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?

It is the opinion of European Property ventures (Cambridgshire) that a review of all spatial options is required to ensure that the quantum of development an 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 similar levels of growth and ensure that similar growth is continued through the next Plan period. This will involve making appropriate allocations to ensure that an adequate number of homes can be delivered to support the levels of economic growth, given that this will result in a substantial increase in demand for homes and increase in housing costs. To avoid an uncontrolled trajectory in growth that will exacerbate housing pressures, the Plan should ensure it adopts a robust approach to identifying sufficient sites to meet this demand. This should include consideration of the distribution of development alongside other spatial options identified in the Issues and Options draft of the new Plan, such as focusing growth around Cambridge and at strategi growth locatinos such as Waterbeach. If the new spatial strategy were to inappropriately focus growth upon a single spaital option, the policy's flexibility will be limited and any opportunity to respond to market factors, infrastructure delays or national economic influences would be removed. The ability of a strategic approach to respond to such infleunces is an important consdieration, especially in respect of providing a continual supply of development across the plan area and at levels appropriate to the commnities it is intended to serve. A spatial strategy is advanced that concentrates a level of housing around Cambridge and main settlements, whilst a quantum of growth is distrubuted amongst rural settlements and will provide that is required to ensure the maintenance of a robust housing supply. Without maintaining the supply, the 5-year housing land supply will be at risk, which could result in the Councils being vulnerable to speculative development. 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, it has been established through the representations made to the Issues and Options Consultation that there are suitable sites in the Green Belt that should be considered for allocation and development. The site at Dry Drayton Road, Oakington, provides an opportunity to secure development at a location that would not result in wider harm to its strategic function or the intrinsic value of the open countryside. Furthermore, villages such as Oakington should be recognised as sustainable locations, particularly where it can be demonstrated that existing public transport provision enhances linkages that do not necessarily require to the use of private cars to access job markets, such as the rapidly expanding market within Cambridge. Consideration of sites at the villages, such as the site at Dry Drayton Road, Oakington demonstrate a reasonable and sustainable approach to strategic development.. 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.

We think that the following issues have not been sufficiently addressed: • Distribution of national investment between North and South • Flood risk arising from sea level rise due to climate change • Damage to rivers and chalk streams by over-extraction of water • Transport system integration • Effective reduction of car use • Localisation of employment and provision of employment space which reduces commuting • Effect on skilled employment of closure of Marshalls airport. • Provision of facilities and finance for moving new technologies out of R&D and into local pilot and production phases • Impact of already approved developments. Cambridge needs a period of stability. • Protection of the Cambridge Greenbelt and prime agricultural land. • Protection and enhancement of existing biodiversity. • Managing the natural environment to meet climate change. • Protection of the natural landscape character such as chalklands and the fens • Waste management and recycling hierarchy. • Internet coverage especially in the more remote villages in the district. • How a new Plan will be managed and monitored, We are particularly concerned about water supply. The state of the chalk aquifer is absolutely critical to future development in Greater Cambridge. Around 97percent of our water is supplied from this groundwater source. Over abstraction has led to the River Cam and its tributaries coming under severe stress particularly during the summer months with a consequent increase in pollution levels and loss of biodiversity. This situation will only get worse with the increasing impact of climate change. The planning Authority must now put in place a Grampian condition which limits the scale of housing and industrial development to a level that the aquifer can sustainably manage. A study to this effect must the principle priority of the Sustainability Appraisal. The planning authority can no longer rely on the water company’s assurance of connection and must robustly question the Environment Agency projections. The planning authority must follow the precautionary principle.

We have provided advice in Annex B on some additional topics for consideration and further detail on some of those already included and discussed above.

- The next plan should be clear about how it will incorporate monitoring especially any new data from the 2021 census and whether some supplementary questions can or should be asked in the GC area. - The next plan should be clear also as to how provision of around 41,000 homes relates to the commitment to 100% growth in GVA over 25 years with, presumably, an implicit, related consquence about growth in numbers of jobs and GVA per capita and some assumptons about inward and outward commuting and housing costs. - The next plan should also recognise that the subsequent plan should be underpinned by more reliable data from the 2021 Census and monitoring of new settlements and planned transport improvements. - The next plan should also show some consideration of the consequnces of not achieving the high growth targets if growth turns out to be slower.

2.25 The adopted Local Plan for Cambridge City Council recognises the benefits of developments which are for the purpose of faculty, research, and administrative sites for the Universities and where educational facilities are seeking to improve the quality and range of teaching accommodation. 2.26 Over recent years, a common theme which the Cambridge Colleges, including Downing, have identified, is that the social spaces within the College environment are now being used in different ways. Typically, attendance at College bars is declining, and there is a greater demand for flexible spaces which can change from day to evening, enabling cafe settings as well as other spaces which can accommodate hobbies such as watching films, exercise, or contemplation. Managing students’ wellbeing whilst they are studying is an increasingly important issue for the College. Spaces where students can relax and spend time away from study is as important as spaces for study and teaching. 2.27 In addition to students’ social needs, it has become apparent to the College through surveys that students seek flexible and adaptable work spaces which can accommodate the latest technology. Not all learning happens in lecture theatres: people need and enjoy different working environments. 2.28 The College has found that its students seek out appropriate co-working or study environments off-site. It has become increasingly important for the College to create these spaces on-site so that students can seek advice from each other, share ideas, and be close to resources. If their fellow students are available on-site, international students integrate more quickly into College life. 2.29 The College suggests that the emerging Local Plan should recognise those schemes that provide flexibility and the adaptation of spaces to support teaching and learning within the College environment and not just as part of the University. These are two separate organisations, which whilst delivering educational teaching in harmony are nevertheless separate entities. The College considers that this differentiation is occasionally blurred or misunderstood and needs to be clearer in future planning policies.

Priorities for both the Commissioners and associated Boards are, as follows: • To fund, maintain, protect and improve existing and make further provision of viable and appropriate water level and flood risk management infrastructure and systems to reduce the likelihood of harm to people and damage to the economy, environment and society. • The implementation and management including enforcement of water efficiency measures for residential, business and other users of potable water. • The retention and improvement of the rivers and waterways, their settings and associated corridors for navigation, environmental, leisure and tourism through the provision of related facilities. • To maintain, protect and improve the existing and make further provision of net gains to achieve environmental benefits to the waterways in the district. In summary the current consultation document appears to consider key issues such as climate change, and Biodiversity and green spaces which are important, but as commented upon on several occasions in this response it is most disappointing to note the absence of "water related" issues including water level and flood risk management, water efficiency and resources etc. Failure to do so could have consequences for those that reside, work or visit Greater Cambridge and these issues must be considered if the proposed growth targets are to be achieved. In addition to the matters raised, we would advise on the following, which may be beneficial to The Greater Cambridge Partnership in respect of related development control issues. (C) Other Issues (i) Consultation during the planning process Whilst the Commissioners and associated Boards no longer provide bespoke responses to the LPA (unless instructed to do so by the relevant Board or the applicant, if the application is subject to a Pre/Post-AppIication Consultation procedure, see section (C) (ii) below), it takes the opportunity and time to contribute to strategic planning documents, such as HELAA, Water Cycle Strategy etc; however it is disappointing to advise that our comments are often ignored. Whilst it is appreciated that there are other planning matters to be considered, experience elsewhere within our respective catchments has identified that the failure to fully consider our comments has led to poor solutions which have to be resolved at the ratepayers' expense. It is appreciated that this document is primarily planning related. However, it must be understood that whilst a planning application may be acceptable to your Council it also needs to be appropriate to other parties if the development is to be viable and buildable with the minimum of delay yet maximising our respective limited resources. Decision makers need to be held more accountable for their involvement in the water level management and flood risk element of a development. The inappropriate raising of a developer's expectations and chasing LPA housing numbers is considered to be the start of a poor surface water disposal solution which, if not considered at this stage, could increase flood risk. The Commissioners and associated Boards are no longer prepared to resolve, at their expense, problems created by others. (ii) Early engagement and better design of infrastructure In accordance with best practice the Commissioners and associated Boards promote early consultation on Masterplans/Development Briefs/planning applications, etc that meet any of the following criteria: • Being either within or adjacent to a Commissioners'/Boards' watercourse, and/or any other flood defence structure or asset. • Being within the channel of any other Ordinary Watercourse. • Where a direct discharge of surface, ground or treated foul effluent water is proposed. For any development affecting more than one watercourse and having possible strategic implications. • In an area of known actual flood risk or "wet spot". • Being within the maintenance access strips provided under the Byelaws. • Any other application that, in the opinion of the Middle Level Commissioners' Chief Engineer, has material drainage implications. The Commissioners offer several pre-application consultation procedures, as detailed on our "Pre& Post-application consultation procedures" document. However, in view of the sensitive nature of the local water level and flood risk management systems within the area the use of the detailed discussion procedure is considered essential. This procedure is intended to guide all parties from the initial concept stage to the approval of navigation, flood risk and water level management and relevant environmental issues prior to applications being submitted. Therefore, increasing the likelihood of meeting the Boards' minimum requirements, alleviating the need to oppose applications and discharge conditions and, ultimately, speeding up the associated processes and reducing costs. In certain situations, as listed above, the Boards will require that a Flood Risk and Drainage Impact Assessment (Flood Risk/Drajnage Strategy/Assessment), has been supplied as part of an application. The Assessment must meet the Boards' minimum requirements together with those of the NPPF, the District Council's Strategic Flood Risk Assessment (SFRA), relevant aspects of the Pitt Report, which requires all sources of flooding to be considered, and advise whether there is any material prejudice to the Boards' systems; local water level management system; water, natural or built environment. The Assessment must be supported by suitable adequate technical data and designs. Failure to do so could lead to the Boards opposing the application concerned. It would also be appropriate for applicants of smaller developments to consider and provide details of a drainage strategy as part of the basic submission. Ideally, it should be submitted and checked by the Boards prior to any application being made. Any resultant adverse impacts must be considered at the earliest possible stage. (iii) Statutory Powers The Board's primary powers are under the Land Drainage Act 1991 and its byelaws, policy statements and other relevant documentation but sections of the Water Industry Act 1991, the Highways Act 1980 and the Flood and Water Management Act 2010 also apply. The Boards' Drains are protected under their byelaws made under the Land Drainage Act. Consent for works within, under or over the protected watercourses and/or encroachment within the associated 9.0m wide maintenance access strip requires the Boards' prior written consent. In this respect, the Boards promote detailed pre-application consultation as this enables any issues to be dealt with prior to and not during the decision-making process. It should not be assumed that consent will be given by the Boards. Contravention of the Land Drainage Act, or any other Act, is a criminal offence which could lead to enforcement action being taken against the perpetrator. (iv) Hazard mapping and development within the floodplain The floodplain, its definition, derivation and extents have been an issue for IDBs since its introduction. This has become of more concern since the elevated importance of the Sequential Test in the National Planning Policy Framework (NPPF). The definition and extents of a "floodplain" are matters for the planning authority to resolve with the relevant authority who prepared the hazard map, be it the EA for its various flood maps, the LPA, for its SFRA, and/or the LLFA for its Surface Water Management Plan (SWMP). It is acknowledged that whilst there may be specific issues relating to future proposed aspects of development within their catchment the Boards will not oppose it simply because it is within the floodplain. As you are aware, the main purpose of an IDB is to aim to manage flood risk up to an appropriate Standard of Protection (SOP). The Commissioners and associated Boards have policy statements available, which identify the SOP that they will seek to provide, floodplain or not. In addition, the Commissioners and associated Boards do not agree with the generic content of national policy, such as, the NPPF and argue that "The Fens" is a special case and should be considered as such. (v) River settings and corridors Whilst the Commissioners' system does not extend into the area covered by The Greater Cambridge Partnership they generally promote the use and enhancement of the local navigation system and are urging the relevant planning authorities to give serious consideration to enhance the setting, access, use and opportunities associated with the navigable rivers and associated river corridors that pass through their area and make a positive impact on the largely rural economy and promote the area as a tourist destination whenever possible, provided that they do not detrimentally affect statutory water level and flood risk management functions. (vi) Biodiversity and protected habitats and species/Green Infrastructure Whilst the Boards encourage the principle of increased ecological value and development of water level management and flood defences that provide for the creation of green infrastructure/habitat and recreation, the ability to maintain such systems for their intended use must also be considered. Experience has shown that biodiversity can be supported and improved within a regular framework of essential maintenance operations but care needs to be taken to ensure that a water level and flood risk management system does not suffer because of 'green' issues. An example of how these issues can affect what was originally intended as a flood defence, although on a much larger scale, is the Ouse Washes where concerns have been raised about the adverse impact on biodiversity due to flooding. The Boards have nature conservation duties under the Land Drainage Act 1991, the Wildlife and Countryside Act 1981 and are a competent authority under the Conservation (Natural Habitats etc) Regulations 1995, therefore, any works affecting their systems, requiring their consent, or on any works that affect any on-site open watercourses will require an Environmental Statement and a Risk Impact Assessment. The Boards have adopted Biodiversity Action Plans (BAPS) as one of their policies and are committed to their implementation. The BAPS will help the Boards to maximise the biodiversity benefits of their activities and demonstrate their contribution to the Government's UK BAP targets. The plans will be reviewed periodically and updated as appropriate. Higher temperatures will result in increased evaporation of open water bodies leading to poor quality and will have an adverse impact on biodiversity. (vii) River Naturalisation Many of the rivers and most of the other watercourses within the area are not natural but manmade, primarily within the last 600 years. Most are open and not piped or culverted, or otherwise 'modified' and, with the exception of those within the towns or villages, not urbanised, therefore, we are uncertain as to what further re-naturalisation can be undertaken. It is accepted that these requirements do have a place, possibly on the Agency's watercourses, such as, the Ouse Washes system, but it must not be at the expense of making rivers unmaintainable or at increased flood risk. Failure to do so could have significant consequences, as has been seen elsewhere in the country in recent years. (viii) Open watercourses In order to prevent an increase in flood risk, by reducing available hydraulic and water storage capacities, restricted access for maintenance etc and to protect the natural environment, the piping and filling of open watercourses, except as may be necessary to create a means of access across a channel, is generally prohibited. (ix) Flood Risk & Water Level Management Flood Defences Whilst the Boards concerned have particular duties, as discussed elsewhere in this response, and will endeavour to achieve these in accordance with its policy statement, its powers are permissive and, ultimately, under "common law', landowners have the primary responsibility for draining their land, to ensure that they do not create a flood risk to others; managing the flood risk issues; and taking appropriate action to protect their property. NB. It should be appreciated that it is unlikely that the current level of government funding for water level and flood risk management projects will be available in the future. Therefore, it is likely that funding will be required from other stakeholders, potentially including your Council, if current SOP are to be maintained in the long term. Infiltration Devices Experience with the use of infiltration devices in the area has shown that any infiltration rates can be low and, therefore, on the whole they do not work efficiently unless there is a significant amount of space to install them. Unfortunately, housing density and Government targets do not allow sufficient space. In addition, very few people know how to correctly undertake a permeability test, provide the associated calculations and design the devices correctly. Sustainable Drainage Systems (SuDS) The Boards generally agree and acknowledge that SuDS are the preferred option in certain situations. However, they are not always the answer to the problem and not always the most suitable. Careful consideration needs to be given to the facility to be used, what is trying to be achieved and the nature of water level management in the area. Devices such as permeable paving and crate-based systems require valuable resources to be extracted from the ground, heat and energy to make the product and then for it to be transported hundreds of miles to site. Is this sustainable? Whilst SuDS can generally be incorporated into larger sites, it is often difficult and not viable to use them on smaller sites. A holistic approach will require considerable master planning, together with the resolution of funding and maintenance issues. Prior funding from an external source, say via the Community Infrastructure Levy, may be required if this is to work correctly. Given that your Council is within an area which is water stressed, it would be appropriate, where possible, to "think outside the box" and allow for SuDS devices to form part of a hydrological train where the retained water could be used for water harvesting, irrigation purposes etc. Treated effluent disposal/Dry weatherflows No reference is made to the adverse impact on flood risk and water quality from increased discharges from Water Recycling Centres (WRCs) or other sources of dry weather flow that is associated with increased "growth"! Water efficiency Within local strategic planning documents water resource issues predominantly refer solely to potable water supply but other water resource issues which exist within the study area, for example, agricultural use, navigation, amenity, biodiversity should also be considered, particularly if drought conditions, like those previously experienced, become more regular, and if the impact of climate change becomes a reality. The failure to consider this could have economic and environmental effects on the area. However, given the current financial climate and the view held by most developers that they already invest too much into their developments and will want the councils to contribute more, it is considered that funding from an external source will be required. In terms of fixtures and fittings, issues such as total water neutrality are not going to be achieved until all I old l fixtures and fittings are totally replaced by 'sustainable' fittings. To be fully accepted this policy really needs endorsement from Senior Council Members but they may be reluctant to do this if it restricts development in the area. (x) Rainwater harvesting/Recycling facilities The Boards promote the use of rainwater collection and grey water recycling, particularly if drought conditions become more regular and the impact of climate change becomes a reality, but consider that such systems should be in addition to but not replace or form any part of a surface water disposal system. Whilst it is accepted that during normal rainfall events the water recycling facility is likely to prove adequate, during the winter months there may be insufficient volume to store a design event. There are also concerns about the effects on the local systems if the facility is inoperative or during periods when the property is empty. In addition, it is also understood that the majority of tanks require a means of disposal when the units are being cleaned.

2.38 A similar policy to E/7 will be needed to encourage IWM Duxford to flourish. The policy would be even more useful if it made mention of the site masterplan and allowed scope for this to be adopted as a SPD. 2.39 The Masterplan has provided an agreed set of development principles for the sustainable use of the site and its buildings by IWM which could help streamline the process of consent for the planning authority and IWM, releasing staff time and budgets for both. 2.40 Whilst the wording of paragraph 10.37 of the present plan, requiring consultation with the IWM over tall developments around the site, is welcome, this does not have the power of a specific policy which would give greater protection to the ability to fly historic planes from the airfield and safeguard its historic landscape setting.

Climate change, biodiversity and green space, wellbeing and social exclusion and great places are all important themes. However, CUHP would suggest that the Local Plan also include economic growth, housing, employment and infrastructure, as they are inextricably linked to the delivery of development in a sustainable, economically, socially and environmentally responsible way as per the objectives defined in the National Planning Policy Framework. We note in particular the findings of the 2018 Cambridgeshire & Peterborough Independent Economic Review (CPIER). This sets out a compelling case for the international importance of the Cambridge economy, a target to double the economic output of Cambridgeshire, and notes the real risk of decline if policies do not support the investment in infrastructure, housing (including affordable housing) and the economy, with a blended development strategy proposed. We note that all of the Local Authorities have signed up to recommendations of the CPIER report, which is welcomed.

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.

4.81 No comments.

4.80 No comments.

A significant omission from the South Cambridgeshire Local Plan 2018 was recognition of AgriTech as an important sector that should be planned for within the Greater Cambridge area (much like other significant sectors in the region). The Local Industrial Strategy and a number of additional important regional and national strategy documents should provide a starting position for the Local Plan to determine how it can contribute towards meeting the outlined key economic objectives and strategies. As outlined in response to a number of questions within this consultation, these strategies highlight the importance of investing in and planning for a number of sectors including AgriTech to meet economic, climatic and population challenges. Many of these strategies were not available during the drafting of the South Cambridgeshire Local Plan 2018, so must now be used to inform the new plan. The consultation document outlines that one of the key themes of the new Local Plan is Climate Change. Currently, the adopted Local Plan (2018) makes insufficient links between the impact of agriculture on climate change, issues around food security due to changes in climatic conditions and how the AgriTech sector can help address climate change, the climate emergency and assist in achieving net zero carbon aspirations. AgriTech can form part of the solution and if South Cambridgeshire District Council and Cambridge City Council are serious about tackling these issues of local, national and global significance they need to be more proactive about supporting, investing in and providing for the AgriTech sector. It is considered that the significance of this sector should be recognised within the new local plan and land should be allocated for the provision of a world leading AgriTech Park focussed on the development and commercialisation of this important sector.

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.

The focus of the majority of the questions is on new development, with an underlying assumption in favour of development. It may be that National Planning Policy Framework requires this. However the next Local Plan should also contain robust policies for the protection of open spaces in public and private ownership, Cambridge’s historic centre, landscape setting, and vistas and views, green corridors. Whilst biodiversity and sites of wild life importance should be protected, the Plan should also include policies which acknowledge the importance of green spaces or lungs, even if not accessible to the general public, e.g. college playing fields, and domestic gardens the visual enjoyment of which improves quality of life...

• It would be good to merge the existing Cambridge City policies (Policy 31 and 32) with other authority policies such as The Greater London Authority policies. The Greater London Authority gives a 7-stage drainage hierarchy, which could be incorporated into the Greater Cambridge Local Policy. • It would be good to incorporate particular parts of the Cambridge City Policy 31 and 32 into the Greater Cambridge Local Plan, including the strict requirements that all hard surfacing should be constructed as permeable paving and all flat roofs should be green/blue/brown. As it would be good to see such drainage polices applied across South Cambridgeshire, rather than just confined to the City. • Possibility for further specification on what is considered to be 'reasonably practicable' for the incorporation of SuDS such as permeable paving (i.e. guidelines for industrial sites and hardstanding area subject to heavy goods vehicles. • It would be useful to create a Green Infrastructure and Biodiversity strategy across the Local Plan area, based upon the up-to-date evidence base.

The issues and options report has not adequatley addressed the findings of the Health New Town Programme "Putting Health into Place" and consideration should be given to explore where the Ten Healthy New Town Principles can be incorporated into Local Plan policy. The evidence section 3.4.1 has not used local health and or social care data including the Joint Strategic Needs Assessments, in addition the local plan should take account of the draft Cambridgeshire and Peterborough Health and Wellbeing Strategy as per the National Planning Policy Framework and Guidance.

63. 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. 64. 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.

Grosvenor considers that at this first stage of the emerging Local Plan that the four big themes and their interaction are appropriate and valid matters for seeking responses and for moving forwards in preparation of the next stage of the process.

53. 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. 54. 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.

2.89 Nothing to add at this stage.

· 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 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. 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.

63. 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. 64. 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.