Question 51: Generic Question

Thank you for consulting Natural England on the above in your email of 20 December 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. We support Cambridge City and South Cambridgeshire District Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Cambridge area, with policies aligned with the revised National Planning Policy Framework (NPPF). We welcome the evidence being gathered to inform preparation of the Plan including further research on responding to climate change and the transition to net zero carbon, green infrastructure and biodiversity net gain, landscape and Habitats Regulations Assessment (HRA). The Councils continue to engage with Natural England in the preparation of the relevant aspects of the evidence base and we will be pleased to review and provide comments on the draft documents in due course.

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4.3 The four big themes are all considered to be important aspects to achieving positive development. All four themes should be used to inform the spatial strategy within the Local Plan in terms of distributing growth and determining planning applications to deliver growth. It is therefore not considered necessary to rank the options in order of preference. 4.4 The proposed redevelopment of Kett House and 10 Station Road could address the big themes in the following ways: ● Climate Change – Brookgate and Aviva recognise the climate emergency and wish to deliver a development that embraces the new agenda to work towards net zero carbon. The proposed commercial-led development will be designed to a high quality and incorporate low carbon technologies and energy efficiency measures. The site is also in a sustainable location with access to excellent public transport connections including the new Chisholm trail link, thereby reducing residents’ reliance on private cars for travel. ● Biodiversity and Green Space – through the provision of on-site green infrastructure to create recreational and ecological assets to be enjoyed by future and existing residents. ● Wellbeing and Social Inclusion – the proposals would incorporate public-facing commercial uses to offer a choice of services for workers and residents in the area. The proposals would also promote healthy lifestyles and wellbeing through the provision of on-site recreation and the site’s accessibility to employment, education, shops and public transport by active modes of travel. ● Great Places – there is an opportunity to maximise the site’s potential to deliver densification in a well-connected area, providing open space on site and opportunities for increased recreation.

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Q2. Whilst Natural England is unable to put forward any sites for consideration we would welcome the opportunity to provide early advice on any proposals for greenspace and wildlife habitat creation e.g. with regard to potential opportunities for enhancement. We have provided some advice on the assessment of sites submitted for consideration as development or greenspace allocations at the end of Annex B.

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Annex A: Natural England additional guidance and advice on embedding biodiversity net gain into the Greater Cambridge Local Plan policies Background Biodiversity Net Gain (BNG) is an approach to development, and/or land management, which aims to leave the natural environment in a measurable better state than beforehand. Defra recently consulted on proposals to make biodiversity net gain mandatory for Town & County Planning Act (TCPA) developments. The consultation closed in February 2019 and in the Spring Statement it was confirmed that mandatory net gain would be taken forward. BNG is usually measured through use of a metric, most commonly one based upon Defra’s ‘biodiversity metric’. This calculates before and after habitat values in terms of ‘biodiversity units’. The recent net gain consultation, also sought views on updates to the metric, which was originally piloted by Defra in 2012. BNG does not replace existing environmental legislation or policy requirements. Importantly this includes the application of the mitigation hierarchy and BNG does not apply to development subject to the Habitats Regulations. Furthermore BNG is not intended to be used to assess impacts and calculate compensation for habitat damage or loss affecting irreplaceable habitats or other designated sites, including SSSIs. BNG outcomes can be achieved onsite, offsite or a combination of the two. The priority should be on securing onsite gains where possible. When delivering offsite, links should be made to relevant plans or strategies to ensure gains are targeted on areas of opportunity, for example the Cambridgeshire Green Infrastructure Strategy, the Cambridgeshire and Peterborough Biodiversity Group Habitat Opportunity Mapping areas, etc. It should be noted that BNG is not predicated on there being a biodiversity loss on a site. National Planning Policy Framework (NPPF) The revised NPPF (2019) set outs the planning policy context for delivering BNG through the planning system, clearly stating that planning policies and decisions should provide net gains for biodiversity. The net gain policy should be considered in conjunction with other NPPF policies on the natural environment, including the mitigation hierarchy: ‘providing net gains in biodiversity where possible’, has been strengthened to ‘minimising impacts on and providing net gains for biodiversity’ (para 170, NPPF 2019) and now refers to ‘measurable net gains’ (174). In addition, LPAs have a duty to have regard for biodiversity in the exercise of their functions* (under Section 40 NERC Act, 2006). An evidence based approach to biodiversity net gain can help LPAs demonstrate compliance with this duty. Links to green infrastructure Green infrastructure within and around new development e.g. SUDs, green spaces etc. can be designed and maintained to deliver new or enhanced habitat features for biodiversity (contributing towards the need for measurable BNG requirements) as well as providing a range of other health and wellbeing benefits for communities, contributing towards wider place-making. BNG through Local Plans Strategic policies should include requirements to conserve and enhance the natural environment (NPPF, para 20). LPAs can set a clear framework at this level for biodiversity net gain, which can flow down and be supplemented by lower tier plans, including neighbourhood plans. Non-strategic policies should be used to set out more detailed policies for specific areas, neighbourhoods or types of development. This can include allocating sites for development and the provision of infrastructure and community facilities at a local level. Non-strategic policies may provide further detail on biodiversity net gain, for example the delivery criteria for a development allocation or local priorities for habitat enhancement. Helpful guidance is available through the CIRIA/IEMA/CIEEM publication** including https://www.ciria.org/Resources/Biodiversity_Net_Gain.aspx One of the first steps is to identify locations where development should be avoided (in line with the mitigation hierarchy) and locations where any off-site BNG delivery should be targeted e.g. to enhance ecological networks or to restore degraded habitats. The work being undertaken by Greater Cambridge to develop a biodiversity and green infrastructure evidence plan should help to identify these areas. Natural England has already advised on the availability of existing information through the following sources:  Natural England’s Impact Risk Zones (IRZs) available through Magic;  The Cambridgeshire Biodiversity Partnership’s Mapping Natural Capital and Opportunities for Habitat Creation in Cambridgeshire (May 2019);  Combined Authority Doubling Nature Investment Plan;  Cambridgeshire and Peterborough Non-Statutory Strategic Spatial Framework;  the objectives and projects in the Cambridgeshire Green Infrastructure Strategy (2011);  Natural England’s Cambridgeshire Analysis of Accessible Natural Greenspace 2010;  Cambridgeshire Rights of Way Improvement Plan. The Cambridgeshire and Peterborough Environmental Records Centre (CPERC) and existing environmental assessments for recent developments may provide useful additional data. The existing evidence can be used to help develop policy objectives, for example by securing habitat creation to connect areas of fragmented habitat through development. It can be useful to gather evidence and emerging approaches in a background paper to inform policy development. The Portsmouth Background Paper*** provides a useful example of bringing together the existing baseline and key priorities for the new Local Plan, highlighting gaps in evidence relevant to priorities for the plan. BNG is integral to the entire paper and key actions around environmental mapping and policy development is highlighted. Another good example is Lichfield Local Plan 2015 which includes a good BNG policy which requires development resulting in a loss to provide compensation that is at least 20% greater. Engaging local stakeholders is also crucial in early plan making and we welcome the approach being taken to this by the Greater Cambridge Shared Partnership. Natural England may be able to assist with designated site knowledge, however it also important for the LPA to engage with the local community, Wildlife Trust, RSPB, local birdwatching groups etc. to understand what is important locally to the people who work, live and visit the area. A partnership approach is considered the most effective way of delivering BNG. This includes an understanding of the view of local communities, residents, visitors and landowners, to help understand local aspirations and priorities. Organisations working together via the Local Enterprise Partnership, the Combined Authority, the Local Nature Partnership or other biodiversity partnership can help to deliver BNG across larger spatial scales. We are aware that Greater Cambridgeshire Partnership is taking forward a partnership approach to the delivery of BNG in planning, which includes a leading role for the Local Nature Partnership. Mapping biodiversity and green infrastructure opportunity areas and analysing connectivity, ahead of selecting sites for development, will help identify where the biggest opportunities exist to maximise biodiversity gains when considering where to allocate areas of growth through the Local Plan. Warwickshire County Council’s approach to the Local Plan is underpinned by a robust evidence base using various data sets, including maps on grassland and woodland habitats. From here, they began to target where enhancement could be made and/or the connections between well-established existing habitats. The County Council formed a close working relationship with the Local Environmental Records Centre and neighbouring authorities to outline a programme of work to review and update data. More detail can be found here. At this early stage the Councils should consider: - What biodiversity is at risk locally and whether the approach to BNG should be targeted on-site or off-site, and how this might work in practice to secure delivery; - Consider and map the area’s most important assets and their connectivity; - Identify other relevant plans and strategies and cross reference these, for example the Cambridgeshire Green Infrastructure Strategy (Cambridgeshire Horizons, 2011) and Cambridgeshire Habitat Opportunity Mapping to identify opportunity areas, reducing the need for additional evidence mapping; - Establish the best and least favourable areas for BNG underpinned by evidence; - Undertake further evidence gathering where gaps occur or to provide further detail to inform options; - Set out minimum requirements for BNG, bearing in mind the ‘doubling nature’ vision for Cambridgeshire is equivalent to 100% net gain; - Consider the impact of the BNG approach on viability and the deliverability of emerging policies and allocations. Natural England advocates the inclusion of a standalone BNG policy within Local Plans, and the inclusion of specific BNG requirements within site allocation policies. Ideally this should include a BNG % target, although local plan policy may simply outline the positive intention for BNG, noting that a mandatory requirement is likely to be at least 10%. The policy should also include a commitment to using a single, preferably the Defra 2.0 metric, to ensure consistency. Policy requirements should be clear so that they can be accounted for down the line, ensuring costings are factored in and that BNG is deliverable indicating whether this will be secured through planning condition or S106 agreement. Further details can be set out in lower tier plans such as a Supplementary Planning Document (SPD). Local Plans should include a commitment to monitor the BNG policy and approach including the quantified gains achieved by the policy and the recording of any losses. A habitat banking approach could be taken for smaller developments. The SA should include an objective around biodiversity and net gain that could be tested against all policies in the emerging draft plan For larger sites allocations additional evidence including mapping of key areas and opportunities for BNG can be sought from the developer. Longer term the Nature Recovery Network (NRN) will be a useful tool in the delivery of BNG. Net gain can contribute both towards the creation of new habitats and the enhancement of existing sites and habitats to develop a NRN, which is a key action in the Defra 25 Year Environment Plan. *See http://www.legislation.gov.uk/ukpga/2006/16/section/40 ** CIRIA/IEMA/CIEEM Biodiversity Net Gain – Good practice principles for development (2016) CIRIA/IEMA/CIEEM Biodiversity Net Gain: Good practice principles for development – a practical guide’ 2019) CIRIA/IEMA/CIEEM Biodiversity Net Gain: Good practice principles for development Gain – Case studies (2019) ***Biodiversity and Portsmouth Background Paper. Portsmouth City Council, February 2019.

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B: Natural England Further Advice on Local Plan Policies Biodiversity and geodiversity Designated sites The Local Plan should set criteria based policies to recognise the hierarchy of designated biodiversity and geological sites and ensure their protection. Such policies should clearly distinguish between international, national and local sites*. Natural England advises that all relevant Sites of Special Scientific Interest (SSSIs), European sites (Special Areas of Conservation and Special Protect Areas) and Ramsar sites** should be included on the proposals map for the area so they can be clearly identified in the context of proposed development allocations and policies for development. Designated sites should be protected and, where possible, enhanced. The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can inform key decision making on strategic options and development sites. It may be necessary to outline avoidance and/or mitigation measures at the plan level, which will usually need to be considered as part of an Appropriate Assessment, including a clear direction for project level HRA work to ensure no adverse effect on the integrity of internationally designated sites. It may also be necessary for plans to provide policies for strategic or cross boundary approaches, particularly in areas where designated sites cover more than one Local Planning Authority boundary. The Plan should set out a strategic approach, planning positively for the creation, protection, enhancement and management of networks of biodiversity through all relevant development including housing, transport and community infrastructure. There should be consideration of geodiversity conservation in terms of any geological sites and features in the wider environment. The biodiversity policy and wider Plan preparation should apply the mitigation hierarchy and promote delivery of biodiversity net gain, in accordance with paragraphs 170 and 174 of the NPPF. The existing ecological network including designated sites, priority habitats and other important green spaces should be mapped along with key areas for protection and delivery of strategic / landscape-scale enhancements. This will help in the development of a strategy to inform the appropriate location of site allocations and to identify opportunities for delivery of biodiversity and green infrastructure enhancement projects through the Plan’s major development and biodiversity and green infrastructure policies. Ideally the policy should include a requirement for proposals to be accompanied by a biodiversity survey, including an audit of gains and losses, based on the Defra 2.0 metric or very similar methodology. Developer’s should also be required to consider Natural England’s IRZs to ensure that potential direct and indirect impacts to designated sites, including recreational pressure, are appropriately assessed and that any adverse impacts can be satisfactorily mitigated. The policy should seek to safeguard the value of previously developed land where it is of significant importance for biodiversity and/or geodiversity. Priority habitats, ecological networks and priority and/or legally protected species populations Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England. Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area. Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks. Planning positively for ecological networks will also contribute towards a strategic approach for the creation, protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF. Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran trees, there should be appropriate policies to ensure their protection. Natural England and the Forestry Commission have produced standing advice on ancient woodland, ancient and veteran trees. The policy should include a commitment to work with developers and Natural England to identify a strategic approach to great crested newt mitigation, where this is required, on major sites and other areas of key significance for this species. Green Infrastructure Green infrastructure refers to the living network of green spaces, water and other environmental features in both urban and rural areas. It is often used in an urban context to provide multiple benefits including space for recreation, access to nature, flood storage and urban cooling to support climate change mitigation, food production, wildlife habitats and health and well-being improvements provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands, rivers and wetlands. Green infrastructure is also relevant in a rural context, where it might additionally refer to the use of farmland, woodland, wetlands or other natural features to provide services such as flood protection, carbon storage or water purification. A strategic approach for green infrastructure is required to ensure its protection and enhancement, as outlined in para 171 of the NPPF. Green Infrastructure should be incorporated into the plan as a strategic policy area, supported by appropriate detailed policies and proposals to ensure effective provision and delivery. Evidence of a strategic approach can be underpinned by Green Infrastructure Strategy. We encourage the provision of green infrastructure to be included as a specific policy in the Local Plan or alternatively integrated into relevant other policies, for example biodiversity, green space, flood risk, climate change, reflecting the multifunctional benefits of green infrastructure. We advise the Council to prepare a map of the existing ecological network and opportunities for enhancement. An accompanying strategy should identify opportunities for delivery of biodiversity and green infrastructure enhancement projects through the Plan’s major development and biodiversity and green infrastructure policies. The policy should make provision for appropriate quantity and quality of green space to meet identified local needs as outlined in paragraph 96 of the NPPF. Natural England’s Cambridgeshire Accessible Greenspace Analysis (2010) may be of use when considering current level of provision whilst our Accessible Natural Greenspace Standard (ANGSt) offers useful guidance to developers. Provision of sufficient quantity of high quality alternative natural greenspace is an important tool in mitigating the effects on recreational pressure associated with new housing development on more sensitive SSSIs. Our advice is that the level of provision should be proportionate to the scale of development, for example 8ha /1000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance. The policy should promote Natural Cambridgeshire’s Developing with Nature Toolkit to maximise opportunities within the design of the development to provide sufficient area of high quality multi-functional green infrastructure, including sustainable drainage (SuDS) to deliver net gain for biodiversity, landscape and accessible open space to meet people’s recreational and health needs. Appropriately designed and managed green infrastructure can also provide significant climate change mitigation including urban cooling. Developers should be encouraged to follow Natural England’s Accessible Natural Greenspace Guidance detailed in 'Nature Nearby'. Landscape Natural England expects the Plan to include strategic policies to protect and enhance valued landscapes, as well criteria based policies to guide development. Access and Rights of Way Natural England advises that the Plan should include policies to ensure protection and enhancement of public rights of way and National Trails, as outlined in paragraph 98 of the NPPF. Recognition should be given to the value of rights of way and access to the natural environment in relation to health and wellbeing and links to the wider green infrastructure network. The plan should seek to link existing rights of way where possible, and provides for new access opportunities and avoid building on open space of public value as outlined in paragraph 97 of the NPPF. Soils and agricultural land The Local Plan should give appropriate weight to the roles performed by the area’s soils. These should be valued as a finite multi-functional resource which underpins our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver. The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with National Planning Policy Framework paragraph 170. Air pollution We would expect the plan to address the impacts of air quality on the natural environment. In particular, it should address the traffic impacts associated with new development, particularly where this impacts on European sites and SSSIs. The environmental assessment of the plan (SA and HRA) should also consider any detrimental impacts on the natural environment, and suggest appropriate avoidance or mitigation measures where applicable. Natural England advises that one of the main issues which should be considered in the plan and the SA/HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment. The effects on local roads in the vicinity of any proposed development on nearby designated nature conservation sites (including increased traffic, construction of new roads, and upgrading of existing roads), and the impacts on vulnerable sites from air quality effects on the wider road network in the area (a greater distance away from the development) can be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. We consider that the designated sites at risk from local impacts are those within 200m of a road with increased traffic***, which feature habitats that are vulnerable to nitrogen deposition/acidification. APIS provides a searchable database and information on pollutants and their impacts on habitats and species. *International sites include: Special Protection Areas (SPAs); Special Areas of Conservation (SACs) and Ramsar sites**. National sites include Sites of Special Scientific Interest (SSSIs) and National Nature Reserves (NNRs) Local sites include wildlife Sites or geological sites (a variety of terms are in use for local sites). Page 15 of 15 Tranquillity The Local Plan should identify relevant areas of tranquillity and provide appropriate policy protection to such areas as identified in paragraph 100 and 180 of the NPPF. The CPRE have mapped areas of tranquillity which are available here and are a helpful source of evidence for the Local Plan and SA. Flood and Water Management Natural England expects the Local Plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should be based on an up to date evidence base on the water environment and as such the relevant River Basin Management Plans should inform the development proposed in the Local Plan. These Plans (available here) implement the EU Water Framework Directive and outline the main issues for the water environment and the actions needed to tackle them. Local Planning Authorities must in exercising their functions, have regard to these plans. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focussed on European sites, SSSIs and local sites which contribute to a wider ecological network. Plans should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this. A specific requirement for relevant development to be accompanied by a detailed hydrogeological assessment should be included. Site allocations / assessment Our advice is that site assessment methodology should be based upon a robust and credible consideration of deliverability, the suitability of the land to accommodate the proposed development, as well as the potential contribution towards sustainable development against potential suitable alternatives. Preference should be given to allocating sites on brownfield / previously developed land to protect BMV land, noting that these can support important biodiversity. When assessing Site Allocations we recommend the use Natural England’s Impact Risk Zones, which are available for LPAs to download or through www.magic.gov.uk, to identify where development may have an impact on designated sites. Impacts and mitigation requirements should be identified through the SA. The delivery of mitigation measures will need to be secured through relevant Plan policies. Water resource / quality impacts and the effects of increased recreational pressure on SSSIs are likely to be key issues which need to be addressed for some of the settlements identified. The combined effects of proposed development will need to be considered where relevant. **The following wildlife sites should also be given the same protection as European sites: potential SPAs, possible SACs, listed or proposed Ramsar sites and sites identified, or required, as compensatory measures for adverse effects on European sites ***The ecological effects of diffuse air pollution (2004) English Nature Research Report 580 Design Manual for Roads and Bridges Volume 11, Section 3 Part 1 (2007), Highways Agency

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Our client, who is the landowner of several sites in Graveley, has instructed us to make the following comments on their behalf in respect of the Greater Cambridge Local Plan Issues and Options Consultation. One of the big themes outlined in the Local Plan Issues and Options 2020 is climate change. Achieving net zero carbon is an important consideration in the preparation of the Local Plan. The sites in Graveley were put forward as part of the Greater Cambridge Local Plan Call for Sites undertaken in Spring 2019. The sites provide an infill opportunity in Graveley and the homes would be efficiently designed. The sites can accommodate tree planting which will also create biodiversity net gain, another important big theme. The Issues and Options Consultation also identifies wellbeing and social inclusion as another big theme, especially in rural areas where people have limited access to services and transport. Enhancing the vitality of villages is supported by Paragraph 78 of the National Planning Policy Framework and the development of the sites in Graveley will enable homes and enhance the setting and spirit of the village through much needed housing providing environmental and social benefits. As set out in the Local Plan Issues and Options, the cost of renting or buying a home in Greater Cambridge is much higher than the national average. If the Local Plan does not make provision for a larger quantity of housing this will be exacerbated. To achieve this, the Council must set itself an ambitious housing target for the plan period. The Government’s Standard Methodology fails to consider changing economic circumstances in its calculations. Considering Greater Cambridge is at the heart of the Oxford-Cambridge Arc, the UK Innovation Corridor and the Cambridge-Norwich Tech Corridor, all of which will transform the regional economy, it is imperative the Councils plan for a higher number of homes than the minimum required by government. The type of housing provided should be informed by the Strategic Housing Market Assessment. It is also important to note that Paragraph 68 of the National Planning Policy Framework requires councils to identify 10% of their housing need on sites of 1 hectare or less. Land within and adjacent to villages such as Graveley is perfectly suited to meeting this requirement.

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2. Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. -We oppose new sites on the Green Belt. - We suggest reappraisal of the mix of employment and housing in the NECAAP area favours housing since your reports state 38% of workforce commute into GCP area. Employees resident in Cambridge are stated to have a high mode share of sustainable travel. Overemphasis on additional employment will create additional car based commuting unless a heroic change in commuting mode takes place for people in new and future empoyment. Conversely, the availability and type of housing provided will influence the number of outbound commuters. - The above point highlights the need for clarity as to how the Local Plan driver to provide around 41,000 homes relates to the commitment to achieve 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 assumpton about inward and outward commuting.

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3. Please submit any sites for green space and wildlife habitats you wish to suggest for consideration through the Local Plan. Provide as much information and supporting evidence as possible. - We support the Green Belt designations in place. - We strongly oppose reallocating land now in the Green Belt for future development; especially in Fen Ditton. This is a Council policy and the FDPC has consistently objected to all such proposals. - We support the concept of Green Corridors and repeat our previous suggestion that the River Cam corridor is further developed by the addition of the fields and woods following the direction of the abandoned railway line leading out to the land forming part of the Wicken Fen Vision and providing green separeation between Fen Ditton village and Cambridge City and the Airport/Marleigh/Wing development. - We suggest that exising land use in the Green Belt and in Green Corridors fulfils many green space and wildlife functions. Maintaining these is just as important as designating new sites unless the new designations strengthen the ability to avoid urbanisation and severance. - We suggest the role of the, nationally high, proportion of private green spaces is also taken into account in the analysis of need.

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7. How do you think we should prioritise these big themes? - If you intend the priority to inform resolution of conflicts between them, the existing order is reasonable. However the bigger issue arises from conflicts between the scale of growth in jobs and housing and GVA and the big themes.

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Q42. Where should we site new development? - Major new developments appear to be the main component of meeting the growth targets for housing and employment. It follows that sites with good transport connections are preferable.

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EXECUTIVE SUMMARY These representations are made on behalf of Endurance Estates and set out comments in relation to several questions in the Issues and Options Consultation on the emerging Greater Cambridge Local Plan (2017-2040). This representation is concerned mainly with the housing delivery strategy for Greater Cambridge and related Green Belt issues. However, it also touches upon interrelated topics such climate change, biodiversity and green spaces, wellbeing and social inclusion and great places. The emerging plan will need to strike the right balance between high growth needs and the character of what makes the area unique. It will also need to consider how the economic success of the area is not hampered by inadequate transport infrastructure, housing delivery and other infrastructure needs. Along with housing and economic drivers, the development strategy for Greater Cambridge will need to tackle sustainability in a holistic way, rebalancing growth in the area to respond positively to issues such as health and wellbeing, community, biodiversity, green infrastructure and climate change. In response to this challenge, this representation advocates allocating the widest possible range of sites in order to provide a more sustainable development strategy and to rebalance growth needs in Greater Cambridge in accordance with paragraphs 67 and 68 of the NPPF 2019. This means, amongst other things, allocating sufficient housing land for small-medium housing sites in rural settlements, which can deliver quickly and improve the rate at which houses can be absorbed by the market. To address this, it is clear that current settlement boundaries will need to flex to accommodate further growth in sustainable locations. Having assessed the reasonable options for meeting identified housing need set out in paragraph 137 of the NPPF, there is a compelling case for Greater Cambridge to initiate a review of the Cambridge Green Belt in order to best meet the challenges of its housing need and direct growth to sustainable locations, enhance the sustainability of existing rural settlements and promote sustainable travel in accordance with paragraphs 78, 103 and 138 of the NPPF.

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1.0 INTRODUCTION 1.1 These representations are made on behalf of Endurance Estates and set out comments in relation to several questions in the Issues and Options Consultation on the emerging Greater Cambridge Local Plan (2017-2040) in accordance with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012. 1.2 These representations should be read alongside Barton Willmore’s Greater Cambridge Housing Delivery Study (Appendix 1). This includes a detailed review of Greater Cambridge’s housing needs, current housing delivery strategy and local transport plan and the corresponding implications for the emerging Greater Cambridge Local Plan. Several key findings are made within this study in relation to the growth strategy for Greater Cambridge and provide the context for the recommendations set out in this representation. 1.3 This representation is concerned mainly with the housing delivery strategy for Greater Cambridge and related Green Belt issues. However, it also touches upon interrelated topics such climate change, biodiversity and green spaces, wellbeing and social inclusion and great places.

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2.0 GREATER CAMBRIDGE HOUSING STRATEGY - RECOMMENDATIONS 2.1 The Cambridgeshire and Peterborough Independent Economic Review (CPIER) 2018 highlighted concern that Cambridgeshire and Peterborough are running a very significant risk of not achieving their economic potential due to insufficient levels of planned housing. It calls for the recalibration of housing need assessments based on more accurate employment growth forecasts, which in turn should set new, higher housing targets – at the very least adding on accumulated backlog. This would require delivery of around 2900 homes per annum in Greater Cambridge until 2040. These indicative housing projections are substantially higher than the Government’s standard method and present exceptional circumstances to justify an alternative approach to the standard method. 2.2 To address this higher housing forecast up until 2040 the development strategy will need to balance the distribution of housing supply and ensure (as per para.59 of the NPPF) that sufficient amount and variety of land can come forward where it is needed. The current Local Plan trajectory places significant reliance on growth sites continuing the housing supply beyond 2031, but such sites are skewed to the north of the district and do not consider communities to the south. The collective proximity of these growth sites to one another also present future challenges in terms of market absorption rates. 2.3 Basing the CPIER’s estimates against the existing proportional representation of growth across the adopted development strategy shows the potential need for 6,294 additional homes in rural areas up until 2040 (see Barton Willmore Housing Delivery Study, 2020 – Appendix 1) beyond the current pipeline of homes that have permission or are allocated in the adopted Local Plans. This relies on the remaining housing need being delivered through densification of Cambridge, further urban fringe sites and new settlements. Whilst some of this need may be coordinated or shared with neighbouring authorities through the duty to cooperate it is highly likely that a great deal of this need will need to be delivered within Cambridge City and South Cambridgeshire taking into account the affordability crisis, sustainability objectives, as well as economic and market forces. Future pressure on Cambridge to densify and further expand its urban fringes will therefore need to be weighed against the harm to its compact and historic character. 2.4 The alternative scenario for the development strategy is to steer a greater proportion of homes towards sustainable rural settlements. As such, there is potential scope to consider the need for more than 6,294 additional homes to be delivered in rural areas up until 2040. In purely quantitative terms this would mean delivering around 60 homes in each of the 106 rural settlements as a minimum. 2.5 This raises some key questions for the Local Plan that are already contained in the Issues and Options Consultation, as follows:

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2.1 Land at Capital Park, Fulbourn is submitted as a potential allocation for residential development in the Local Plan. The site was submitted for consideration as part of the Call for Sites which ended in March 2019. The extent of the site is shown on the site location plan at Appendix 1. 2.2 The site is located in Capital Park, outside the development framework within South Cambridgeshire District Council (SCDC). The site extends to 5.490 hectares. Most of the site comprises an open field, though there are some buildings on the site including The Yews and The Firs in the north western corner which are currently unoccupied. There are no other significant physical constraints on the site such as tree protection orders or public rights of way. 2.3 The site is adjacent to a major employment site and hospital on the edge of Cambridge and a consented care home that was granted permission at Committee on 7 March 2018 (ref: S/3418/17/FUL) for the demolition of the existing Fulbourn social club and the construction of a 72-bedroom care home on land adjacent to the site. 2.4 The site is within the Green Belt, but is well screened by an existing tree belt along the southern and eastern boundaries. There is a consented scheme adjacent to the site for a care home. 2.5 The site is within Fulbourn Conservation Area. There are no listed buildings on or near to the site. Approved Care Home Site Site: Land at Capital Park 2.6 The site is within the Environment Agency defined Flood Zone 1 in terms of flooding from rivers (very low risk of flooding). The majority of the site is also within a ‘very low’ risk of flooding from surface water. 2.7 To the west of the site is land designated under policy H/3 ‘Fulbourn and Ida Darwin Hospitals’. Policy H/3 supports the redevelopment of the Ida Darwin Hospital for residential redevelopment on the eastern part of the Ida Darwin site, and the transfer of part of the building footprint to the Fulbourn Hospital site for new mental health facilities will be permitted. Planning Policy Context 2.8 Fulbourn is inset within the Green Belt with its own defined development framework. The Site lies immediately to the east of the current development framework for Fulbourn and within the Cambridge Green Belt. 2.9 Within the Green Belt, the NPPF recognises the construction of new buildings can be considered appropriate where they constitute ‘limited infilling in villages’ or ‘limited affordable housing for local community needs’ (paragraph 145). The adopted 2018 Local Plan also includes for a policy to allow for infilling in the Green Belt. 2.10 Notwithstanding the above, as part of the preparation of the Greater Cambridge Local Plan, a review of the Green Belt should also be undertaken to assess whether land currently within the Cambridge Green Belt still serves the five purposes of the Green Belt as set out in paragraph 134 of the NPPF. Where land does not serve these five purposes or the fundamental aim of Green Belt policy, which is to prevent urban sprawl by keeping land permanently open (NPPF paragraph 133), the Green Belt boundaries should be altered in the next Local Plan accordingly. 2.11 Furthermore, Green Belt land that no longer serves the five purposes and is in locations which facilitate more sustainable patterns of development, for example, land within close proximity to public transport corridors or adjacent to some of the larger villages in the District, should be released to contribute to reducing climate impacts. 2.12 The proposed development could be developed in such a way as to respect its surrounding context and would not result in any adverse impact on the character, amenity, tranquillity or function of Fulbourn. The Opportunity 2.13 Fulbourn is a Minor Rural Centre in the settlement hierarchy within the adopted 2018 Local Plan. Minor Rural Centres are the second most sustainable settlement type within the hierarchy and have a lower level of services, facilities and employment than Rural Centres, but a greater level than most other villages in South Cambridgeshire, and often perform a role in terms of providing services and facilities for a small rural hinterland. The adopted Local Plan confirms that within Minor Rural Centres there is scope in principle for larger scale windfall development within the village framework to allow larger villages with a reasonable level of services to provide services and facilities for surrounding smaller villages to achieve more development. 2.14 National Planning Policy also advises that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. It adds that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services (Paragraph 78). 2.15 A variety of facilities and services are currently available within walking distance of the site including a nursery 100m to the north of the site and a Tesco superstore approximately 800 metres to the north west (a 10-minute walk or 3-minute cycle ride from the site). 2.16 In terms of transport connections, there are four bus stops located adjacent to the site offering regular services to the city centre and Arbury, approximately every half an hour. Fulbourn Greenway is also proposed to be delivered that would better connect the site to surrounding cycle networks and is expected to be routed approximately 100m to the north. 2.17 The Site is therefore located in a sustainable location reducing the need to travel by car and can promote sustainable travel. Further public transport enhancements are also proposed that will improve connectivity to Fulbourn by sustainable and active modes of transport. Proposed Development 2.18 The proposed development is for a landscape-led development for either residential or commercial-led development with access provided off Capital Park Road, for either of the following options: ● The site could accommodate a landscape design-led residential development of approximately 150 residential units, subject to further design work. This would include 40% affordable housing subject to viability, landscaping, vehicular access and formal and informal open space, taking into account the trees around the boundary of the site. The site could also accommodate specialist housing including elderly accommodation or student housing; ● Alternatively, the site could accommodate a range of potential employment uses including offices, a hotel, or employment floorspace ranging from uses B1, B1b, B1c, B2 or B8. 2.19 Existing boundary vegetation will largely be retained and enhanced in order to provide a defensible boundary to the Green Belt edge and to contribute towards achieving net gain. 2.20 The proposed development would comprise infill development and has the potential to deliver tangible social, economic and environmental benefits to the surrounding area. Benefits 2.21 The development proposals could deliver numerous tangible social, economic and environmental benefits to the local area, including: ● The opportunity to deliver affordable housing to help meet the needs of Cambridge and Fulbourn; ● A landowner who wishes to work with the community in order to shape a proposal which meets the needs of and can provide wider benefits to Cambridge, as was achieved in the Fulbourn Care Home scheme adjacent to the site; ● Improving accessibility to the site by providing open space, play and recreation space that is accessible to residents throughout the village; ● Redeveloping part of the site which is brownfield land, in accordance with the councils’ sustainability agenda; ● The potential to provide specialist housing such as elderly care accommodation; ● Providing access to the countryside and the associated wellbeing benefits that arise from development in locations with access to the countryside and green spaces.

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3.0 CONCLUSION 3.1 In relation to questions 31, 32, 37, 40, 41 and 47 of the Greater Cambridge Issues and Options Consultation 2020, it is clear that current settlement boundaries will need to flex in order to accommodate further growth in sustainable locations. Paragraph 78 of the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Accordingly, the existing settlement hierarchy should be revised or re-ordered to consider further housing growth and its potential transformative nature. 3.2 There are several benefits to existing villages in receiving further housing supply and infrastructure, which have been highlighted in this representation. Transport is a key theme for the emerging Local Plan and the siting of additional housing in rural settlements near to transport corridors or planned transport interventions presents opportunity to realise a reasonable scale of growth that is both sustainable and meaningful compared to previous Local Plan allocations. Consequently, in answer to question 48, planned transport improvements create opportunity to rebalance housing supply geographically across the district, improve sustainable transport measures and better connect rural areas. 3.3 In response to questions 32, 39 and 45, the pressing housing problems of Greater Cambridge and the undersupply of housing relative to economic growth present a strong case for the emerging Local Plan to consider all development scenarios including a review of the Green Belt. The constraints to housing growth within Cambridge, its fringe areas and the potential overreliance on new settlements presents further reason to secure Green Belt release when combined with the high growth needs of the area and the overarching need to deliver growth in a sustainable way. It is vital that less sensitive locations on the edge of Cambridge are reviewed for Green Belt release, taking in to account the opportunity to bring forward sustainable development in a location that arguably provides the best opportunity to influence and change people’s behaviours around travel and commuting and encourage adoption of more sustainable modes of transport. Development in these locations can support residents living sustainable lifestyles, as well as living in sustainable buildings. 3.4 The high level of housing delivery needed to sustain a rolling 5 year housing supply throughout the plan period is best met through a mix of housing sites and land availability. Sustainable growth of settlements surrounding Cambridge can make an important contribution to this objective, creating opportunity to rebalance housing supply geographically across the district and tie in with improved sustainable transport measures. Having assessed the reasonable options for meeting identified housing need set out in paragraph 137 of the NPPF, there appears to be a compelling case for Greater Cambridge Planning Service to initiate a review of the Cambridge Green Belt in order to best meet the challenges of its housing need and direct growth to sustainable locations, enhance the sustainability of existing rural settlements and promote sustainable travel in accordance with paragraphs 78, 103 and 138 of the NPPF.

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Submission of the Department of Education: 1. The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. 2. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and DfE is the delivery body for many of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient school places, including those at sixth form, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We have published guidance on education provision in garden communities and securing developer contributions for education, at https://www.gov.uk/government/publications/delivering-schools-to-supporthousing-growth. You will also be aware of the corresponding additions to Planning Practice Guidance on planning obligations, viability and safe and healthy communities. 3. We would like to offer the following comments in response to the above consultation document.

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I write in relation to my client, Countryside Properties (UK) Ltd’s site at land west of Station Road, Fulbourn, Cambridgeshire. This submission follows a previous submission made in March 2019 as part of the Greater Cambridge Local Plan ‘Call for Sites and Broad Locations’ exercise. My client welcomes the opportunity to comment on the Greater Cambridge Local Plan: The First Conversation, which explores a series of big themes that will underpin the decisions about where homes, jobs, and infrastructure should be located, and consequently what spatial development strategy the Greater Cambridge Shared Planning Service should adopt. Countryside strongly welcomes the inclusion of these ‘big themes’ that will influence how jobs, homes, and infrastructure are delivered. The draft Local Plan’s strong focus on climate change, biodiversity & green space, wellbeing & social inclusion, and making great places provides an excellent framework and starting point within which consideration should be given to prospective sites. Of particular significance is the level of housing required, which should be set at a level that seeks to meet the demand created by the concentration of jobs in the Greater Cambridge area, and the spatial strategy. A key consideration will be how to accommodate sustained high growth, while keeping Greater Cambridge special. Countryside supports a blended strategy (as advocated in the Cambridgeshire & Peterborough Independent Economic Review (CPIER)) and one that focuses on sustainable locations that are well-connected or have the potential to be connected to high quality public transport, while recognizing that a range of sites is required to aid deliverability and to ensure that all villages can grow in a sustainable manner appropriate to their size and scale. My client’s site at land west of Station Road, Fulbourn proposes the erection of up to 200 dwellings with a care/community/retirement facility and associated public open space and would represent an appropriately sized extension to the large, sustainable village of Fulbourn. In recognizing the importance of linking communities with high quality public transport, my client recognizes the villages’ excellent and regular bus services between Fulbourn and many of the other major employment locations in the Greater Cambridge area, and also proposes to safeguard land for the provision of a new railway station at Fulbourn should it be required in the future. This submission comprises completed forms, which respond to the following questions: Q32: Do you think we should plan for a higher number of homes that the minimum required by government, to provide flexibility to support the growing economy?  Q37: How should we encourage a shift away from car use and towards more sustainable modes of transport such as public transport, cycling and walking?  Q39: Should we look to remove land from the Green Belt if evidence shows it provides a more sustainable development options by reducing travel distances, helping us to reduce our climate impacts?  Q40: how flexible should the Local Plan be towards development of both jobs and homes on the edge of villages?  Q42: Where should we site new development?  Q47: What do you think about growing our villages?  Q48: What do you think about siting development along transport corridors?  Q49: Do you have any views on any specific policies in the two adopted 2018 Local Plans? If so what are they? Site Description The site is located on the northern edge of the large village of Fulbourn, surrounded on its southern, western, and eastern sides by residential development and on its northern edge by the Cambridge to Newmarket railway line. Fulbourn is identified in the current South Cambridgeshire Local Plan as a Minor Rural Centre (Policy S/9). These are described as ‘having a lower level of services, facilities, and employment than Rural Centres, but a greater level than most other villages in South Cambridgeshire, and often perform a role in terms of providing services and facilities for a small rural hinterland’. The current policy permits ‘Residential development and redevelopment up to an indicative maximum scheme size of 30 dwellings…within the development frameworks of Minor Rural Centres’. This policy is considered to be unduly restrictive and the new Local Plan should allow for a greater level of development in sustainable villages such as Fulbourn. Fulbourn has an excellent range of shops, services, and facilities, including regular bus services to nearby employment sites such as Capital Park, the Peterhouse Research Park, and the Cambridge Biomedical Campus, and given its close proximity to Cambridge and sustainability credentials should be placed higher in any future settlement hierarchy when the new Local Plan is prepared. The National Planning Policy Framework sets out the five purposes of Green Belts (para. 135), which seek to a) check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land’. The National Planning Policy Framework states that Green Belt boundaries can be altered in exceptional circumstances where they are fully justified through the preparation or updating of a Local Plan. The site is located within the Cambridge Green Belt but plays a very limited contribution to the five purposes of Green Belts set out above. It is surrounded by residential development on its southern, eastern, and western sides, and by the Cambridge to Newmarket railway line to the north. Furthermore, there is increasing evidence (such as that set out in the Cambridge & Peterborough Independent Economic Review) that these exceptional circumstances exist – namely that the recent ‘Growth is employment has not been matched by corresponding house-building, or developments infrastructure’, and that ‘We are rapidly approaching the point where even high-value businesses may decide that being based in Cambridge is no longer attractive. If nothing is done, the damage to society from the continuing drift away of less well-paid workers may become irreparable’. This letter should be read in conjunction with the completed forms, and site location plan, and vision document that accompany this submission. I trust that the information submitted is sufficient for your purposes but should you require any additional information, please do not hesitate to contact me.

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General Comments 4. DfE notes that growth in housing stock and economic activity due to the City Deal is expected in the Greater Cambridge Area (comprised of Cambridge City Council ‘CCC’ and South Cambridgeshire District Council ‘SCDC’). This will place additional pressure on social infrastructure such as education facilities. The Plan will need to be ‘positively prepared’ to meet the objectively assessed development needs and infrastructure requirements. 5. DfE welcomes reference within the plan to support the development of appropriate social and community infrastructure within the ‘Big Themes’ of plan, and specifically at paragraph 4.3.3 regarding the need for provision of infrastructure alongside growth. 6. The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 94). 7. When new schools are developed, local authorities should seek to safeguard land for new schools and any future expansion where demand indicates this might be necessary, in accordance with Planning Practice Guidance and DfE guidance on securing developer contributions for education.1 We would be happy to share examples of best practice. 8. CCC and SCDC should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on Planning for Schools Development2 (2011) which sets out the government’s commitment to support the development of state-funded schools and their delivery through the planning system. 9. In light of the above and the Duty to Cooperate on strategic priorities such as community infrastructure (NPPF para 24-27)3 (3 NPPF paragraph 24-27 specifies that this collaborative working should include infrastructure providers.), DfE encourages close working with local authorities during all stages of planning policy development to help guide the development of new school infrastructure and to meet the predicted demand for primary and secondary school places. Please add DfE to your list of relevant organisations with which you engage in preparation of the plan. 10. Please note that there are two routes available for establishing a new school. Firstly, a local authority may seek proposals from new school proposers (academy trusts) to establish a free school, after which the Regional Schools Commissioner will select the successful trust. Under this ‘local authority presumption route’ the local authority is responsible for finding the site, providing the capital and managing the build process. Secondly, school proposers can apply directly to DfE during an application round or ‘wave’ to set up a free school. The local authority is less involved in this route but may support groups in pre-opening and/or provide a site. Either of these routes can be used to deliver schools on land that has been provided as a developer contribution. DfE has published further general information on opening free schools4 as well as specifically in relation to opening free schools in garden communities.5

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Q42 Summary: A blended spatial strategy is supported but specifically including development in villages and along public transport corridors. Full comment: Within this question the Greater Cambridge Shared Planning Service invites consultees to rank a series of options about where new development should be located within the spatial planning area of Greater Cambridge. It explores six choices: - densification of existing urban areas - edge of Cambridge: outside Green Belt - edge of Cambridge: Green Belt - dispersal - new settlements - dispersal: villages - public transport corridors This is a rather blunt tool in which to assess the spatial approach and a flexible approach is likely to be more appropriate. Within the Cambridge & Peterborough Independent Economic Review (CPIER), which was published in September 2018, it concludes that 'Cambridgeshire and Peterborough is an area which already makes a huge contribution to the UK, and which holds great promise for the future. It also faces risks, which could bring the success to an end, and challenges relating to creating an inclusive society where economic growth works for everyone'. The CPIER, which admittedly covers a wider geography than Greater Cambridge, advocated a 'blended spatial strategy' of four possible scenarios. The scenarios considered included: - densification - dispersal - fringe growth - transport corridors It concluded that 'some densification, particularly in Cambridge, is needed, though this should happen away from the historic centre, and more on the edges, as and where new development sites come forward. There should be some scope for expanding development around the city boundary, but intelligently planned transport links will be needed to avoid worsening of congestion. In Cambridge specifically though there are limits to the growth of the city in other directions, the east side of the city [of which Fulbourn is on] offers significant scope for housing and commercial development. Such development would have the advantage of being close to the principal centres of employment and the existing rail infrastructure whilst also opening up opportunities for new transport links to connect the main centres of employment more effectively'. My client's site at land west of Station Road, Fulbourn is a very sustainable location, which is consistent with the conclusion of the CPIER. The site is well-related to the centre of Fulbourn, which benefits from a high quality bus service and the site is also adjacent to the Cambridge to Newmarket railway line, where land has been safeguarded to provide for a new railway station should it be required in the future.

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Question 2: Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Q2 response: 24. DfE would like to be included as early as possible in discussions on potential site allocations, as there are central wave pipeline free school projects in Greater Cambridge which may be appropriate for specific designation. We would welcome the opportunity to meet with the Council in the near future to discuss these projects. The provision of school places is required to ensure that the needs of existing and future communities are met, as well as widening choice, increasing quality and maximising opportunity through education. Therefore, it is important that the policy framework ensures the expedient delivery of schools and expansions. 25. In relation to questions 38-48, regarding the specific location of development, DfE would request that the infrastructure delivery considerations are assessed as part of determining the overall spatial strategy. This is to ensure that the right sites are able to be brought forward in the right timescales for infrastructure delivery, with as few additional burdens to delivery as possible.

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Conclusion 44. Finally, I hope the above comments are helpful in shaping the Greater Cambridge Plan, with specific regard to the provision of land and developer contributions for schools. Please advise DfE of any proposed changes to the emerging Local Plan policies, supporting text, site allocations and/or evidence base arising from these comments. 45. Please do not hesitate to contact me if you have any queries regarding this response. DfE looks forward to continuing to work with SCDC and CCC to aid in the preparation of a sound Plan.

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Response to Question 2 The landowner has submitted the proposed site option at the 2019 Call for Sites stage. However further work has been done on the A428 dualling route in readiness for the Development Consent Order application by Highways England – anticipated for submission Summer 2020. The detailed plans for the A428 have now been made available through its 2019 consultation exercise and whilst the previous submission is still relevant as a broad location for growth, the attached concept plan incorporates the detail from the proposed A428 general arrangement plans. The position of the Toseland Road overbridge and its proposed connections into the site are reflected on the attached Concept Plan to demonstrate how an early phase of development could be delivered. The preferred route of the East West Rail Link has now been identified, including a new rail station at Cambourne. Options for the Cambridge Area Metro (CAM) to be extended along the route of the existing A428, once downgraded, leads to further consideration as to how development in this location could contribute to the objectives of sustainable development. NPPF 2019, para 72 directs strategic-policy makers to consider the opportunities presented by existing or planned investment in an areas infrastructure when considering suitable locations for new development. The Concept Plan shows how a garden village concept within the Greater Cambridge Local Plan administrative boundary could be achieved. It can either be standalone for circa 1,750 homes and associated supporting infrastructure on part or all of the 106 hectares that lies within South Cambridgeshire administrative boundary or it has the potential to form an early phase 1 of a larger garden village community of up to 4,000 new homes in the future, through cross boundary working with Huntingdonshire District Council. The land is under a single ownership and can be phased over plan periods to continue delivering to 2050. A proposed Garden Village at Croxton would be a unique, practical and exciting opportunity to deliver housing and growth needs using Garden Settlement principles in Greater Cambridge without requiring the release of further Green Belt land. As guided by NPPF 2019, non-Green Belt options should be fully explored before considering any further Green Belt releases for strategic-scale development. The proposed location, being bounded by the existing and new A428 road could provide a unique solution towards meeting the identified social and economic needs and addressing the housing and development delivery during the plan period and beyond.

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Housing: Thank you for consulting Fenland District Council (FDC) on your Local Plan Issues and Options consultation document. FDC recently completed their Issues and Options consultation which includes housing need figure of 11,550 dwellings between 2019 and 2040. We welcome the long term strategy of your Local Plan, with the same proposed end date of 2040.

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As you are aware FDC is working on a shared evidence base for the Strategic Housing Market Assessment and Gypsy and Travellers Accommodation Needs Assessment with other Cambridgeshire and surrounding authorities. At this early stage, FDC is unaware of any strategic matters which might arise between the two areas. We would like to be informed of the progress of the Great Cambridge Local Plan and welcome further discussion as the Plan progresses. To confirm, at the present time, FDC is not seeking to accommodate any unmet housing need from Greater Cambridge (should any such unmet need arise), nor ‘offload’ any need arising in Fenland to Greater Cambridge.

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1. Introduction 1.1 Magdalene College was founded in 1428. The historic campus sits immediately to the NE of Magdalene Bridge. Additional student accommodation is also provided on the west side of Magdalene Street in converted historic buildings and purpose-built blocks constructed throughout the C20. Further accommodation is provided in converted and purpose-built accommodation off Chesterton Lane and in Thompson’s Lane. The College also are the free-holders of Quayside and some properties along Bridge Street. 1.2 The College has a resident community of almost 800 students, fellows and members of staff. The majority of undergraduate students are housed in College accommodation either side of Magdalene Street with post-graduates additionally housed off Chesterton Lane, Hertford Street and Northampton Street. The College also enjoys extensive gardens beside the river contributing to the ecological diversity of the River Cam. 1.3 Turley were asked to provide these representations to the Cambridge Local Plan Issues and Options Consultation on behalf of Magdalene College in early 2020.

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Response to Question 2 Granta Park - Context Granta Park is a well-established Science and Technology campus located in Great Abington, South Cambridgeshire providing for office, Research and Development (R&D) and laboratory space. The R&D sector has driven the Cambridge phenomenon and has been a major component of the ongoing success of the Cambridge Economy. The Park is a major contributor to the local and wider economy and a part of this vital R&D sector. Over 3000 staff are employed at the park, in excess of 500 of those staff work at TWI Ltd, a not-for-profit research organisation owned by its members, which also accommodates 90 PhD students and approximately 150 students studying Masters programmes. Housing supply and affordability is a significant issue across Greater Cambridge and this is also the case for employees at the Park. The core of the Park’s competitiveness in the labour market centres around being able to provide a high-quality work force, which in turn is reliant on there being affordable housing available in a location to be able to commute from; ideally by sustainable travel. Although the R&D sector is a highly valuable part of the economy, not all jobs in the sector are highly skilled and highly paid, so not all employees of the sector are able to readily access the local housing market. For reasons largely around availability and affordability, employees at the park currently commute from a wide range of locations that in turn creates an environmental impact arising from those vehicular journeys, this also impacts on the health and wellbeing of the employees through spending prolonged time travelling to and from work. An initial survey of employee post code locations has been formed and is included in Appendix 3, this initial survey finds that the employees are spread over a wide area. This situation makes it more difficult to attract new employees, retain employees and provide a more sustainable Granta Park. To help address this issue there is a need for the provision of housing that is affordable and close to Granta Park for its essential workers. This approach is supported by the Greater Cambridge Authority through the Greater Cambridge Housing Strategy 2019-2023 which includes the needs of workers who provide support services necessary for the local economy. Essential local workers must be accommodated within this definition to help support the economy and reduce excessive commuting distances. Annex 5, Section 7.1 of the Cambridge Housing Strategy, Providing for different types of homes to meet specific need - Promoting housing for Essential Local Workers, states: 7.1.1 Both councils are keen to work with local employers and other partners to get a better understanding of the potential need for housing for local workers to support local services, the local economy and further economic growth. 7.1.2 The National Planning Policy Framework (NPPF) defines ‘essential local workers’ as certain groups of public sector employees who provide frontline services in areas including health, education and community safety. However, we do not believe there is a ‘one size fits all’ definition. As well as public sector employees providing frontline services, we also want to take into account the needs of other workers who provide the support services necessary for the economy. It is important that housing provision, in particular a range of affordable housing options, supports the local economy and helps to reduce long commuting distances to work. 7.1.3 Any development for essential local workers will need to be evidenced based in terms of how it supports economic growth and housing need. Analysis of income levels, household type, etc. will inform the type and size of development. 7.1.4 Whether such housing should be provided on a particular development is also likely to be dependent on issues such as location of the development, the particular needs of the employer(s) concerned, and the need to create mixed communities that support the needs of the wider population. 7.1.5 South Cambridgeshire in particular is interested in working with businesses to help themselves to deliver a range of homes that are provided for and are affordable to their workforce. The aim would be to provide additional homes specifically to address the housing needs of their workforce without impacting on the delivery of housing, including affordable housing, more generally. This directly relates to Granta Park and its essential workers who contribute to the ongoing success of the Park and its contribution to the economy. The Research and Development sector is vital to the Cambridge Economy and the Granta Park employees are vital to the contribution Granta Park makes. There is an affordability issue within Greater Cambridge, with a large proportion of the population struggling to afford suitable accommodation. To help address this, Granta Park wishes to ensure there is housing available for its employees, as essential local workers, and to make land available within the Parks ownership to provide for some of this much needed housing. As the emerging Local Plan is brought forward, this ‘Granta Park housing need’ will be evidenced to show the extent and type of need, but it is clear that a modest number of homes will start to make a notable and positive contribution to a number of workers at Granta Park. As a related example, permission is to be granted at the Wellcome Genome Campus Hinxton, (ref: S/4329/18/OL) within South Cambridgeshire at a Research and Development Park to provide for 1,500 new homes specifically for its Campus Workers. While Granta Park propose only a modest allocation to support its workers, there is a direct comparison for the overarching reasons and benefits to accrue from providing linked worker housing.

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1. Introduction 1.1 This statement has been prepared by Turley on behalf of The Bell Educational Trust Limited (the Trust) in response to the questions set out in the Greater Cambridge Local Plan Regulation 18: Issues and Options Consultation 2020 (the Consultation). 1.2 The Trust is the charitable shareholder of the Bell School which is located on the southern edge of the City in Redcross Lane, in close proximity to Addenbrookes. 1.3 This statement specifically considers those matters most relevant to the Trust and their current and future role within the City. Whilst the current Cambridge City Council Local Plan 2018 acknowledges the role that language and specialist schools make to the economy of the City, it also places a number of restrictions on their future expansion and ability to accommodate their students. 1.4 These restrictions are considered within this statement and emphasise the need for future policy to provide flexibility and give due consideration to all types of education provision within the City. 1.5 Section 3 of the report provides a detailed response to the Consultation on behalf of the Trust. The comments made focus on jobs, homes and biodiversity and green spaces.

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2. Background 2.1 The Bell Educational Trust Limited (the Trust) owns the site and wholly own Bell Educational Services (Bell), its trading subsidiary. Bell is an English language school for international students and has been established for over 60 years in Cambridge. 2.2 The school was founded by Frank Bell, a University of Cambridge graduate who had a vision to promote intercultural understanding through language education. Following his experience during the second world war, where as a prisoner-of war he established an “undercover University” and organised language courses to promote understanding and harmony through language education. In 1955 he opened his first language school in Cambridge. Since then Bell has grown to become a high-quality education business. The school offers a wide selection of English language courses, as well as university foundation courses for graduate and post graduates, young learners’ courses and teacher training. 2.3 Bell runs English language courses for international students, of variable duration, depending on student requirements. These courses run all year and provide the majority of the student intake. Bell also provides longer term courses for international students preparing for entry into higher education, where the study is in English. 2.4 The need to provide student accommodation has to be considered in the wider context of the expansion of the school teaching space and support facilities as a whole. In order to ensure that Bell continues to operate at the premium end of the market, the Trust needs to ensure that the school facilities are at the very least compatible with the best of its competitors. 2.5 The long term aspirations are to expand the current language school on the site at Redcross Lane through both the ability to increase the teaching floorspace and also to accommodate future students within a campus setting. 2.6 The following sections of this report provides specific comments in relation to the Trust’s views on the future policy approach for the Local Plan. Namely; • the provision of a policy which covers all education establishments in equal measure including the requirements for residential accommodation; • the removal of any requirement to restrict the occupancy of student accommodation to those undertaking a full-time course of a year or more; and • the re-assessment of the criteria relating to the designation of Protected Open Space.

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6. Summary and Conclusions 6.1 This representation has been provided on behalf of The Bell Educational Trust to the Greater Cambridge Local Plan Regulation 18: Issues and Options Consultation 2020. 6.2 These representations have provided general comments to the document subject to consultation and specifically relate to the Bell School site at Redcross Lane, Cambridge. 6.3 The school has been part of Cambridge since the 1950’s and has played a valuable role in encouraging students from abroad to the City. The Trust is seeking a more flexible policy approach to the future expansion of ‘non-university’ institutions in recognition of the important role that they play within the economy of the City and tourism. 6.4 Importantly, the removal of restrictions on those student attending short or part-time courses in terms of student accommodation and a more comprehensive approach to all education provision across the City. The Protected Open Space allocation for the wider school site currently makes it very difficult for the school to expand and the restrictions enforced through Policy 46 of the Cambridge Local Plan 2018 only add to this. 6.5 Accordingly we seek the following specific policy changes in the emerging Local Plan to facilitate the future growth of the Bell School; • The removal of any policy relating specifically to language schools and specialist schools and instead a broad policy that covers the expansion of all educational institutions with no requirement for residential accommodation; • Any policy relating to student housing should remove the criteria restricting the provision of new student accommodation to those attending a full time course of one year or more. This would enable the provision of education, outside of the two universities, to expand and continue to contribute to the local economy while being more inclusive; and • The review of the criteria attached to any Protected Open Space designation and the area to which this refers. The Trust wish to see the attractive grounds of the site retained but consider there to be no justification for the inclusion of some of the areas within the blanket designation. 6.6 The Trust is happy to meet with officers to discuss the matters raised further in order to assist with the drafting of the new Plan if that would be helpful.

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Thank you for your e-mail dated 13th January in respect of the above. The opportunity to contribute to the consultation is welcomed. It is noted that a questionnaire type format has been used. As you will appreciate as a navigation, water level and flood risk management authority many of the matters or questions are not relevant to our duties and functions. Therefore, please find below our response to the applicable questions asked. Where the questions raised are not specifically relevant but may be related to issues upon which we would like to make a remark we have prefixed the text with the word "Comment". Our response is as follows: (A) Risk Management Authorities The Middle Level Commissioners (the Commissioners) are a statutory water level and flood risk management and navigation authority responsible for the maintenance of major watercourses within their catchment. In addition to their statutory role, the Commissioners provide consultancy services to the Internal Drainage Boards (the Boards) within and adjacent to their area. The Boards are autonomous water level and flood risk management authorities that obtain support from the Commissioners' staff and supervise drainage at a more local level. The Commissioners and associated Boards are Risk Management Authorities (RMA), as identified by Defra and designated under the Flood and Water Management Act 2010. Together with the County, your and other District Councils and other stakeholders, the Commissioners are members of the Cambridgeshire Flood Risk Management Partnership (CFRMP). As members of the CFRMP we would generally promote issues that improve water level management and reduce flood risk on our particular systems in accordance with the respective policy statement. Please note that the Commissioners' catchment does not extend into the Greater Cambridge area. Therefore, with the exception of general navigation related issues, this response is made on behalf of the Boards for whom we provide a planning consultancy service within your Council's area of jurisdiction which are listed above.

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