would arise in relation to the Important Countryside Frontage designation along the roadside frontage. No technical concerns were identified through this proposal’s consideration, with the Highway Authority, Ecology Officer, Environment Agency, Lead Local Flood Authority, Urban Design. District Landscape Officer and Planning Department considering the site as suitable to accommodate new homes. In relation to secondary school provision, an extension to increase capacity at the Village College by 150 pupils has been completed, as a result of an identified shortfall in capacity in 2012. Following other residential consents at Swavesey any development at the village would enable the expansion of the Village College further, which would assist in ensuring capacity over the extended plan period. It is Southern and Regional Developments (Swavesey) position that the approach to be taken by Greater Cambridge Councils should identify a spatial strategy that is comprehensive across all of the sustainable settlement tiers; considering a number of avenues to achieve the requisite levels of housing development. Swavesey’s settlement status as a Minor Rural Centre should be recognised through the allocation of further housing growth proportionate to the facilities it provides. Summary of Comments: The new Plan needs to consider all spatial options to ensure adequate numbers can be realised, including sites at villages such as Swavesey.

The Plan should include a glossary. This should include appropriate Historic Environment terminology including Historic Environment, Heritage Assets, Listed building, Conservation Area, Scheduled Monument, Registered Park and Garden, Designated Heritage Assets, Non- designated Heritage Assets, Local List, Heritage at Risk etc. The Plan should include appropriate monitoring indicators.

4.117 In light of the responses provided within this report, we consider that the next Local Plan should give full and detailed consideration of the role the logistics sector and the allocation of the Brickyard Farm site will have in fostering economic growth for the plan period and beyond.

The 2018 Plans from both Councils included a strong and clear statement of their future Vision of the Greater Cambridge area. This is lacking in this consultation. As noted above, the “Visions of Cambridge in 2065” document, with its very contrasting (and often mutually incompatible) views could have provided a very stimulating basis for discussion and for drawing out key issues and choices. Environmental capacity is the key issue which has been overlooked. This is fundamental for a meaningful, realistic Plan, and for a credible consultation. The listed evidence base is totally inadequate. Published growth-promoting reports (e.g. CPIER, and by Cambridge Ahead) should be subject to critical analysis and overview. The evidence base needs to include thorough assessments of environmental capacity, including the impacts of existing growth proposals approved but not yet completed, the impacts of approved and proposed transport proposals, and the capacity of Greater Cambridge’s buildings to meet Climate Change targets. The evidence base also needs to include all existing assessments of environmental quality, including Conservation Area Appraisals and Suburbs and Approaches studies. The Councils need to identify further research as needed to provide a comprehensive holistic evidence base, and to set out, for public comment, a programme to deliver this research. The draft takes a far too complacent view of outcomes achieved. As noted above, Fig 17 is both superficial and grossly misleading. The effectiveness of 2006 and 2018 Local Plan policies relating to the Historic Environment and Design needs to be urgently reviewed, in relation to the quantum and the quality of development (see CB1, The Marque, “Hideous Cambridge” etc etc), and the historic environment. The City Council has failed to set the example required in its own development at the former Depot Site, coupled with failure to resolve the adjacent Listed building at risk (former Mill Road Library).