S/SB: Settlement boundaries

As set out under Policies S/DS and S/SH, we are very concerned that the proposed development strategy ignores the need for suitable levels of growth to come forwards in the rural areas in order to maintain the vitality of rural communities. Without growth, facilities and services in these villages will not be viable in the long term.

The proposed settlement boundary policy compounds this issue by severely restricting growth outside settlement boundaries. There will be a need for both market and affordable housing growth in all villages during the plan period and to resolve this issue, we consider that some growth should be allocated to all settlements or a flexible policy should be adopted to allow a certain level of development on the edge of all villages according to their position in the settlement hierarchy. One such flexible policy would be to draw settlement boundaries more loosely so that they include small sites promoted for development on the edge of villages. In this way, it would be possible allow suitable sites to come forward under Policy S/SB.

We await the detailed maps in this regard. The Council’s will need to consider the implications of any changes in national policy in this regard.

The proposed policy direction to include settlement boundaries around settlements is supported. Settlement boundaries play an important role in controlling development, however they should not be used as a basis for preventing otherwise sustainable development from coming forward. It is noted that the First Proposals states that boundaries will be defined to take into account the present extent of the built-up area and planned new development. However, the proposed development strategy to restrict the number of dwellings in certain tiers of the settlement hierarchy and the low number of site allocations proposed for the rural areas will prevent sustainable development from being brought forward unless further sites are allocated for development and included within the settlement boundary.
Should the Councils wish to continue to apply a heavy reliance on windfall development to accommodate growth, the settlement boundaries will need to be drawn more loosely around existing settlements, particularly those beyond the outer Green Belt boundary, to allow for speculative development to come forward.
Consideration should also be given to the provision of Cambridge South new station, which is anticipated to increase capacity along the existing rail line, through settlements such as Meldreth. Such infrastructure will increase the sustainability of existing settlements such as Melbourn, enabling further development to come forward within this location. Land to the East Side of Cambridge Road offers a sustainable location for residential growth located along the Melbourn Greenway, which will enhance linkages between Melbourn and Cambridge, providing a green active travel into and out of the city for walkers, cyclists and horse riders. The greenway states that a key benefit is its convenient location for Melbourn Science Park, recognising the importance of this Science Park as an employment destination and its contribution to the wider Greater Cambridge area.

The proposed policy direction to include settlement boundaries around settlements is supported. Settlement boundaries play an important role in controlling development, however they should not be used as a basis for preventing otherwise sustainable development from coming forward.

It is noted that the First Proposals states that boundaries will be defined to take into account the present extent of the built-up area and planned new development. However, the proposed development strategy to restrict the number of dwellings in certain tiers of the settlement hierarchy and the low number of site allocations proposed for the rural areas will prevent sustainable development from being brought forward unless further sites are allocated for development and included within the settlement boundary.

Should the Councils wish to continue to apply a heavy reliance on windfall development to accommodate growth, the settlement boundaries will need to be drawn more loosely around existing settlements, particularly those beyond the outer Green Belt boundary, to allow for speculative development to come forward.

Fowlmere
In particular, the adopted settlement boundary for Fowlmere is tightly drawn around the existing built edge of the settlement, restricting the ability for additional greenfield sites to come forward as windfall development.
On the basis that the settlement boundary remains unchanged through the Greater Cambridge Local Plan, it is assumed that windfall development within the settlement is anticipated to be delivered through brownfield sites.
Fowlmere predominantly comprises residential development on small plots serviced by a number of facilities, including but not restricted to a church, public house, primary school, business units and business park. There are no clear opportunities for redevelopment of previously developed land within the settlement.

A review of the sites promoted through the recent call for sites also emphasises the lack of brownfield sites available, with only one previously developed site promoted for development.

This, together with the way in which the settlement boundary is shown, suggests that there is very limited opportunity for additional growth to be delivered within Fowlmere during the emerging Local Plan period and we raise concerns with regards to the Councils’ overall spatial strategy, which could be detrimental to the vitality of these Group Villages.

Land West of London Road Fowlmere lies adjacent to the existing settlement boundary as well as to employment opportunities at the Manor Farm Business Park to the north, is suitable for development and is immediately available, thereby able to contribute to the vitality of this Group Village. In addition, the proposed development would deliver low carbon housing, electric vehicle charging at every dwelling and promote low water consumption, therefore positively contributing to reducing carbon emissions and mitigating the effects of climate change.

The Welding Institute (TWI)

Object

Policy S/SB: Settlement boundaries

The settlement boundaries around settlements will be drawn on the Policies Map that will accompany the draft Local Plan for consultation.

Requested Change
Granta Park (Employment areas in the Countryside) needs to be clearly identified as being an exception to development in the Countryside.

In terms of the policy direction under S/SB it is identified that outside settlement boundaries, we propose that no development would be permitted except for:

• allocations within Neighbourhood Plans that have come into force
• Rural (see policy approach H/ES) which help meet local needs for affordable housing
• development for agriculture, horticulture, forestry, outdoor recreation and other uses that need to be located in the countryside; or
• development supported by other policies in the plan.

Requested Change
Employment areas in the Countryside should be referenced under the terms of this policy.

Whilst considering how settlements could grow, LVA encourage the Council to also consider modern concepts of development outside of settlement boundaries. It needs to provide policies that are open-minded to different types of development at villages and within the rural areas beyond the usual market and affordable housing sites. Flexible live-work units should be strongly encouraged to cater for the many more people who are working from home. LVA urge the Council to broaden existing policies to incorporate concepts such as:

▪ Co-housing - There are key benefits to this type of development that are currently largely disregarded in planning policy. The concept permits families and communities to live together within their own spaces in diverse, multi-generational neighbourhoods. It results in a prosperous community approach to living, a reduced need for social care provision, improvements to the health and wellbeing of residents, especially among the elderly and vulnerable and many more benefits.

▪ Self-Build - Self-build sites that provide serviced plots offer people the highly attractive opportunity to build their own home to suit their own needs and lifestyles. The introduction of a policy which accepts that self-build led schemes to proportionate level will be permitted at all settlements (inside and outside settlement boundaries) where such need is evidenced would be welcomed. This would add to the richness of design and variety.

Additional, exceptional growth outside of any development boundaries should be supported where products serving specific needs and communities are provided, such as (but not limited to) first-time buyer housing, live/work units, age-restricted rural-style living sites (care homes, park home sites etc.), co-housing sites, self-build sites, special care sites etc.

We support the expansion of the Cambridge City settlement boundary to include any additional land required to support the sustainable and environmentally respectful growth of Cambridge Biomedical Campus, including land identified to the south of the Campus as the potential Major Area of Change. Any development will be carefully planned to take account of the views of neighbouring authorities and with a primary objective to achieve great placemaking.

Settlement boundaries should be a positive planning tool. The inflexibility that this creates for smaller sites, including those in the Green Belt, to plug the gap to maintain supply targets in the event that delays are experienced at the larger sites. Villages in the green belt are generally relatively more sustainable, particularly at Gt Shelford. Without any safeguarded land being identified, there is still a valid concern that speculative applications could be pursued at less sustainable locations if the housing supply drops below five years during the plan period.

Our submissions to the Councils in advance of the First Proposals demonstrate how expansion to the SE and SW of the Campus can be achieved without undermining important Green Belt objectives and how new boundaries for Cambridge can be set which would enhance its southern edge and the connections between the City and its countryside.

We also propose an amendment to the policy text for Policy S/SB Settlement Boundaries (p51), through the insertion of ‘garden centres’ within the 3rd bullet point, to read: ■ development for agriculture, horticulture, garden centres, forestry, outdoor recreation and other uses that need to be located in the countryside; As garden centres require to operate on sites of a significant scale they are frequently found in the countryside rather than within a settlement boundary. Dobbies garden centres such as at Royston benefit from proximity to the strategic road network as well as from a countryside ambience.

Objection is raised in respect of the proposed approach to settlement boundaries (and rural settlements more widely). In this regard, the policy approach of including the present extent of the built up area, and deliberately excluding farm buildings even if they are contiguous with or within the settlement, stifles opportunities to deliver much needed growth at rural settlements, many of which within the Plan area would positively benefit from new development through opportunities to deliver affordable housing for local people, as well as much needed growth and investment into communities. If settlement boundaries are to be defined, the Plan approach should be adapted to include obvious development opportunities, such as large-scale farm buildings contiguous with existing settlements within the settlement boundaries. These buildings are frequently unsightly, overly dominant in scale and give rise to amenity complaints, making them bad neighbour uses. Their redevelopment can deliver significant planning benefits, yet they are needlessly hindered by an unjustified approach to settlement boundaries that precludes them from being brought forward.

Bury Farm in Meldreth is a relevant case example, where a large scale farm complex within/adjoining the settlement of Meldreth, with bus and rail services adjoining, is needlessly excluded from coming forward as a windfall site, despite the potential to deliver a highly sustainable development, comparable with or superior to most development sites in the Plan area.

The policy approach of precluding farm buildings/sites beyond settlement boundaries from being developed is irrational. There are very few allocations at rural settlements in the draft Plan, there are very few windfall sites within such settlements and the Plan can ill afford to ignore and hinder such an obvious and suitable source of supply.

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the ‘organic’ growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.

Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the ‘open countryside’. But it is not logical to treat all sites equally in policy terms. Whilst sites within sensitive valued landscapes and the green belt should receive a high level of protection, the sensitive development of some sites on the edge of a village would cause no significant harm. Such a pragmatic approach is often taken at appeal. For example, rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping where it would soften an existing harsh area of built form can be acceptable in certain locations.

Furthermore, for minor rural centres such as Linton, the current strategy to restrict schemes to an indicative maximum of 30 dwellings within settlement boundaries will not deliver the quantum of development required to meet the pressing local need for affordable homes. As a result, the affordability crisis will deepen in the rural area. For example, to deliver 25 affordable homes within Linton, a minimum of 63 dwellings will need to be permitted as part of major developments. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable villages such as Linton.

In summary, a carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built-up areas should not perpetuate unfettered incremental growth.

In line with their promotion of Land South of Newington, Willingham, Silverley Properties Ltd advocate that the entirety of the site should be included within the settlement boundary of Willingham as part of the allocation of the site for residential development.

Cambourne Town Council is in agreement with this policy

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). While it is acknowledged that the principle of this growth is already established through adopted development plan documents, the additional dwellings at Cambourne is proposed through the emerging GCLP and associated East West Rail.

While it is acknowledged that the Council’s preferred development strategy is to utilise those edge of Cambridge sites which were previously developed, the redevelopment of both North-east Cambridge and Cambridge East poses significant challenges. North-east Cambridge requires the relocation of a sewage treatment works and existing businesses; Cambridge East requires the relocation of airport related uses and businesses. The development of these site is therefore very complex and highly likely to cause delays to delivery within the plan period and also highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The Councils’ preferred development strategy also refers to speeding up housing delivery rates at some new settlements. However, there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. The Councils have not evidenced if any site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings per year over the plan period.

In order to ensure that the overall plan is deliverable, there needs to be greater certainty that sites will come forward within the plan period to deliver the growth required and, in turn, to address the under-delivery of affordable housing within Greater Cambridge. This under-delivery is evidenced through the affordable housing contributions that have come forward on major strategic sites as follows:

• Northstowe (Phase 1 and 2) - 20%
• Waterbeach – 30%
• Cambridge East – (Wing) – 30%
• Cambourne West – 30%

The development strategy should allocate some sites that are capable of delivering policy-compliant levels of affordable housing. Land at Gazelle Way does not have infrastructure constraints and, as such, can provide policy-compliant levels of 40% affordable housing to help address the significant under-delivery in Greater Cambridge. The potential for sites like this to deliver policy compliant levels of affordable housing has been evidenced at Land north of Cherry Hinton.

It is acknowledged that the development of Land at Gazelle Way requires some release of land from the Green Belt, and that the Council have dismissed this as a preferred option as per the following conclusion:

“Whilst edge of Cambridge Green Belt sites performed in a similar way in many respects to Cambridge East, they would have significant Green Belt impacts and given the relatively good performance of Cambourne, which is not in the Green Belt and would benefit from there was considered to be no exceptional circumstances for releasing land on the edge of Cambridge to meet development needs as a matter of principle and that spatial option was not preferred.”

Greater Cambridge has significant affordability issues and addressing such affordable housing needs should be a priority for the Local Plan. Allocating the land east of Gazelle Way which will deliver the affordable housing required provides justification for the release of Green Belt land, especially since this land is located sustainably and is well served by public transport as required by paragraph 142 of the NPPF when reviewing Green Belt boundaries.

Land at Gazelle Way is located on the edge of Cambridge, only three miles from the City Centre. The site benefits from existing sustainable transport infrastructure, including access to existing cycle routes and bus service provision to access surrounding local amenities and facilities, as well as convenient access into the City Centre. The site will also benefit from being located along the proposed Fulbourn Greenway route and has potential to accommodate a new train station along the Cambridge-Ipswich line. The accessibility of the site is not reliant on expensive major new infrastructure.

The development strategy needs to fully embrace and reflect the strategy for the City of Cambridge to be net zero carbon by 2030. The allocation of highly sustainable sites where housing and jobs are located together, reducing the need to travel, will be instrumental in achieving this goal. The Land at Gazelle Way is within a highly accessible location which means that new residents would not be reliant on their cars to access jobs, shops or socialise either within the Site or within the City. The vision for this site is to provide a highly sustainable community which locates homes and jobs together.

In summary, Endurance Estates wish to object to the ‘high risk’ nature of the development strategy, which is dependent upon the delivery of some strategic, complex sites. The development of these is highly likely to cause delays to delivery within the plan period and highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The development strategy should allocate some additional sites such as Land east of Gazelle Way that are capable of delivering policy compliant levels of affordable housing. The allocation of the site would also contribute to the Council’s aspirations to become a zero-carbon authority by 2030 by offering an opportunity to be a truly sustainable community which locates homes and jobs together.

BioMed Realty (Granta Park JCO1 Limited)

Object

Policy S/SB: Settlement boundaries

The settlement boundaries around settlements will be drawn on the Policies Map that will accompany the draft Local Plan for consultation.

Requested Change
Granta Park (Employment areas in the Countryside) needs to be clearly identified as being an exception to development in the Countryside.

In terms of the policy direction under S/SB it is identified that outside settlement boundaries, we propose that no development would be permitted except for:

• allocations within Neighbourhood Plans that have come into force
• Rural (see policy approach H/ES) which help meet local needs for affordable housing
• development for agriculture, horticulture, forestry, outdoor recreation and other uses that need to be located in the countryside; or
• development supported by other policies in the plan.

Requested Change
Employment areas in the Countryside should be referenced under the terms of this policy.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). While it is acknowledged that the principle of this growth is already established through adopted development plan documents, the additional dwellings at Cambourne is proposed through the emerging GCLP and associated East West Rail.
While it is acknowledged that the Council's preferred development strategy is to utilise those edge of Cambridge sites which were previously developed, the redevelopment of both North-east Cambridge and Cambridge East poses significant challenges. North-east Cambridge requires the relocation of a sewage treatment works and existing businesses; Cambridge East requires the relocation of airport related uses and businesses. The development of these site is therefore very complex and highly likely to cause delays to delivery within the plan period and also highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The Councils' preferred development strategy also refers to speeding up housing delivery rates at some new settlements. However, there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. The Councils have not evidenced if any site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings per year over the plan period.

In order to ensure that the overall plan is deliverable, there needs to be greater certainty that sites will come forward within the plan period to deliver the growth required and, in turn, to address the under-delivery of affordable housing within Greater Cambridge. This under­ delivery is evidenced through the affordable housing contributions that have come forward on major strategic sites as follows:

• Northstowe (Phase 1and 2) - 20%

• Waterbeach - 30%

• Cambridge East - (Wing) - 30%

• Cambourne West - 30%

The development strategy should allocate some sites that are capable of delivering policy­ compliant levels of affordable housing. Land at Gazelle Way does not have infrastructure constraints and, as such, can provide policy-compliant levels of 40% affordable housing to help address the significant under-delivery in Greater Cambridge. The potential for sites like this to deliver policy compliant levels of affordable housing has been evidenced at Land north of Cherry Hinton.

It is acknowledged that the development of Land at Gazelle Way requires some release of land from the Green Belt, and that the Council have dismissed this as a preferred option as per the following conclusion:

"Whilst edge of Cambridge Green Belt sites performed in a similar way in many respects to Cambridge East, they would have significant Green Belt impacts and given the relatively good performance of Cambourne, which is not in the Green Belt and would benefit from there was considered to be no exceptional circumstances for releasing land on the edge of Cambridge to meet development needs as a matter of principle and that spatial option was not preferred."

Greater Cambridge has significant affordability issues and addressing such affordable housing needs should be a priority for the Local Plan. Allocating the land east of Gazelle Way which will deliver the affordable housing required provides justification for the release of Green Belt land, especially since this land is located sustainably and is well served by public transport as required by paragraph 742 of the NPPF when reviewing Green Belt boundaries.

Land at Gazelle Way is located on the edge of Cambridge, only three miles from the City Centre. The site benefits from existing sustainable transport infrastructure, including access to existing cycle routes and bus service provision to access surrounding local amenities and facilities, as well as convenient access into the City Centre. The site will also benefit from being located along the proposed Fulbourn Greenway route and has potential to accommodate a new train station along the Cambridge-Ipswich line. The accessibility of the site is not reliant on expensive major new infrastructure.

The development strategy needs to fully embrace and reflect the strategy for the City of Cambridge to be net zero carbon by 2030. The allocation of highly sustainable sites where housing and jobs are located together, reducing the need to travel, will be instrumental in achieving this goal. The Land at Gazelle Way is within a highly accessible location which means that new residents would not be reliant on their cars to access jobs, shops or socialise either within the Site or within the City. The vision for this site is to provide a highly sustainable community which locates homes and jobs together.

In summary, Endurance Estates wish to object to the 'high risk' nature of the development strategy, which is dependent upon the delivery of some strategic, complex sites. The development of these is highly likely to cause delays to delivery within the plan period and highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The development strategy should allocate some additional sites such as Land east of Gazelle Way that are capable of delivering policy compliant levels of affordable housing. The allocation of the site would also contribute to the Council's aspirations to become a zero-carbon authority by 2030 by offering an opportunity to be a truly sustainable community which locates homes and jobs together.

This policy defines that settlement boundaries will be identified around existing settlements and planned new development outlined in the Plan. It is proposed that boundaries would take into account the existing built-up areas but will not normally include buildings associated with countryside uses, such as farm buildings nor development which is detached from the main concentration of buildings in an existing area.
It is also proposed that outside defined settlement boundaries that no development would be permitted except for:
• allocations within Neighbourhood Plans that have come into force;
• Rural Exception Sites which help meet local needs for affordable housing;
• development for agriculture, horticulture, forestry, outdoor recreation and other uses that need to locate in the countryside; or
• development supported by other policies in the plan.
This policy limits the opportunity for suitable sites on the edge of settlements to come forward that can meet the needs of Extra Care development where it is required, and which can effectively tackle the known affordability crisis in the district. This policy needs to ensure that affordable housing is delivered quickly and in areas in which it will support the local community. PPG notes that ‘A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.’ (Paragraph: 009 Reference ID: 67-009-2019072)
As outlined above, there is a defined current and future substantial unmet need for specialist housing. The current need of specialist housing is rising, and it is unlikely that this need will be met at urban extension or within new settlements, which are likely to come forward in the later parts of the plan period. Given the overall demand for housing in Greater Cambridge and the inflexibility of the Councils’ overall strategy the nature and extent of supply in these locations is such that operators within the specialist older persons housing sector face extreme pressures of competition in securing development opportunities. This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
Consideration should therefore be given to the release of such sites for development beyond sustainable settlement envelopes such as land at Branch Road and Long Lane, Comberton.

No coalescence of settlements.

Partly Supportive but OBJECT to parts of this policy as being incomplete. The Local Plan (LP) states that it will include settlement boundaries around settlements, identifying areas that are considered to be part of the settlement for planning purposes.
However, it fails to include, or refer to the area between Fen Ditton and Horningsea known as Honey Hill despite the fact that building a commercial development there extends the building capacity of North East Cambridge as described in the proposed North East Cambridge Area Action Plan.
Object also that the LP also states that where planned developments, such as new settlements, have reached sufficient certainty regarding their exact boundaries, new settlement boundaries will be drawn. This does not allow for a finite point at which that certainty is assessed and allows for “mission creep”. More careful wording is needed for this policy to prevent description of boundaries becoming vague. While the LP proposes that no development would be permitted outside settlement boundaries with exception, these exceptions include development supported by other policies in the plan. This would allow incursion in the Green Belt if it became expedient to enlarge a development that already covered by other policies, such as Policy S/NEC: North East Cambridge.

FORM RESPONSE

Vision and development strategy
Section / Policy Your comments
Vision and aims
How much development, and where – general comments Support the approach to contain any development to major clusters.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support Steeple Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support tightly drawn development boundaries are important to reduce encroachment into the countryside and particularly for linear villages protecting their character. Also assists in delivering exception sites.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity so do we have an obligation to consider where we might generate this locally? There should be clear comments on how and where solar PV farms and windfarms are going to be planned
CC/NZ: Net zero carbon new buildings Should not be specific about not connecting a gas pipe to new housing. This might prevent the future distribution of Hydrogen. Should keep this option open
CC/WE: Water efficiency in new developments Absolutely necessary.
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation. Especially managing hard surface run off.
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding.
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedialaction if required.
BG/GI: Green infrastructure Support for recognition of Pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support particularly providing enhanced protection to existing mature trees.
BG/RC: River corridors Support Steeple Morden has an important tributary of the Cam flowing through the Parish – The Rhee. There should also be recognition enhancement and protection for the brooks which emanate from the aquifer spring line and help feed the river system.
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety Support

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character particularly those villages with a predominantly linear form.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support Need to complete Conservation Area Assessments for villages
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support but condition included that if part of Pub is agreed for another use the marketing policy remains.

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Strongly support particularly in the light of grade I peat soil requiring remedial action and the need for increased food security.
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support but would stress the importance of ensuring that structures are sound.
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support and encouraged where there is no conflict with exception site policy.

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.

Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff from hard surfaces to minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but Improvements required to rural public transport and the last mile congestion into Cambridge City.
I/EV: Parking and electric vehicles Support for rural public charging points at community facilities
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support. Should also include disused railway lines with potential for future use.
I/AD: Aviation development Airfields are an important resource and difficult to replace. Local Plan should recognise the need for National Network of General Airfields.Government National Planning Policy Framework section 106.f, to ensure that planning decisions have regard to the importance of the national network of General Aviation airfields is clear. Environmental health concerns should be taken into account when deciding on housing location to avoid new occupants stress, disappointment and possible conflict.
I/EI: Energy infrastructure masterplanning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Supporting documents on which we are consulting
Policy Your comments
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)
Habitats Regulations Assessment

Firstly, the Form To Assist gives a comment column for Vision and Aims.
We have numerous comments to make under this heading but I have not been able to locate this on the online system.
Secondly, the online system asks "Did you raise the matter that is the subject of your representation with the LPA earlier in the process?"
Guilden Morden Parish Council have not been involved earlier in the process. I have therefore clicked "No" but the system will not allow me to proceed further.
The online system allows only 100 words for each comment and to summarise the comments to avoid exceeding 100 words. It would have been helpful if the Form To Assist had stated that.
Vision and development strategy
Section / Policy Your comments
Vision and aims 1.Guilden MordenParish Council has concerns that the increase in population resulting from the additional homes target of 44,000 will have a negative impact on an already struggling traffic, school and healthcare infrastructure.
Specifically on traffic and congestion:
Commuting into and out of Cambridge at peak times already attracts significant congestion and delay for commuters.
This not only effects commuting by car but also bus and the Park&Ride buses as these typically use the same roads as the other commuters and the bus lane network doesn’t extend to where it’s needed.
Links between the train stations and the city centre are also currently inadequate and equally effected by commuter congestion.
The guided busway is too infrequent to be a viable alternative and typically the Park& Ride parking is at capacity leaving commuters with little alternative other than to drive into the city centre.
All of the above describes the current situation which will clearly be significantly worsened by the addition of 44,000 homes by 2041.
2. Is the methodology used in arriving at the figure of 44,000 defendable?

How much development, and where – general comments Support that the proposed developments are to be in major clusters in areas with good public transport.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support. Guilden Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support. Tightly drawn development boundaries are important to reduce encroachment into the countryside.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity. Where might this be generated locally by solar and/or wind?
CC/NZ: Net zero carbon new buildings Support
CC/WE: Water efficiency in new developments Absolutely necessary
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedial action if required
BG/GI: Green infrastructure Support for recognition of pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support
BG/RC: River corridors Support
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Support
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.
Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff fromhard surfacesto minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but improvements required rural public transport and congestion into Cambridge (see comments under Vision and Aims)
I/EV: Parking and electric vehicles Support
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support
I/AD: Aviation development Support
I/EI: Energy infrastructure master planning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

Whilst the Council reference rural exceptions sties in this policy no mention is made to First Home exception sites. Given that First Home exception sites are referred to in policy HE/S the Councils must ensure that policy S/SB refers to both rural exception sites and first homes exception sites in order to maintain consistency between these two policies.

The overall development strategy is very reliant on the delivery of an extension to an existing new settlement (Cambourne West and an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). While it is acknowledged that the principle of this growth is already established through adopted development plan documents, the additional dwellings at Cambourne is proposed through the emerging GCLP and associated East West Rail.
While it is acknowledged that the Council's preferred development strategy is to utilise those edge of Cambridge sites which were previously developed, the redevelopment of both North-east Cambridge and Cambridge East poses significant challenges. North-east Cambridge requires the relocation of a sewage treatment works and existing businesses; Cambridge East requires the relocation of airport related uses and businesses. The development of these site is therefore very complex and highly likely to cause delays to delivery within the plan period and also highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The Councils' preferred development strategy also refers to speeding up housing delivery rates at some new settlements. However, there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. The Councils have not evidenced if any site-specific circumstances are present on these sites that mean they will deliver an above-average number of dwellings per year over the plan period.

In order to ensure that the overall plan is deliverable, there needs to be greater certainty that sites will come forward within the plan period to deliver the growth required and, in turn, to address the under-delivery of affordable housing within Greater Cambridge. This under­ delivery is evidenced through the affordable housing contributions that have come forward on major strategic sites as follows:

• Northstowe (Phase 1and 2) - 20%

• Waterbeach - 30%

• Cambridge East - (Wing) - 30%

• Cambourne West - 30%

The development strategy should allocate some sites that are capable of delivering policy­ compliant levels of affordable housing. Land at Gazelle Way does not have infrastructure constraints and, as such, can provide policy-compliant levels of 40% affordable housing to help address the significant under-delivery in Greater Cambridge. The potential for sites like this to deliver policy compliant levels of affordable housing has been evidenced at Land north of Cherry Hinton.

It is acknowledged that the development of Land at Gazelle Way requires some release of land from the Green Belt, and that the Council have dismissed this as a preferred option as per the following conclusion:

"Whilst edge of Cambridge Green Belt sites performed in a similar way in many respects to Cambridge East, they would have significant Green Belt impacts and given the relatively good performance of Cambourne, which is not in the Green Belt and would benefit from there was considered to be no exceptional circumstances for releasing land on the edge of Cambridge to meet development needs as a matter of principle and that spatial option was not preferred."

Greater Cambridge has significant affordability issues and addressing such affordable housing needs should be a priority for the Local Plan. Allocating the land east of Gazelle Way which will deliver the affordable housing required provides justification for the release of Green Belt land, especially since this land is located sustainably and is well served by public transport as required by paragraph 742 of the NPPF when reviewing Green Belt boundaries.

Land at Gazelle Way is located on the edge of Cambridge, only three miles from the City Centre. The site benefits from existing sustainable transport infrastructure, including access to existing cycle routes and bus service provision to access surrounding local amenities and facilities, as well as convenient access into the City Centre. The site will also benefit from being located along the proposed Fulbourn Greenway route and has potential to accommodate a new train station along the Cambridge-Ipswich line. The accessibility of the site is not reliant on expensive major new infrastructure.

The development strategy needs to fully embrace and reflect the strategy for the City of Cambridge to be net zero carbon by 2030. The allocation of highly sustainable sites where housing and jobs are located together, reducing the need to travel, will be instrumental in achieving this goal. The Land at Gazelle Way is within a highly accessible location which means that new residents would not be reliant on their cars to access jobs, shops or socialise either within the Site or within the City. The vision for this site is to provide a highly sustainable community which locates homes and jobs together.

In summary, Endurance Estates wish to object to the 'high risk' nature of the development strategy, which is dependent upon the delivery of some strategic, complex sites. The development of these is highly likely to cause delays to delivery within the plan period and highly likely to give rise to viability issues, leading to a reduction in the level of affordable housing to be provided.

The development strategy should allocate some additional sites such as Land east of Gazelle Way that are capable of delivering policy compliant levels of affordable housing. The allocation of the site would also contribute to the Council's aspirations to become a zero-carbon authority by 2030 by offering an opportunity to be a truly sustainable community which locates homes and jobs together.

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.

Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the 'open countryside'. But it is not logical to treat all sites equally in policy terms. The sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Land West of Elizabeth Way, Gamlingay). Such a pragmatic approach is often taken at appeal; rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping that would soften an existing harsh area of built form can be acceptable in certain locations.

Furthermore, for Minor Rural Centres such as Gamlingay the current strategy to restrict developments to an indicative maximum of 30 dwellings within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes as there are few opportunities for the development of sites within the existing settlement. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much-needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable villages such as Gamlingay.

Overall, a carefully worded criteria-based policy which is supportive of organic growth adjacent to existing built-up areas would allow rural areas to thrive and is in accordance with the aims of NPPF paragraph 79 which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

This policy will define the boundaries of settlements and proposes that outside of settlement boundaries, no development would be permitted unless they meet a specific set of requirements. Gladman recommend that the new Local Plan should take a flexible approach to development and growth within and on the edge of villages. A rigid approach to development beyond settlement boundaries, except for specific circumstances, may act to unnecessarily stifle sustainable growth opportunities. This is at odds with national policy which seeks to significantly boost the supply of housing and applies a presumption in favour of sustainable development.
Gladman recommend that the settlement boundaries policy incorporates a criterion based balancing exercise so that the Plan can protect against unsustainable development whilst being open and flexible to additional development opportunities to come forward to meet identified needs.

Firstly, the site at Steeple Morden is surrounded on three sides (north, west and south) by built form, with the settlement boundary for Steeple Morden being immediately adjacent to the west and south of the site.
The context of the site is key as the Councils’ reasoned justification for the proposed approach in the policy is to “help guard against incremental growth in unsustainable locations. (our emphasis)” Given that the site is encompassed by built form, it follows that the land forms part of the settlement form of Steeple Morden. Development on the site would be in a sustainable location within Steeple Morden, consistent with the existing settlement pattern and that would not result in the encroachment of the countryside. Furthermore, the site is residential curtilage and paddock land, which when read in the context of the wider site does not align with the features and characteristics of the surrounding countryside and is more akin to the settlement of Steeple Morden. Development of the site could therefore be achieved without adversely effects upon the intrinsic character and beauty of the countryside.
Definition of the settlement boundary for Steeple Morden is therefore unsound on the grounds of being not justified and not consistent with national policy.
The northern portion of Steeple Morden is largely linear in terms of development along a single road; however, the southern portion of the settlement is more clustered in terms of its built form which extends eastwards from Hay Street.
The site lies in an area of transition between the two distinctive areas so could be designed in a way that would support the transition without overtly impacting upon either of the two areas. The eastern boundary of the site if developed would follow the existing built form edge of Steeple Morden (along Craft Way) to the south of the site, which would act as a continuation of the settlement northwards, highlighting the relationship of the site to Steeple Morden. Therefore, given the characteristics of the site in relation to the identify of Steeple Morden it would be appropriate for it to be included within the settlement boundary to enable a smooth transition for the defined areas, in a sustainable location.

Land between 12 and 14 Station Road, Steeple Morden SG8 0NW
Site reference 40054

On 22nd April our planning consultant wrote to you alerting you to the fact that the call for sites database incorrectly represented our site in terms of its planning history. The site now benefits from an extant planning consent. Our submission to the local plan matches (does not exceed) the scale of development and land extent of the approved outline planning application S/1887/18/OL. The consent notice was dated 24th June, 2020.

The implication of this is that the District Council’s own assessment concluded that there were no factors in terms of Landscape and Townscape effects which outweigh the need for development. Indeed, the application was recommended for approval without objections from professional technical consultees for landscape and conservation area matters working on behalf of the District Council.

In the light of the foregoing we note that the Local Plan team’s site assessment (Map 596 site 40054) categorises our site a “Red” in the summary and “Red" against Landscape and Townscape. The assessment states that, “A key concern here is the woodland that comprises the site, development in this location would adversely impact the immediate and adjacent setting”. This conclusion is clearly based merely on a desktop appraisal and in ignorance of the various detailed professional submissions that led to recommendations for approval by the Council’s own professional officers in these areas of expertise. By this message we submit that the Local Plan's site assessment is demonstrably technically flawed. A substantial volume of technical submissions are held on the planning portal for the outline consent sufficient to outweigh the Local Plan’s conclusion and obviate the necessity to provide detailed argument here.

Our second area of concern is the stance taken in the plan to ignore the need for small scale opportunities for development in established settlements.

We submit that it is clear in paragraph 69 of the NPPF that ‘small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly’ and that local planning authorities should ‘promote the development of a good mix of sites’. It is considered that the Council 's strategy focuses on very large sites to deliver their housing requirement with virtually no small or medium allocations.

Furthermore, paragraph 79 of the NPPF is clear that in order 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.’ By delivering more housing in settlements such as Steeple Morden, development will continue to support local services and facilities, supporting their retention and growth. The need for additional housing in Steeple Morden was demonstrated by a formal 'Housing Need Survey' undertaken for the project by Cambridgeshire Acre in September and October 2020.

Taking these two points together we submit that there is a strong case to be made for the site to be allocated to deliver homes which meet a local need and for the settlement boundary for Steeple Morden to be amended to include our site 40054 within the development framework. As was concluded in the District Council's assessment of our planning application, development of our site represents gains in terms of housing, landscape, ecology and arboriculture. We hope that the Local Plan team will reconsider the status and the record of assessment of our site.

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.
Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the 'open countryside'. But it is not logical to treat all sites equally in policy terms. Although sites within sensitive valued landscapes and the green belt should receive a high level of protection, the sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Whittlesford). Such a pragmatic approach is often taken at appeal; rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping that would soften an existing harsh area of built form can be acceptable in certain locations.
Furthermore, for Group Villages such as Whittlesford and Whittlesford Bridge, the current strategy to restrict developments to an indicative maximum of 8 dwellings (or 15 dwellings where this would make the best use of a single brownfield site) within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes or the projected need that could follow nearby business park expansions. As a result, the affordability crisis will deepen in the rural area. For example, to deliver 25 affordable homes within Whittlesford, a minimum of 63 dwellings will need to be permitted as part of major developments. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much­ needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable settlements such as Whittlesford Bridge.
Overall, a carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built-up areas should not perpetuate unfettered incremental growth.