Question 51: Generic Question

Thank you for consulting East Cambridgeshire District Council on your Local Plan at the Issues and Options stage. The online document is well laid out and makes good use of diagrams and illustrations. It is easy to navigate with sections and sub-sections clearly laid out. We note it is very much an open consultation asking questions, rather than making proposals at this stage. We welcome the long term strategy of the Local Plan, with its proposed end date of 2040. In terms of any cross-boundary strategic matters which might arise between our two areas, as a consequence of your emerging Local Plan, at this early stage we note your commentary at section 3.6.5. ECDC is content that this identifies the right broad areas for consideration, though is a little uncertain about what, if any, cross border implications there could be on ‘carbon offsetting and renewable energy generation’, which is the third of your identified issues. This implies that your plan may seek to include carbon offsetting or renewable energy generation beyond its boundaries? Clarification would be welcomed. Nevertheless, you correctly identify housing as a key strategic issue, and we note elsewhere a range of options for your growth strategy and also a question seeking views on going beyond the ‘standard method’ for establishing a housing target, potentially substantially increasing your target. As the Plan evolves, if it seeks to plan for anything significantly different than its housing need as established via the national standard method, then ECDC requests early engagement with you on this so that we can understand what implications, if any, such departure from national policy would have on the district of East Cambridgeshire. For the avoidance of doubt, at the present time, ECDC is not seeking to accommodate any unmet housing need from Greater Cambridge (should any such unmet need arise), nor ‘offload’ any need arising in East Cambridgeshire to Greater Cambridge. The other issue which may arise as you progress your Plan is whether any review of the Green Belt is to be considered. As you are aware, part of the outer boundary of the Green Belt falls within ECDC area. As such, any review of the Green Belt, especially its outer boundary, should include full involvement of ECDC. We have no further comments to make on your Local Plan at this stage. We understand this is an early stage in the preparation of the Local Plan and we would welcome to be kept informed of its progress.

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Response to Question 2 - ADDITIONAL INFORMATION 2.1 Land to the north of Station Road, Cambridge is submitted as a potential allocation for employment in the Local Plan. The extent of the site is shown on the site location plan at Appendix 1. 2.2 The Site is located on the north side of Station Road, Cambridge and stretches from the Hills Road/ Station Road junction eastward to Tenison Road. The site is composed of eleven buildings, comprising 1 - 4 Arundel Villas (semi-detached), St Andrews (detached) and 1 - 6 Salisbury Villas (detached). In this document, they are all collectively referred to as the ‘Salisbury Villas’, for simplicity. The villas are currently in Use Class B1(a) (office) and Use Class D1 (language school). 2.3 The villas are set back approximately 16m from Station Road and, what would have originally been separate front gardens, have been joined together to form a second access road, parallel to Station Road, with parking behind a row of mature lime trees. 2.4 The Site can be accessed from Station Road and the junction of Station Road and Tenison Road. 2.5 The Site is surrounded by office development to the east and south, as part of the ‘Area of Major Change’ to the Station Area, and residential properties lie to the north. No.s 55-59 Hills Road and No.s 1-7 Station Road (also within the ownership of Jesus College) lie to the west and are in retail use. The Vision 2.6 The vision is to breathe new life into the Site, continuing the successful transformation of this part of the city and to provide additional capacity to support the clustering in the local area, which has proven so important to Cambridge’s economy. 2.7 In order to guide the future development of the site, the College has developed four core objectives: ● Supporting a sustainable Cambridge by making appropriate and efficient use of a site in a highly accessible location; ● Spearheading solutions to move to a net zero-carbon society in the context of the climate emergency in this highly sustainable and accessible location; ● Delivering a lasting legacy of high-quality architecture with a distinctive character to create a unique sense of place as part of the College’s long-term endowment portfolio; ● Enhancing the green space and public realm at this important gateway into the city centre. 2.8 The supporting Vision Document provides further detail on the significant opportunity that the site presents, informed by additional site assessment work and in light of the four ‘big themes’ identified in the consultation document. The Economic Context 2.9 National Planning Policy confirms that planning policies should help create the conditions in which businesses can invest, expand and adapt (NPPF, paragraph 80). The NPPF specifically states that “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development” (emphasis added). The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. 2.10 The NPPF continues, at paragraph 81, in advising the planning policies should: “a) set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration; b) set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period; c) seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment; and d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances.” 2.11 Paragraph 82 adds that: “Planning policies and decisions should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries; …at a variety of scales and in suitably accessible locations” 2.12 The Cambridgeshire and Peterborough Independent Economic Review (CPIER) (2018) and the Cambridgeshire and Peterborough Industrial Strategy (2019) provide such a vision and have each outlined ambitious plans for growth over the next 20 years. 2.13 Furthermore, the Cambridgeshire and Peterborough Combined Authority (CPCA) has a target of doubling the regional economic growth (GVA) over the next 25 years as part of the Devolution Deal. This requires the area going beyond what it has achieved in the past (to double an economy over twenty-five years requires an average annual growth rate of 2.81%. Historically, since 1998, the local economy has only grown at around 2.5%.). Achieving this requires employment growth and more importantly productivity growth, as we are already at comparatively high levels of employment 2.14 In order to deliver this ‘step change’ in economic performance, the Consultation document states that around 2,900 homes a year would need to be built in Greater Cambridge if the jobs growth is achieved – an indicative total of 66,700 homes over 2017 – 2040. This compares with 1,800 homes per year to meet local needs using the Government’s standard method. 2.15 There is clearly a need to provide for an amount of housing above the standard methodology to take account of the pressing and worsening affordability issue and to support the aspiration to grow the Greater Cambridge economy and double the GVA across the Greater Cambridgeshire and Peterborough area. The Opportunity 2.16 The Station Road area in Cambridge has changed beyond all recognition since the preparation of the Station Area Development Framework (SADF), adopted in April 2004. Significant development has since come forward in recent years along Station Road as part of the Area of Major Change resulting in the delivery of a bustling city quarter today. The Site now finds itself located at the heart of Cambridge’s newly formed Central Business District (CBD) and it has attracted a number of significant pre-lets; a sign of its desirability. 2.17 The area has seen job growth of 4% since 2015, much of which has been focused along Station Road where 0.5 million sf ft of offices has been built since 2013. The new occupants (such as Microsoft, Amazon, Samsung and Apple) have created a new Research and Development (R&D), AI and business services cluster. Such knowledge intensive industries tend to cluster together, pulled by the forces of agglomeration (easy access to knowledge, workforce, supply chains, markets). 2.18 This clustering has significant benefits to Cambridge and the wider UK economy and to grow this cluster requires office development in close proximity to the existing occupants. However, future business development in the area is constrained by the lack of high-quality office space. All the commercial buildings within the ‘CB1’ masterplan area, along Station Road, now have planning permission or a resolution to grant permission. Current availability in this area is now less than 1.5%, with no Grade A space. 2.19 The supporting Employment Needs Appraisal, prepared by Bidwells LLP, confirms that this limited supply and strong demand has led to significant increases in rent of 32% over the past five years. For the R&D, AI and business services sector, the location decisional drivers are access and ability to recruit the right skill sets. Central Cambridge provides this, but the small size of the core central area, the lack of available space and lack of development pipeline puts that resilience at risk and could undermine the growth of the R&D sector. 2.20 Land to the north of Station Road is the last section of the Station Road area to benefit from a clear and shared long-term vision and so represents a significant opportunity to continue the successful transformation of this part of the city and provide additional capacity to support the further clustering around the Station. 2.21 The Site is within single ownership and capable of delivering a well-designed, high quality development that could make efficient use of a brownfield site, in a highly sustainable location, whilst also being able to respect its historic context. The site’s proximity to Cambridge railway station, links to the Chisholm trail and the transport interchange at the Station also enables opportunities to promote sustainable transport modes. Responding to the Four Big Themes 2.22 Since the submission of the ‘Call for Sites’ representations in March 2019, Jesus College has appointed a masterplanner, Allies and Morrison, to undertake a detailed analysis of the site constraints and opportunities, informed by further technical assessment work. A summary of this assessment work is provided below. These assessments have specifically sought to respond to the four ‘big themes’ of the emerging Local Plan and in turn help shape the emerging concept proposals for the Site. Climate Change 2.23 The two Councils and the County Council have committed to achieve net zero carbon by 2050. In order to meet this challenge, the Local Plan will need to plan for low-carbon lifestyles and encourage low carbon activities and alternatives to private car use. 2.24 The Local Plan will also need to promote highly sustainable patterns for growth, such as densification of underused brownfield sites like Land to the north of Station Road, that enables travel by low-carbon modes thus reducing car use to ease congestion and reduce airborne pollutants. The same measure offers opportunities to promote active travel choices (walking, cycling) to enhance health and wellbeing. 2.25 A Sustainable Transport Appraisal for the Site has been prepared by Vectos and accompanies these representations. This confirms that the site is extremely well located for access to key facilities and services, including transport infrastructure such as Cambridge Railway Station and the Cambridgeshire Guided Busway (CGB) and the city centre; all within a 10 minute walk. Furthermore, there are a number of strategic schemes coming forward which will improve mobility in the area (the Chisholm Trail, extensions to the CGB, Cambridge Autonomous Metro). Along with a rare opportunity to reduce the amount of car parking within a City Centre location. 2.26 A Sustainability Appraisal for the Site has been undertaken by Hoare Lea and this has been incorporated into the accompanying Vision Document. This reviews the emerging concept proposals from a sustainability perspective and outlines a number of climate change mitigation and adaptation measures that could be incorporated into redevelopment proposals for the Site, such as: ● Passive design measures which lower the cooling requirement and have shorter lifecycles, such as solar shading and high fabric performance; ● Improvements to water efficiency, such as water efficient fittings and metering and systems which recover water; ● Design measures to minimise waste volume as far as possible, through the careful selection of materials and the use of techniques such as off-site and modern methods of construction, material consumption, waste volumes, and product quality; ● Improvements to flood resilience through removal of large areas of hardstanding and incorporation of a range of future climate scenarios that better manage the water runoff into the wider city drainage system. Specifically, there is opportunity to explore the integration of measures such as green or blue roofs and sustainable drainage systems; and ● Green infrastructure to offer greater resilience to a warmer and drier climate than currently exists, to provide a 10% net biodiversity gain in ecosystem habitats and to provide broader ecosystem services such as forming part of a sustainable drainage system. 2.27 The operational emissions of a building are defined as those emissions (measured in CO2 equivalent, or “CO2e”) arising from the use of energy in the day to day running of the building from uses such as lighting, heating, ventilation, and equipment. This can be measured in absolute terms but, in order to allow comparability between buildings, is often quoted as an intensity metric, such as CO2e/FTE; which represents the carbon emissions generated from a building on a per full time employee basis. 2.28 Development at scale presents an opportunity to radically reduce the carbon intensity per employee at the site. 2.29 The Local Plan will be required to allocate land to provide for an increase in employment floorspace across Greater Cambridge. These additional jobs will have to be allocated somewhere; there is great benefit to provide these new jobs in a highly accessible location and in a manner that would improve the operational carbon intensity of an existing site. Biodiversity and Green Spaces 2.30 Both Councils have declared biodiversity emergencies and, as members of the Natural Cambridgeshire Local Nature Partnership, the Councils support the Partnership’s vision to double the area of rich wildlife habitats and natural greenspaces within Cambridgeshire and Peterborough. 2.31 Jesus College recognise the importance of improving the natural environment and is committed to achieving net biodiversity gain in respect to potential redevelopment proposals at Land to the north of Station Road, Cambridge. The Site in particular presents an opportunity to greatly improve the public realm along the Station Road frontage and in turn create wellbeing through improved public spaces to relax, move through and socialise. As referred to above, new areas of green infrastructure also provide opportunities to mitigate against climate change, through creating resilient new habitats. 2.32 A site-wide ecological appraisal and background desk study was completed by Ecology Solutions in December 2019 and accompanies these representations. 2.33 The key findings from the appraisal are summarised below: ● There are no statutory or non-statutory designated sites within or directly adjacent to the site; ● The habitats within the site are of limited intrinsic ecological interest; ● There are no overriding ecological constraints to redevelopment of the Site; ● The villas offer potential opportunities for roosting bats and as such further surveys are required. However, there is good scope for providing enhancements for bats as part of any redevelopment proposal; and ● The site presents opportunities to achieve a 10% biodiversity net gain through a sensitively designed, landscape-led scheme which would incorporate, wherever possible, native species of local provenance and those of known value to native wildlife to offer biodiversity gains post-development. 2.34 A Tree Survey and Constraints Plan was prepared by Haydens in January 2020 and accompanies these representations. 2.35 The key findings from the survey work are summarised below: ● A total of sixty-nine individual trees, nine groups of trees and two areas of trees have been surveyed. These were found to be of mixed condition and age providing a variety of amenity benefits; ● Three of the trees are identified as Category A trees (high quality and value). These are as follows: − T012: Austrian Pine − T059: Beech (this tree is located on neighbouring land, but due to its proximity to the boundary, it could nonetheless affect development proposals) − T066: European Lime ● The majority of the other mature trees are classified as Category B (moderate quality and value), with the remainder either category C (low quality and value) or U (remove); ● All the trees along Station Road are Lime and classified as Category B; ● The tree species in the back gardens are more mixed and are mainly either Sycamore, False Acacia or European Lime; and ● Any redevelopment proposal would need to consider the siting and design of the layout in respect to the presence of trees, particularly those of the highest quality, and add new trees where possible. Wellbeing and Social Inclusion 2.36 Cambridge City Council has an Anti-Poverty Strategy which includes an action plan. This identified that while the Cambridge economy continues to thrive, there are high levels of income inequality in the city. Cambridge City Council also has an Air Quality Action Plan 2018-2023 and sets out Cambridge City Council’s priority actions for improving areas of poor air quality in the city and maintaining a good level of air quality in a growing city. 2.37 Redevelopment of Land to the north of Station Road has the potential to achieve ‘good growth’ that promotes wellbeing and social inclusion, as outlined below. These benefits also serve to reinforce the potential of the site for employment densification: ● Securing improvements in air quality through promotion of a car-free development thus reducing car use to ease congestion and reducing airborne pollutants within a designated Air Quality Management Area (AQMA); ● Encouraging healthy lifestyles through provision of employment opportunities in a highly accessible location by low-carbon modes, thus encouraging active travel. The Site is also within five minutes walk of the Botanic Gardens, which provides open space of a scale that can absorb a large number of people, thereby having the capacity to serve high density employment development; ● Proximity to a range of shops and services which offer healthy eating choices; ● Proximity to local services and amenities bringing opportunities for social interaction and community development. Particularly important given a large number of potential employees will not likely be resident in Cambridge and have established local networks; ● Opportunities for new build design to provide all-electric heating and hot water systems to avoid the on-site combustion of fossil fuels and incorporate passive design to support indoor air quality, improved acoustic performance and adequate levels of daylight; ● Creation of a safe and inclusive community through provision of a wide range of jobs; and ● Creation of high-quality buildings and public realm that meet the WELL Building standards and offer natural sociability, interaction and access to nature. Great Places 2.38 Greater Cambridge has a track record as a place where contemporary design and the historic environment co-exist in harmony. A key issue for Land to the north of Station Road will be how to balance heritage with the demands of growth. 2.39 The Site is located within the New Town and Glisson Road Common Conservation Area. 2.40 None of the buildings within the Site are listed, however they are all identified as ‘Buildings of Local Interest’ (51-53 Hills Road and the Station Mews are excluded from this list). In addition, they are identified as ‘Buildings of Positive Townscape Value’ in the New Town and Glisson Road Conservation Area Character Appraisal (2012), (51-53 Hills Road and the Station Mews are excluded from this list). As such, the existing buildings are considered to be “non-designated heritage assets”. 2.41 In light of the above, the College recognise that it is important to understand the relative merits of the existing buildings and land in the context of these designations and the relevant legislation and policy framework. The College have therefore has prepared an Initial Significance Assessment to understand the historic interest of the existing properties, attached. The Assessment concludes the following: ● The villas are ‘non-designated assets’ in their own right, and are therefore subject to the provisions of the NPPF; ● The villas contribute positively to the character and appearance of the Conservation Area (a designated heritage asset) and are therefore subject to the provisions of the NPPF; ● As a group, and in their contribution to the Conservation Area, the Villas hold a value ranging from moderate to good (although some buildings individually have a lower level of value as a result of lower original quality and adaptations to them); and ● The site could however accommodate some form of development within its heritage context and indeed a number of benefits to the character and appearance of the Conservation Area could be secured through any future redevelopment. 2.42 In the case of designated heritage assets (such as Conservation Areas and listed buildings), paragraph 193 of the National Planning Policy Framework (NPPF) explains that, “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation”. In the event that “less than substantial harm” would be caused, the policy requires this harm to be clearly outweighed by public benefits. In the event that substantial harm is caused, this level of harm should be “exceptional and could only be outweighed by substantial public benefits.” 2.43 In the case of non-designated heritage assets (such as locally listed buildings or buildings of positive merit) Paragraph 197 of the NPPF requires a Local Planning Authority to make a “balanced judgement” having regard to the scale of any harm or loss of the heritage asset. 2.44 Ultimately, a balanced judgement would be required for any redevelopment proposals in terms of the impact on the significance of designated and non-designated heritage assets and the public benefits arising. The Site has the potential to deliver significant public benefits, as outlined below: ● The opportunity to deliver high quality B1a (office) accommodation in a Core City District and in a sustainable travel location close to central Cambridge railway station; ● Supporting the local economy and community through expansion of an established R&D and AI Cluster and associated supply chains; inclusive growth that considers the needs of vulnerable groups; can compete on the international office market; and takes a large step toward to meeting regional growth targets; ● Supporting economic growth in a manner that promotes health and wellbeing for employees and the wider community through; - high quality architecture and passive design measures which lower the cooling requirement and have shorter lifecycles, such as solar shading and high fabric performance; - significant improvements to public realm along Station Road frontage; - opportunities to travel sustainably and helping to tackle air pollution, as well as bring physical benefits; ● Improvements to flood resilience through removal of large areas of hardstanding and incorporation of a range of future climate scenarios that better manage the water runoff into the wider city drainage system. Specifically, there is opportunity to explore the integration of measures such as green or blue roofs and sustainable drainage systems; ● Green infrastructure to offer greater resilience to a warmer and drier climate than currently exists, to provide a 10% net biodiversity gain in ecosystem habitats and to provide broader ecosystem services such as forming part of a sustainable drainage system; ● Helping to maximise the benefits arising from major investment in a key public transport corridor associated with sustainable transport and active travel; and ● A landowner who wishes to work the community in order to shape a proposal which meets the needs of and can provide wider benefits to the area. The Emerging Concept Proposals 2.45 The supporting Vision Document includes three potential scenarios for the site to represent the wide-reaching opportunities that the site offers; ● Scenario A – Do nothing (the existing accommodation extends to circa 3,500m2, including outbuildings); ● Scenario B – Retention of Salisbury Villas with development to the rear, potentially linked to the Villas (a total net floor space of circa 16,000m2 could potentially be delivered plus public realm improvements along Station Road); and ● Scenario C – Demolition and redevelopment of Salisbury Villas (a total net floor space of circa 24,000m2 could potentially be delivered plus public realm improvements along Station Road). 2.46 The three scenarios have been assessed within the context of the four ‘big themes’ of the consultation document. The detailed scenarios assessment is included in the Vision Document but for reference a summary is included below. Scenario A: Do nothing 2.47 This scenario represents the status quo. The existing tenants would remain in place, essential repairs to the buildings would continue to be carried out, and the existing hard-standing and car parking would remain. 2.48 However, this also means that none of the potential benefits of redevelopment and the associated investment could be realised: no new floor space would be created for businesses to grow, no additional jobs would be delivered, the public realm would not be revitalised, no new trees would be planted or biodiversity gains implemented, no social value opportunities initiated and the existing villas would remain carbon-intensive and in need of rejuvenation. 2.49 Ultimately, this scenario would provide little opportunity for the Site to contribute to the four big themes and to ‘do nothing’ would represent a significant missed opportunity. Scenario B: Retention of Salisbury Villas with new development to the rear 2.50 This scenario retains and refurbishes the villas, including removing the unsightly outbuildings in the rear gardens. Several of the gardens could be joined to form larger development plots. 2.51 A group of three larger buildings, likely commercial in use, are proposed to the rear of the villas as free-standing buildings. These new buildings are envisaged to be connected to the existing villas through linking elements, but they could also remain separate from the villas with their own access. These linking elements might accommodate stair cores and lifts, and are inserted either side of glazed atriums that provide light and ventilation. Placing the cores in this arrangement creates large and efficient rectangular floor plates with no interruptions. 2.52 The existing villas can be refurbished to comprise reception rooms, meeting rooms, break out spaces, executive offices and other supporting facilities. New deeper basements can also be considered to maximise area. 2.53 The buildings will most likely require some level of articulation and stepping, to mitigate potential overlooking and overshadowing towards the north. Some stepping may also be required along the west boundary towards the houses at Claremont Gardens. 2.54 This Option clearly provides a greater range of benefits when compared to scenario A, in terms of creating a range of new jobs, boosting the local economy and spearheading the move to a net zero-carbon society. Scenario C: Demolition and redevelopment of Salisbury Villas 2.55 This scenario envisages the complete demolition of the villas and their boundary walls in order to create larger development plots for a series of new buildings with efficient and modern floorplates. 2.56 In this scenario, there is an opportunity to move the building line slightly further forward closer to the road, while still retaining the avenue of lime trees and the potential for generous public realm improvements. 2.57 This option delivers the most floor space overall, and has scope for adding greater height to the new buildings along the Station Road frontage as well as notable benefits through the construction of modern, purpose-built commercial floorspace built to the highest environmental standards to create the largest opportunity for new jobs in a highly-accessible location. Summary 2.58 The site represents an opportunity to provide a commercial-led scheme in a highly accessible location; a location that has a proved track-record to attract high calibre businesses. A high-tech AI (Artificial Intelligence) cluster has already formed in the adjacent new commercial buildings; attracted by their modern, efficient floorspace all group together to revel in the wellevidenced benefits of clustering. 2.59 The site is the last piece of Station Road that does not have a long-term Vision for how it should respond to Area of Major Change Policy and the major development changes that are occurring to the Station Area. The site is an underused asset in one of the most accessible and sustainable locations in Greater Cambridge and it is appropriate for the emerging Local Plan to include the site for commercial development. A suite of supporting documents accompany this representation, including a Vision Document to set out an understanding of the existing site and to present three development scenarios that represent the wide-ranging opportunities that the site offers; from a do-nothing scenario to a full redevelopment. Each scenario has its pros and cons, but the greater the development, the greater the benefits for job creation and forming sustainable development. 2.60 The full redevelopment offers the greatest opportunity to achieve the lowest carbon intensity; the lowest carbon per employee on site. 2.61 The Council has recognised the climate emergency and aspires to move to a net zero carbon society. To achieve this, it cannot repeat the pattern of historic decisions and previous planning priorities. It must make some strong choices to prioritise those developments that can maximise long-term sustainable benefits; to so this there will be impacts to other planning matters, not all matters can be prioritised. 2.62 The development potential held by the Site offers the opportunity to achieve a number of significant benefits: ● To reduce the carbon intensity four-fold of the site per employee (CO2e/FTE) as CO2e/FTE from 0.75 for the existing building down to 0.18 through a modern redevelopment; ● To increase the GVA contribution from circa £9 million from the existing buildings to £85 million from a full redevelopment; ● To increase the number of jobs (full time equivalent) from 170 jobs to 1,800 jobs ● To achieve significant public realm benefits to Station Road – including major enhancements for pedestrians and cyclists as a major thorough-fare to Cambridge Station; ● To increase the amount of public open space facing Station Road, from what is currently a completely private and walled site; ● To reduce car parking in a city centre location; ● To deliver bespoke high-quality architecture; a landowner that wishes to engage with stakeholders and provide architecture that will be a legacy to be proud of; and ● To deliver 10% net biodiversity gain.

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Set against our responses to the question above, and our clear identification that the emerging plan must distribute a challenging housing requirement across a wide range of Greater Cambridge’s most sustainable settlements, we are pleased to reiterate the availability and suitability of our client’s site for a well-proportioned residential development in Gamlingay. Paragraph 78 of the NPPF is an important policy which promotes sustainable development in villages. Whilst there is an expectation that villages will need to grow, the greatest level of growth should be focussed on the most sustainable settlements, as mentioned above, Gamlingay will shortly be enhanced in this respect, especially with the EW rail line. Gamlingay Parish Council is currently progressing its neighbourhood plan, towards which we have submitted our client’s land to be considered for development. Within the draft plan, there are two housing allocations on the Key Policy Plan: an allocated Local Plan Site GAM1 and land south of West Road for Housing Policy GAM2. However, an application for mixed use development including 90 homes has been approved (Application Ref. S/2068/15/OL) and an application for reserved matters is currently out for consultation for GAM1 site. Along with this, an application for 29 dwellings has been approved (Application Ref. S/2367/16/OL) for the site at GAM2. Consequently, the two sites allocated for housing already already have permission prior to the neighbourhood plans adoption and will already be counted towards both the village and district’s housing land supply. Despite these permissions a clear housing need at what is a sustainable and popular village continues to exist. The Greater Cambridge Local Plan must therefore allocate additional appropriate sites for residential development in Gamlingay to ensure that opportunities are secured to situate development in sustainable locations across the plan area – this would include at Gamlingay. As such, our client’s land North of West Road/adjacent to Dennis Green, Gamlingay as identified on the map below represents an ideal opportunity for future residential development for approximately 10 dwellings.

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Thank you for the opportunity to comment on the first stage of the new Greater Cambridge Local Plan for Cambridge and South Cambridgeshire. This is a jointly agreed officer response on behalf of East Hertfordshire, North Hertfordshire, Stevenage and Welwyn Hatfield councils (NE Herts). It is to be read alongside any individual responses submitted by these authorities. The NE Herts authorities have recently been planning to the early 2030s. These Plans are either recently adopted (East Herts and Stevenage) or at an advanced stage of examination (North Herts and Welwyn Hatfield). Under current Government requirements, Plans in this area will need to be reviewed by the mid-2020s to roll forward their current time horizons. The NE Herts authorities secured funding from MHCLG in 2018 to begin progressing joint working on planning. We are also considering, with other authorities in Hertfordshire and beyond, how best to respond to the challenges of future growth and plan-making. This includes exploring the potential for joint plans in response to the increased emphasis on strategic planning matters in the revised National Planning Policy Framework. Your consultation document clearly sets out the options for the area in the coming years. We note that it is envisaged that the Greater Cambridge Local Plan will plan for development up to 2041. At this stage, the NE Herts authorities do not wish to make any detailed, collective comments about the options that have been put forward in the current consultation document. However, the NE Herts authorities have not yet started planning for development in the period up to 2041 and it may be that cross boundary issues will emerge in planning for development post-2031 for the NE Herts authorities (or any other joint Hertfordshire geography) and Greater Cambridge areas. The current round of plans in north-east Hertfordshire have required challenging decisions about the expansion of the area’s towns and villages. At least some of our authorities are likely to be constrained in their ability to meet future development needs beyond the early 2030s. The NE Herts authorities would therefore welcome further discussions about potential, longer- term cross boundary issues as the Greater Cambridge Local Plan progresses and there is greater clarity on any emerging arrangements for future planning in our own area(s). If you would like to discuss any of the issues raised in this letter in more detail, please contact me using the details provided below.

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Greater Cambridge Local Plan response by the Federation of Cambridge Residents Associations http://fecra.org.uk/ Today, almost 100 resident associations and community groups are part of the FeCRA network, a grassroots civic voice for everyone in Cambridge — and also for its environment. Residents want a say in shaping Cambridge, to ensure that it develops in a way that will achieve balanced communities and quality of life. This response to the Greater Cambridge Local Plan focuses on concerns shared with us by our members and presented at the Local Plan Big Debate.

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The Big Themes All four key issues are important, but residents tell us they want to see the climate and biodiversity emergencies recognised as a priority for the Plan. There is concern about the lack of vision, and what appears to be a piecemeal and growth-driven, interest-led, approach, which lacks coherence and strategy and appears to pay only lip service to the acknowledged need to address the biodiversity and climate emergencies.

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Setting limits – level of growth In this context, ‘how much development can be sustained’ is not the right question, and neither is ‘how much building is needed?’ The right way forward is to assess the impacts and issues arising from current and already approved growth. Without this evidence it is impossible to identify the key issues or parameters that would make future development sustainable. The current work on evidence for the Local Plan considers only housing growth. It should address environmental capacity, the impact of transport proposals, current growth ambitions, the need to address climate change, and Cambridge’s historic environment, before credible issues and options can be identified. The implications of possible projected growth are not made clear in the consultation, making it difficult for residents to understand the different options and the impact they may have. They would like to have information and transparency about the full projections of the total homes mandated by the government, and those that are planned or already approved. Without this information the consultation is flawed - how is it possible for people to engage with the Plan in any meaningful way? Many residents tell us they are concerned about the unquestioned assumption in the explanatory document that the current fast rate of growth will continue or even accelerate. They say that the very qualities of life and environment that have made Cambridge unique don’t scale and ever- increasing growth will make the city a victim of its own success. The benefits of rapid growth for a small city are unproven, the costs are obvious. The pressures on the quality of life in the city centre, including the impact of mass tourism and the water crisis require restraint rather than increasing the level of growth within the plan area.

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Housing and quality of development Residents say the Plan should be about creating communities and streets, not high rises or Trump Towers and should also support biodiversity and wildlife corridors. The back gardens of the city’s houses are important wildlife corridors and this does not correlate with strategies in this consultation calling for densification. Plans for new housing should reflect the needs of a mixed community not just new workers and promote integration, particularly of older people and a range of income groups, through a mix of tenures and housing types which avoids ghettoisation. The Council’s commitment to policies on addressing the climate emergency requires action now to set standards of building insulation, heating/cooling, water recyling, permeable surfaces - 2040 is too late and interim targets need to be set to meet the scientifically agreed minimum reduction in carbon emissions of 50% by 2030. Any meaningful measure must also include the carbon embedded in building material and emitted during construction. All new developments should have the highest standards of water efficiency to mininimise the use of water abstracted from the chalk aquifer, including use of rainwater and grey-water recycling. Large new developments should incorporate permeable paving and urban drainage systems to help water percolate back into the soil. Opportunites for tree planting should be maximised within new developments and development should be designed to respect the value of trees, hedges and grass meadowland as valuable habitats and important for biodiversity. The next Local Plan must must include a Historic Enviroment Strategy as required in the National Planning Policy Framework to ensure we retain the essential character of our streets, public spaces and green infrastucture. There should be no more new hotels/apartments for tourists, and a management strategy should be put in place which recognises that there are significant constraints in a small historic city on the number of visitors that can be assimilated without harm.

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Employment and business growth New office developments should be permitted only if a real employment need can be demonstrated. There is no clear evidence for a strategy of intensification of population growth within or close to Cambridge itself instead of dispersal of growth to surrounding small towns that already have good transport links. Market towns on train lines near Cambridge could be attractive centres for knowledge workers and tech businesses. They have identities, a sense of place and character, and could benefit from investment. The CPIER report gave no systematic evidence in favour of doubling the population of Cambridge without commensurate expansion of infrastructure. There was simply an assertion that tech firms will leave the UK if they cannot be located within or close to Cambridge. However, there appears to be no research evidence for this other than that proximity used to be a benefit to businesses in the early days of the Cambridge Phenomenon. Academics with expertise in this area question if there is current evidence to support the assertion that tech firms would leave if they cannot be crowded into Cambridge. They say that tech businesses are now spread throughout the region, from Ely to Royston, Newmarket to St Ives and should be supported and that Cambridge should be building on shared connectivity, sharing and spreading prosperity whilst maintaining the city’s ingredients of success. They question to what extent the evidence provided for the CPIER strategy has been tested or even peer reviewed. This is important given the concerns already raised with the planning service about the conflicted role of the economic consultancy SQW ( Segal Quince & Wicksteed) in assessing the evidence base for the CPIER strategy. Senior academics also question how much growth it is realistic to plan for beyond what is already envisaged in the existing local plan. In particular, they ask how far can office development and the growth of tourism be contained at a level where economic, social and environmental well-being isn’t prejudiced. Many residents believe that limit has already been reached.

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The river and open spaces The Plan should recognise the need to maintain and improve open spaces, and create new ones, with clear plans to maintain them. Strategies about open spaces should be drawn up in open consultation with local residents, river and community groups and councillors and not drawn up in private by groups or “experts”. Local knowledge and accountability is vital and people want to have input on what they value at an early stage, not be presented with an already decided set of options. The Thames Landscape strategy is a model of how to develop plans in a way that fully engages and works with the local community. This is important as some of those involved in drawing up plans for “doubling nature” and parks or doing deals with college landowners, water companies and developers and site assessment may depend on funding or donations from patrons with business interests. They may benefit from “natural capital” offsetting or from managing schemes prioritisised for investment and from commercialisation of the city’s open spaces and its nature. Plans for open spaces should not be handed down as “sprung plans” or seek to commercialise open spaces such as the river corridor, nature reserves or common land as “destination opportunities”. Plans need to recognise that the unique semi-rural informal qualities of Cambridge’s historic open spaces and its nature including the river are admired and valued all over the world and support a landscape strategy and management structures that reflect this, rather than softening up the city’s precious green spaces and its green belt for commercialisation or development as is said to have happened with the Lee Valley Authority. Despite the recent heavy rain the Cam is the only river in the country that is not back to normal flows, yet exponential growth fuels huge pressure upon our natural water supplies. Concerns about the impact of over-abstraction on the River Cam have been expressed but despite that major schemes continue to be approved. We support the view of Cam Valley Forum that no further development should be allowed which: • adversely affects the chemical or biological condition, or the temperature of the river’s waters. • adversely affects the river and its tributaries, its sustaining aquifers, land liable to flood, and river-side green spaces. • adversely affects any nature reserve, woodland and semi-natural open space. • erodes the areas of best landscape, from the south-east to south side of the city and in particular the views from Magog Trust and there should be no further development on the green space between the Biomedical Campus and Nine Wells Nature Reserve. Prioritisation of a Gogs landscape up to the Magog Trust Land would also maintain the important views from this key approach to the city. Recreational access to this area of farmland would be of benefit to the community, and also to the landowner via the ‘public good’ definition in the Agriculture Bill.

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Consultation and engagement The issues and options which will be identified through this Plan process will have a huge impact on the lives of local people, yet it has not been made easy for them to participate. The only first stage ‘issues and options’ workshop for representatives of Resident Associations was held at short notice at the start of the summer holidays in Shelford, a poor location for city residents. Very few were able to attend, and the majority of those present (over 80%) were from South Cambs Parish Councils. There are numerous on-going consultations on transport and planning issues including several key Supplementary Planning Documents (SPDs). People feel overwhelmed, and are confused about the way all of these consultations impact on each other - there seems no overall strategy or attempt to link them together. They are all dealing with complex issues and often presented in dense, technical documents which are difficult for busy councillors to assimilate and engage with, and often completely impenetrable to ordinary residents. This raises questions of transparency and democratic accountability. Residents’ feedback on the Plan consultation document is that the numerous questions seem daunting and contradictory – the focus on growth does not seem compatible with the stated themes of climate change, biodiversity, well-being and inclusion. Many people, including Cambridge academics, told us that they just gave up. One group provided a primer for members, which has been widely circulated. There are widespread concerns about engagement and stakeholder feedback. We have already raised issues about the consultation process with the planning service, Deputy City Council Leader and Executive Councillor for Planning, including the fact that there seem to be many private meetings convened by non-statutory interest groups which involve officers, councillors and NGOs on key aspects of the Local Plan, including growth, water, housing, natural capital and the call for green sites. The minutes of these are not easily available for public scrutiny, and the remit of these groups Is not always transparent - there are therefore concerns that strategic decisions are being influenced by those who have a vested interest and benefit financially. Some of those involved in the plan evidence gathering have been members of the groups who have worked on the CPIER growth agenda and/or are plan consultees working with and/or receiving funding from those promoting the growth strategy for densification, transport corridors and green belt development. The conflicts of interest regarding evidence gathering by those with vested interests, including business groups, NGOs, transport groups and the university, will need to be managed in a way that is rigorous and transparent to ensure confidence in the data and information on which decisions will be made. On individual planning applications, real stakeholder engagement at an early stage should be mandatory. No major development should be permitted unless the developer can show that it has done a complete stakeholder analysis and then has engaged with all identified local interests before submitting a planning application. To aid transparency, a record of all discussions, formal or informal, between Councillors/ Officers , developers, NGOs and transport and residents groups about planning proposals should be kept and made publicly available on the City Council’s website. Conflicts of interest and donor funding need to be declared in all cases. These measures do not need to wait for the new Local Plan to be adopted; they could be implemented now.

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Thank you for consulting Suffolk County Council (CC) on the Greater Cambridge Local Plan Issues and Options. As a neighbouring authority Suffolk CC is willing to work jointly on addressing strategic, cross boundary issues. In Suffolk, these issues are mainly relevant to West Suffolk, with West Suffolk Council being in the process of developing the first local plan as this authority, however issues across the Suffolk may be relevant. Joint working would be welcome between Suffolk CC, Cambridge City Council, South Cambridge District Council, Cambridgeshire CC and West Suffolk Council as both plans develop. The focus placed on sustainable modes of transport within the Issues and Options document is welcome. The Suffolk CC is supportive of increasing uptake in sustainable modes of travel. The commitment to developing plans for the Cambridge Autonomous Metro (CAM) is noted. If this is to progress, as the aspirations for this system is to extend to Haverhill and Mildenhall, close working will need to take place between all relevant authorities in ensuring this project can integrate well with growth in current and future local plans. the CAM will likely have implications for the emerging West Suffolk Local Plan and the Suffolk Local Transport Plan (currently under review), which will need to be fully explored. Highlighting the improvements to rail infrastructure between Newmarket and Cambridge is welcome, however there are planned improvements to the rail network beyond Newmarket, including better rail connections between Cambridge and Bury St Edmunds and Ipswich. While Suffolk CC supports the focus on sustainable transport, there needs to be consideration of the Strategic Road network and the Major Road Network. Impacts on the A14, A11 and A1307 will need to be addressed. The A14 is an important link to Ipswich and Felixstowe, which is one of the UK’s largest container ports, making the A14 a nationally important route. Junction 37 of the A14 experiences high levels of congestions, though it has received some recent improvements. Suffolk CC is still waiting to hear whether or not Junction 37 (amongst other potential projects) will be funded through the Road Investment Infrastructure Strategy 2. I hope that these comments are helpful. Suffolk CC is always willing to discuss issues or queries you may have. The county council is willing to discuss anything raised in this response.

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I have recently attended several meetings arranged by prospective builders/developers in the Stapleford. Area. It is very clear that they are are not talking to each other as their plans overlap the same plots of land. Also the various councils are not engaging with them because no planning applications have been submitted. The problem residents have are that your high level plans are so vague and broad brush that these developers can drive a bulldoxer through them. Most of the residents of Stapleford are tired of the constant attack on the green belt. Your strategic plan SHOULD be forcing developers to utilies brown land before carving up the countryside.

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The Greater Cambridge Local Plan will shape how Cambridge and South Cambridgeshire changes over the period to 2040, and possibly beyond. The Issues and Options 2020 Consultation enables the first conversation and explores big themes that will influence how homes, jobs and infrastructure are planned. One of the big themes outlined in the Local Plan Issues and Options 2020 is climate change and achieving net zero carbon is an important consideration in the preparation of the Local Plan. The Land off Brockholt Road, Caxton was put forward as part of the Greater Cambridge Local Plan Call for Sites undertaken in Spring 2019 and provides an opportunity to create a well located extension to Caxton with efficiently designed homes. The site can accommodate tree planting which will also create biodiversity net gain another important big theme. The development of Land off Brockholt Lane, Caxton will enable homes and enhance the setting of the village through much needed housing providing environmental and social benefits. As set out in the Issues and Options 2020 consultation 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. 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 Local Plan should provide a range of housing sites, both small and large scale to enable flexibility and competition in the market. As set out in paragraph 68 of the National Planning Policy Framework 2019 small and medium sites such as Land off Brockholt Road, Caxton will make an important contribution to meeting the housing requirement of the area and can be built out quickly. There is significant demand for housing within Caxton given its proximity to Cambourne and Cambridge. The National Planning Policy Framework 2019 sets out in paragraph 78 that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a nearby villages. The land off Brockholt Road, Caxton is ideally placed in relation to Caxton and the transportation corridors. Caxton’s proximity to Cambourne lends itself to be a highly sustainable location for future growth in Cambridgeshire. The terminus of the proposed busway will be located in Cambourne and the Cambridgeshire Autonomous Metro (CAM) will be through Cambourne and beyond towards St Neots. The Greater Cambridge Partnership (GCP) has indicated that the proposed Cambridge-Cambourne busway could be completed as soon as 2024, making it a key consideration in determining where future growth should be located. The Greater Cambridge Local Plan should help to meet its housing need by having a combination of large and small sites as well as along transport corridors. Therefore, dispersal through new settlements, villages and transport corridors would be appropriate locations to develop housing and this site would be key to achieving this aim and enable sustainable development in accordance with paragraph 8 of the National Planning Policy Framework 2019.

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In line with the Garden Walk Residents Association constitution which is focussed on improving the environmental amenity of the street for residents, and as Secretary of GWRA, I am writing a short note to request that in your deliveberations you look to reduce vehicular traffic impacts and enhance the local environment for pedestrian and bicycle use. GWRA is keen to tackle the adverse risks and environmental impacts caused by: speeding vehicles, vehicles 'rat-running' down the street as a short cut to Victoria Road (quicker than Stretten Avenue as no traffic lights or speed humps on Garden Walk), air pollution, noise; and is interested in being part of a local area 'Home Zone' in which our local streets become places where pedestrians have priority. Please can you consider this as part of your work, thank you.

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Response to Question 2 - ADDITIONAL INFORMATION The landowner has submitted a proposed site option for Land off Cambridge Road, Great Shelford at the 2019 Call for Sites stage. However further work has been done on the relative sustainability of the site (attached technical note by TPA). The preferred route of the East West Rail Link has also now been identified, including a potential new rail station at Cambridge South. 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.

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Response to Question 2 - ADDITIONAL INFORMATION Land off Swan Lane Guilden Morden was submitted under the 2019 Call for Sites consultation. The site remains available, suitable and deliverable for residential development. The site lies outside the Green Belt and there are no known technical constraints to delivery. Residential development of the site would provide new affordable and market housing for Guilden Morden, which will help support the vitality of the village. The development also provides opportunities to create new publicly accessible green open space and enhance the ecological value of the site.

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Response to Question 2 - Additional Information E W Pepper Ltd own circa 1.4 hectares of land to the south-west of Ermine Way, Arrington. The site was submitted under the 2019 Call for Sites and remains available, suitable and deliverable for up to 21 dwellings. The site is non-Green Belt and comprises in-part previously developed land. There are no technical constraints to the delivery of residential development on the site.

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EW Pepper own c. 6ha of land to the east of Old North Road, Kneesworth. The site was submitted under the 2019 Call for Sites and remains available, suitable and deliverable for residential development of up to 142 dwellings. The proposed development would provide new affordable housing and market housing to meet local housing local needs. It would also offer the opportunity to create new public open space in the village and enhance the ecological value of the site to achieve a net gain in biodiversity. In addition, it will bring new residents into the village which will help to support the vitality of local infrastructure, including shops, public transport, schools etc.

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Land to the west of Brook End, Steeple Morden was submitted under the 2019 Call for Sites consultation. The site remains available, suitable and deliverable for residential development. The site lies outside the Green Belt and there are no known technical constraints to delivery. Residential development of the site would provide new affordable and market housing for Steeple Morden, which will help support the vitality of the village. The development also provides opportunities to create new publicly accessible green open space and enhance the ecological value of the site

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Response to Question 2 - Additional Information Land South of Milton Road, Impington was promoted to the call for sites process in March 2019 for the proposed development of up to 50 dwellings, including affordable dwellings, and a community park (4.8ha) to provide recreation and leisure facilities. The site is located on the north eastern edge of the village of Impington and currently comprises agricultural land. Existing residential development is located to the south of the site along St Andrews Way. The remainder of the site’s southern boundary is formed by an existing field boundary. An existing residential dwelling also borders the site to the east. The remainder of this site boundary is also formed by an existing field boundary. The northern and western site boundaries are defined by Milton Road. The site is currently located within the Green Belt. It is considered that exceptional circumstances exist to justify the release of land from the Green Belt, which are related to the need for housing and affordable housing in Cambridge and South Cambridgeshire and the deficit that there is in open space provision with Histon and Impington. It is also considered that the development at the site would have no adverse impact on the compactness or setting of Cambridge and it would not lead to merging of villages, as such, the site makes a limited contribution to the purposes for including land within the Green Belt. The adopted development strategy seeks to direct development to locations in the following order of preference: sites on the edge of Cambridge; within new settlements; at Rural Centres; and at Minor Rural Centres. Histon and Impington are designated as a Rural Centre. The villages of Histon and Impington extend to the south west of the site and have a number of facilities and services including schools, doctor’s surgeries, sports centre, shops, pubs, restaurants and a post office. Histon and Impington are connected to Cambridge and Ely by a frequent bus service, and are also on a cycle route into Cambridge. The site is promoted by a developer, Flagship Housing Group, who has previously submitted and withdrawn a planning application for the proposed development. All necessary technical surveys have been completed and formed part of the application submission. Flagship are a Housing Association (registered charity) and provide homes for affordable and market rent, and for sale, across the East of England. They maintain their own housing stock and support the communities which they are part of. Flagship have approximately 28,000 homes (335 of which are in South Cambridgeshire with more currently being built at Papworth Everard and Cambourne), 1,045 employees (including 18 apprenticeships), and achieve a customer satisfaction rate of 90%. Flagship’s purpose is to provide homes for people in need and the proposed development of Land South of Milton Road, Impington will be key to contributing to this purpose.

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I realise I have missed the deadline to feed back on the Local Plan website but we discussed the following issues for the Local Plan on February 20th at our Coldhams Lane Residents Association: -Liaising with Cam-cycle to improve coordination of green development in the area. -The Romsey Lakes, as an area of natural beauty that should be opened up to the public. -Steer development plans away from simply allowing more and more traffic down CL. -Better bus service Could all this be added?

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Response to Question 2 - Additional Information 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. The site at land south of Shepreth Road in Foxton was promoted through call for sites process in March 2019 on behalf of Turnwood Heritage Ltd. The representations to the Issues & Options consultation document will refer to that promoted site where relevant.

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This is more about the underpinning CPIER Report as quoted in the LDP Consulation so any response would be welcomed. a) What are the units if the vertical axis in Fig 2 , they can't be percentage as given in the title. b) Does the GC team think that Fig 13, although clearly stated to be based on number of resdidents (a good dataset) may overstate the productivity of Cambridge cf the others since the City has a much higher net inbound number of workers. For example If Cambridge GVA is spread over residents plus 20% net commuters ie take 80%of GVA/resident, Cambridge falls much closer to the others.

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I would like to thank you for the opportunity to engage in the development of the next Local Plan for Greater Cambridge. Cambridge Ahead has responded to the recommendations made by the Cambridgeshire and Peterborough Independent Economic Review, and has undertaken a significant amount of further analysis to put forward this input, which is based on the broad recommendation made in the Review on the future spatial development of the Cambridge sub-region. Cambridge Ahead has welcomed the chance to test and discuss this with you, while at the same time we have been developing our proposals with our membership. This presentation now represents the consolidated view of Cambridge Ahead’s membership, having been approved by the Policy Group, our individual project groups and by the Board. Our input is titled a Suggestive Spatial Vision: A Catalyst for Conversation, which describes clearly how we intend this to be used. We have purposely not sought to develop a draft plan, but we have developed visioning material which we hope will help to form your considerations around the main strategic spatial choices. This material is supported by significant data and modelling, to demonstrate that the vision is robust and deliverable, and to give an indication of what such a vision could deliver in terms of sustainable, high economic growth. To capture succinctly our views, we propose the Local Plan should consider: • Densification of five strategic employment sites, most around the fringes of the city, supported by strong public transport connectivity; • The extension of the critical technology clusters along nine existing, but uprated transport corridors into the wider sub-region; and • The provision of new large green spaces, rich in biodiversity, to provide future nature parks for the enlarged city. We believe that this blend of strategic spatial choices will unlock high-value jobs, spread Cambridge clusters outwards across a wider footprint without losing their dynamism, support major shifts towards sustainable travel, improve the environment and sustain the quality of life for local people. As you know from our work with you at a technical level, we also believe that it is fundamentally important that the Plan is based upon robust estimates of future employment rates, regularly monitored to keep track of the realities of the local economy. In that regard, I am pleased to share with you, on an embargoed basis, the latest draft Cambridge and South Cambs data on Cambridge companies’ employment growth in the year to April 2019. This is different from the ONS’ BRES data for the same areas, notably showing an acceleration of employment growth despite the uncertainties of the Brexit debates. We will publish the final CPIER data for the two districts and GCP, plus the Combined CBR/BRES data, shortly and thereafter annually to support regular revisions to the Local Plan. This will allow regular updates of Slide 5 of the presentation. We recognise that the material appended to this letter is more than has been sought at the Issues and Options stage of the Local Plan consultation, but it has already been the subject of our discussions to date and we believe this now represents the best opportunity for us formally to share it with you for input into the Local Plan. We look forward to continuing to work closely with you and your colleagues.

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Response to Question 2 - ADDITIONAL INFORMATION 3.1 The Site was submitted as part of the Call for Sites consultation in 2019 and Axis are continuing to promote the Site for allocation in the Local Plan. This submission comprises additional information clearly demonstrating the Site’s suitability and deliverability for residential development early in the plan period. 3.2 The Site is not in the Green Belt, it is on the edge of the settlement and currently lies outside of the existing development framework. A residential allocation is sought through the emerging new Local Plan. The Site offers the potential to create a high quality and sustainable residential development for Swavesey though the provision of approximately 70 market and affordable new homes. Axis is seeking to develop approximately 3.3ha of land. 3.3 Our accompanying Vision Document provides detail on the key principles for our proposed development. The approach has been to retain and enhance existing natural features including woodland, the pond and watercourse for the benefit of flora and fauna. The retention of trees and hedgerows provides mature planting with aesthetic value that helps to mitigate the visual impact of the development. 3.4 Unique to this Site is the opportunity for the existing landscape features to create new public open space and consolidate the character of the proposed development. New houses will front into the new public open space created for the new and existing community. 3.5 Rural gaps and views identified in the Swavesey Village Design Guide can be retained and enhanced. In doing so, these connections with the open countryside will help to maintain the rural character of the village. 3.6 The Site also offers the opportunity to provide a landscape corridor connecting landscape assets. These landscape corridors provide conduits for local wildlife and safe and attractive routes for pedestrians and cyclists. The landscape corridors connect the existing pond and woodland to the wider landscape and provide an attractive outlook for new homes, in doing so, addressing one of the priorities for Swavesey Village Design Guide 3.7 The Site has the ability to provide up to 70 new market and affordable homes which will help address the local housing need with a range of housing types. 3.8 The principles can be summarised as follows: ● Achieve 35 dph which equates to approximately 70 new dwellings (Inc. affordable housing); ● Retain and enhance existing natural features including woodland, the pond and watercourse for the benefit of flora and fauna; ● Retention of trees and hedgerows provides mature planting with aesthetic value that helps to mitigate the visual impact of future development; ● Creation of homes that are in keeping with the historic architectural character of Swavesey; ● Rural gaps and views identified to be retained and enhanced providing connections with the open countryside helping to maintain the rural character of the village (key requirement of the Swavesey Village Design Guide); and, ● Provision of green infrastructure to encourage ecological corridors and increase bio-diversity. Benefits to be delivered by the proposals 3.9 The Site has the potential to deliver sustainable development in accordance with the three dimensions of sustainable development identified at paragraph 7 of the NPPF, whilst also securing a number of benefits to both Swavesey and the wider Greater Cambridge area, including the following: Economic Benefits ● New jobs will be created through the construction phase of the development, both directly and through supply chains; ● New residents will help to sustain existing shops, services and facilities within Swavesey due to higher footfall and patronage once the development is occupied, reinforcing the role of Swavesey as ‘District Centres’; ● Unlike a series of smaller scale developments, a Site of this size is likely to generate Section 106 contributions towards improving local infrastructure; ● Additional revenue will be generated through the New Homes Bonus. Social Benefits ● The potential to deliver approximately 70 market and affordable new homes to assist Greater Cambridge in meeting their objectively assessed housing needs; ● The potential to deliver a range of dwelling size, type and tenure to meet locally identified housing need and creating a mixed and sustainable community; ● The Site is well connected in terms of public transport, with direct access to a range of locations and their associated services and facilities; ● There is potential to create a high quality accessible open space. The provision of such a large area of open space is unlikely to be feasible on smaller scale or constrained brownfield sites; ● There is potential to deliver play facilities on the Site to meet an identified local need. Again, the provision of play facilities is unlikely to be feasible on smaller scale or constrained brownfield sites.; Environmental Benefits ● The Site is well located to promote pedestrian, cycle and public transport trips, thus reducing carbon emissions; ● A sensitive design approach can be achieved which ensures that development will not encroach into areas at risk from flooding; ● The majority of the existing tree and hedgerow planting around the periphery of the Site and along the internal field boundary can be retained; ● Significant additional tree planting can be incorporated throughout the Site. This will also contribute towards biodiversity enhancements. Responding to the four key themes 3.10 The development Site would contribute to the four big themes as follows: ● Climate Change – new dwellings will be designed and constructed in a manner to be energy efficient and incorporate renewable technologies where appropriate. The site will also see an increase in tree planting that would act as a source of carbon capture and reduce the effect of climate change. The Site is also in a sustainable location, providing alternatives to private car use for residents to meet their daily needs; ● Biodiversity and Green Space – through the provision of on-site green infrastructure and retaining and enhancing vegetation this can create an ecological and recreational asset to be enjoyed by future and existing residents; ● Wellbeing and Social Inclusion – the Site would incorporate a mix of housing sizes, types and tenures, to help meet the needs of the District and local community. The proposals would also promote healthy lifestyles and wellbeing through the provision of on-site recreation and the Site’s accessibility to education, shops and public transport by active modes of travel such as walking, cycling or rollerblading; and ● Great Places – a landscape-led approach is central to the design and layout of the scheme, as shown in the Illustrative Masterplan which shows how the Site could come forward. Summary of Technical Assessments 3.11 A series of technical assessments have been prepared to demonstrate the deliverability of the Site, these reports should be read alongside this document. 3.12 A Preliminary Ecological Appraisal has been prepared by BSG Ecology and has informed the Illustrative Masterplan that has been prepared as part of the Vision Document. The report notes that the Site is dominated by grassland which is of a low ecological value and there are no designated sites of wildlife value within its boundary. Ecological value of the Site is limited to the woodland, hedgerow and pond habitats. 3.13 A high-level transport strategy has been prepared by Stantec and is submitted in support of this response. The strategy notes that the Site has good accessibility to key destinations by non-car modes, within footway provision through Swavesey providing non-car access to Swavesey Primary School, Swavesey Village College and a wide range of other local services and facilities that would meet many of the day-to-day needs of local residents. Most of the village is within a one mile walk of the Site, and there is also good non-car connection with the nearby Buckingway Business Park. 3.14 In the wider context, Highways England’s A14 improvement between Milton and Ellington is nearing completion. A new local access road will run parallel between the Swavesey junction at the Buckingway Business Park and Huntingdon Road in Cambridge. This will have a high-quality pedestrian and cycle route alongside it, which would be an extension of the existing shared footway / cycleway along Bucking Way Road, south of Swavesey. This means there would be a continuous shared footway / cycleway between the Site and key destinations including Bar Hill and its Business Park at about 3.4 miles, Eddington at about 7 miles, West Cambridge at about 8 miles and Cambridge City Centre at about 8.5 miles (travelling distances). These are reasonable distances for regular cyclists, therefore providing further opportunities for the development to promote non-car means of travel. 3.15 The Site is close to bus stops in Boxworth End which are served by the Citi 5 service about every 2 hours during weekdays, linking the Site with Bar Hill and Cambridge City Centre. The Site is also about 1.4 miles south of the Swavesey stop for the Cambridgeshire Guided Bus, which provides fast and frequent services to Cambridge Science Park and Cambridge City Centre, along with St Ives. The Site therefore has good public transport accessibility with Cambridge City Centre and the key employment location of the Cambridge Northern Fringe. 3.16 It is proposed that the Site be accessed by a new priority T-junction onto Boxworth End. A preliminary design of this access has been prepared in accordance with highways design guidance. 3.17 It is considered that the Site is deliverable, accords with national and local transport policy guidance, and that therefore there are no transport or highways reasons why Land East of Boxworth End, Swavesey should not be allocated for residential development in the Greater Cambridge Local Plan. 3.18 A drainage and flood risk assessment has informed the proposal. Drainage features have been designed to not only accommodate the 1 in 100 year plus climate change event but also assessed the impact if no discharge occurs in 14 days. Should the Site be allocated then further discussions and consultation with Lead Local Flood Authority (LLFA) will continue to refine the proposal. Drainage and flooding have been carefully considered and measures to facilitate residential development on the Site. Deliverability 3.19 This Site is considered “deliverable” as defined by the NPPF (Glossary). Specifically, the Site is available now, offers a suitable location for development now, and is achievable with a realistic prospect that housing will be delivered on the Site within five years of adoption of the new Local Plan. 3.20 The Site is located in a sustainable location, whereby future residents would not be reliant on the private car for their daily needs. Swavesey is a sustainable settlement with a range of services and facilities which are within walking and cycling distance of the Site. 3.21 As demonstrated by the supporting technical assessments, there are no ‘show stopping’ matters which would prevent the Site being allocated for development in the new Local Plan.

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8.3 It is recognised that no single solution will deliver a sound Local Plan; rather, a combination of approaches to the distribution of spatial growth will be necessary to establish the appropriate locations of new housing and employment development in the district. A hybrid approach will be required but should be underpinned by a focus on accessibility to public transport, employment and other daily needs. 8.4 It is considered that a dispersal to villages should form part of a hybrid spatial strategy. Development within villages is essential to support a prosperous rural economy. Paragraph 84 of the NPPF (2019) notes that: Planning policies and decisions should recognise that sites to meet local business and community needs in rural areas may have to be found adjacent to or beyond existing settlements, and in locations that are not well served by public transport. In these circumstances it will be important to ensure that development is sensitive to its surroundings, does not have an unacceptable impact on local roads and exploits any opportunities to make a location more sustainable (for example by improving the scope for access on foot, by cycling or by public transport). The use of previously developed land, and sites that are physically well-related to existing settlements, should be encouraged where suitable opportunities exist.

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43. We consider that new development should be located strategically within the District, on site’s that are considered to be both sustainable and suitable. Therefore, we feel as though these options should not be ranked by those most and least preferred and should be considered on the basis of their location and sustainability merits. 44. Fundamentally, new development should aim to address problems within the South Cambridgeshire and Cambridge City areas, such as reducing congestion and traffic within and around Cambridge City Centre. It is not considered that further major allocations within and on the edge of Cambridge City will address congestion. 45. It is considered that growth should be focused along key transport corridors and within villages that have a train station and are situated outside of the Green Belt. It is also very important that a number of smaller and medium sites are allocated that can be delivered in the short term without the need for substantial infrastructure requirements. 46. Summary:A blended strategy is supported but specifically including development in villages and along public transport corridors.

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Please inform me of other consultations in connection with the emerging Local Plan.

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As has been explored by Southern & Regional Developments (Cottenham) in their response to Question 6, the Plan does not provide an appropriate approach to the identified big themes with a clear emphasis provided towards achieving environmentally sustainable development. This results in weight attached to objectives focussed on climate change and the natural environment which reduces the Plan's ability to ensure development that meets the other requirements of the Plan, such as the quantum of residential development implemented in the correct locations. It is considered that although the themes of "Climate Change" and "Biodiversity and Green Spaces" should be important issues that need to be addressed through the new Local Plan, these should not preclude the ability of the Plan in engaging with the other big issues. Furthermore, by prioritising these themes into a hierarchy does not aid the Plan is recognising which issues are the most significant in combating. As currently drafted the Plan establishes an approach which automatically quashes the significance of some themes in favour of others. If the Plan wishes to inappropriately prioritise its objectives, it is considered that the big themes should be categorised as follows: 1. Wellbeing and Social Inclusion 2. Great Places 3. Climate Change 4. Biodiversity and Green Spaces It is maintained that the above themes are interlinked. For example, achieving development that combats Climate Change should include strategies to enhance biodiversity and provide open space as part of a sustainable approach. It is considered that, by categorising these themes into a hierarchy, this undermines this interconnectivity and simplifies the circumstances which the Plan looks to engage with. Summary of Comments: 1. Wellbeing and Social Inclusion, 2. Great Places, 3. Climate Change, 4. Biodiversity and Green Spaces.

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