Greater Cambridge Local Plan Preferred Options

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

OBJECT

Bloor Homes Eastern is promoting land west of Linton for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rural southern cluster, and specifically the decision to allocate a very limited amount of development to the more sustainable villages and no development to sustainable villages such as Linton.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + 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). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Camboure West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The preferred development strategy for the rural southern cluster is based on providing additional employment land at existing business clusters and a limited amount of additional housing at villages that are well connected to jobs by walking, cycling and public transport. It is considered that Linton contains a very good range of services and facilities, is accessible by sustainable modes of transport with new walking, cycling and public transport routes planned, and is very well related to employment opportunities at Granta Park and Babraham Research Campus. The decision to allocate housing sites at a limited number of villages in the rural southern cluster provides no support for the existing services and facilities in other sustainable villages provides no strategy to meet current identified affordable housing needs of those villages, and ignores the close proximity of major employment sites to Linton. Bloor Homes Eastern are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages including Linton to support services and ensure that identified affordable housing needs are met.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for rural southern cluster. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders.

Linton contains a very good range of services and facilities, including primary schools, secondary school, convenience stores and post office, village hall, health services including a medical centre, public houses, cafes and restaurants, and bus services. The promoted development at land west of Linton would support the existing services and facilities in the village. The promoted development would also provide land for a GP surgery and early years facility.

The promoted development by Bloor Homes Eastern at land west of Linton is accessible by walking, cycling and public transport to the services and facilities within the village and to employment at Granta Park and Babraham Research Centre. The promoted development would provide additional facilities including a GP surgery, early years facility, play areas, and open space including allotments. The site would be well-related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership’s Cambridge South East Transport project, which includes a new public transport route into Cambridge, a greenway/cycle route through Linton to Granta Park and Babraham Research Campus, and a rural travel hub at Linton. The Greater Cambridge Partnership’s Making Connections project also proposes a more frequent bus service for Linton.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 50 affordable dwellings in Linton for those with a local connection to the village – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without allocations in Linton. It is noted that no draft neighbourhood plan has been published for the village, there is no community land trust, and rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted development by Bloor Homes Eastern at land west of Linton would include housing and affordable housing to meet local needs of the village, and there will be a policy requirement for a proportion of the housing to be provided as self/custom build plots.

For all these reasons, additional medium scale housing allocations should be made in the more sustainable villages within the rural southern cluster , including at Linton, because it is accessible by sustainable modes of transport, it is well-related to the employment sites at Granta Park and Babraham Research Centre, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the villages which would not be met via other means.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that additional medium scale housing allocations should be made in the more sustainable villages within rural southern cluster, including at Linton, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable housing in those villages.

As requested in the Bloor Homes Eastern representations to Section 2.5: Rural Southern Cluster, the land west of Linton should be allocated in emerging GCLP for residential development.

OBJECT

Bloor Homes Eastern is promoting land west of Linton for residential development, and in representations has requested that the site is allocated in emerging GCLP. Linton is defined as a Minor Rural Centre in the settlement hierarchy for South Cambridgeshire, and Bloor Homes Eastern agree with the status of the village because of the very good range of services and facilities in the village and the good accessibility by sustainable modes of transport.

As set out in the representations to Policy S/SB: Settlement Boundaries, it is considered that there is limited capacity within the settlement boundaries of most villages. There are few outstanding development opportunities for 30 dwellings within existing settlement boundaries in Minor Rural Centres, and Linton is an example where there are no opportunities within the boundary for sites of 30 dwellings or more. It is likely that in most cases only small sites for one or two dwellings would be available. It is considered that the site size thresholds for each category of village are largely irrelevant and ineffective because very few sites are actually available, and those that are available would fall below the threshold where affordable housing is required e.g. less than 10 dwellings.

Requested Change

It is requested that a capacity assessment is undertaken of all villages in South Cambridgeshire to determine which potential housing sites might be deliverable or developable during the plan period to 2041, and the number of dwellings that might be delivered from each of those sites.

It is requested that the site size limits for each category of village are deleted and replaced with a general policy that supports development within existing settlement boundaries, in conjunction with a revised development strategy that allocates suitable sites on the edge of existing sustainable villages including at Linton.

OBJECT

Bloor Homes Eastern does not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018. It is very likely that most of the development opportunities within existing village boundaries would have been taken up by now. It is also likely that heritage assets within some villages, such as conservation areas and listed buildings, will constrain development opportunities.

The Councils have not undertaken an assessment of the capacity land within the existing settlement boundaries of villages to accommodate additional development. It is likely that such an assessment would demonstrate that the capacity is limited.

It is considered that the emerging GCLP should seek to allocate suitable sites on the edge of existing sustainable villages and to adjust the settlement boundary to accommodate those allocations. The site promoted by Bloor Homes Eastern at land west of Linton is suitable and available for housing, and should be allocated for development. There is a need for additional housing sites in the more sustainable villages to support existing services and facilities and to meet identified affordable housing needs in those villages.

Requested Change
It is requested that a capacity assessment is undertaken of all villages in South Cambridgeshire to determine which potential housing sites might be deliverable or developable during the plan period to 2041 and the number of dwellings that might be delivered from each of those sites.

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs it is requested that additional allocations are made on the edge of those villages to deliver sufficient housing to meet those affordable housing needs.

It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. The promoted development at land west of Linton would support the existing services and facilities in the village, including primary schools, secondary school, convenience stores and post office, village hall, health services including a medical centre, public houses, cafes and restaurants, and bus services. The promoted development includes land for a GP surgery and early years facility.

Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Small and medium sized sites typically only require limited new physical infrastructure and amendments to the access arrangements. The housing monitoring data from Cambridge and South Cambridgeshire confirms that small and medium sites are delivered quickly i.e. within two to three years. It is considered that small and medium sized sites make a significant contribution towards the short term housing land supply and the five year housing land supply position in Greater Cambridgeshire. It is requested that medium sized sites such as land west of Linton, as promoted by Bloor Homes Eastern, are allocated to meet the requirement for a mix of sites including those that are easily deliverable.

Paragraph 104 of the NPPF expects transport issues to be considered at the earliest stages of plan-making. Those issues include opportunities created by existing or proposed transport infrastructure in terms of the scale, location and density of development, and opportunities to promote walking, cycling and public transport use. Paragraph 105 expects significant development to be focused on locations which are or can be made sustainable. The promoted development by Bloor Homes Eastern at land west of Linton is accessible by walking, cycling and public transport to the services and facilities within the village and to employment at Granta Park and Babraham Research Centre. The site would be well-related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership’s Cambridge South East Transport project, which includes a new public transport route into Cambridge, a greenway/cycle route through Linton to Granta Park and Babraham Research Campus, and a rural travel hub at Linton. The Greater Cambridge Partnership’s Making Connections project also proposes a more frequent bus service for Linton. As such, there will be realistic alternatives to the car for travel to and from Linton once the Cambridge South East Transport project and Making Connections project have been delivered.

Paragraph 62 of the NPPF expects the size, type, and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters, and self-builders. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 50 affordable dwellings in Linton for those with a local connection to the village. This survey was from 2019 so the need will more than likely have increased. This identified need would not be met without allocations in the village. The promoted development by Bloor Homes Eastern at land west of Linton would include housing and affordable housing to meet local needs of the village and a proportion of self/custom build housing plots.

For all these reasons, additional medium scale housing allocations should be made in the more sustainable villages within the rural southern cluster, including Linton, because it is accessible by sustainable modes of transport, it is well related to employment opportunities, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable housing in the villages which would not be met via other means.

The Bloor Homes Eastern representations to the assessment of the land west of Linton site in the HELAA (Site Ref. 51047) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed. In summary, strategic landscaping would be provided as part of the promoted development, the existing public rights of way and the watercourse would be retained an incorporated into the development, the setting of heritage assets would remain free of built development, and open space and green infrastructure would be delivered.

A revised Vision Document has been prepared for the promoted development and is submitted with these representations. The key considerations for the design of the promoted development are as follows:
• Access / junction arrangements off the A1307.
• Protection of the River Granta corridor and associated flood plain while connecting pedestrian routes to existing footpath known as PROW 146/1.
• Conservation of woodland and hedgerows within the site area, through the provision of green space.
• Protection of the easement associated with the high voltage power line to the west.
• Conserving all Public Right of Way through the Site, and in particular creating strong pedestrian and cycle connections to the future Linton Greenway which will adapt PROW 146/2.
• Responding positively to heritage assets just north of the Site at Little Linton, including considering the positive attributes found in Linton Conservation Area.
• Retain existing rights of access for Linton Village College.
• Potential noise buffer/mitigations measures along A1307 Cambridge Road.

The design of the Concept Masterplan for the promoted development is described in detail in Section 5 of the revised Vision Document.

The landscape strategy for the promoted development seeks to:
• Deliver both natural and semi-natural landscapes.
• Retain and enhance existing trees and hedgerows wherever possible.
• Deliver a network of varied spaces, placing nature at its heart through the integration of a range of recreation spaces.
• Deliver new allotment space providing the opportunity for local community food growing and to help improve the biodiversity and habitat assets for the site.
• Deliver a range of multi-functional green spaces.
• Maintain the existing Public Rights of Way running through the site.

The benefits of the promoted development are as follows
• New homes to meet a range of needs, including first time buyers, families, and older people.
• A proportion of much needed new affordable homes.
• New Early Years site to support the existing facilities in Linton.
• New modern purpose built GP surgery for the village.
• Extensive areas of amenity space and green infrastructure.
• Introduction of a car club on site and communal EV charging points.
• High quality scheme which responds to its landscape and environmental context.
• Key views to the Rivey Hill and the water tower retained.
• Existing trees and hedgerows retained and enhanced within green corridors and new native planting.
• Ecological enhancements and an overall Biodiversity Net Gain.
• Direct connection to the proposed Linton Greenway, together with walking and cycling infrastructure to allow residents to use active travel.
• Convenient access to existing bus routes.
• Close to schools, shops, and community infrastructure.

The revised Vision Document could form the basis for a site specific allocation of the land west of Linton

Requested Change

It is requested that the development strategy for the rural southern cluster includes an additional residential allocation at land west of Linton.

It is requested that land west of Linton is allocated with the following policy requirements:

• Site Area of 20.83 Ha
• Capacity for circa 300 dwellings, including affordable housing and self/custom build plots
• A GP Surgery Site
• An Early Years Facility site
• Delivery of open space and green infrastructure
• Connect with proposed Linton Greenway through the site
• Development should address the following constraints:
o Strategic landscaping at southern site boundary
o Acoustic noise bund adjacent to A1307 Cambridge Road
o Avoid harm to heritage assets
o Maintain all existing Public Rights of Way through the site
o Maintain easement associated with the high voltage power line through western part of site

Policy I/ST: Sustainable Transport and Connectivity set out how the transport impacts of development should be managed, and how new development should be connected to the transport network. An aim of the policy is to reduce transport emissions. The preferred development strategy seeks to co-locate housing close to jobs, services, and facilities in order to reduce the need to travel and support travel by walking, cycling and public transport. This approach is consistent with Paragraphs 104 and 105 of the NPPF and is supported. However, it is considered of the aim of Policy I/ST will only be fully implemented if all available opportunities to direct development to sustainable locations are taken, including additional development being directed to Linton.

The promoted development by Bloor Homes Eastern at land west of Linton is accessible by walking, cycling and public transport to the services and facilities within the village and to employment at Granta Park and Babraham Research Centre. The site would be well-related to the transport infrastructure improvements proposed in the Greater Cambridge Partnership’s Cambridge South East Transport project, which includes a new public transport route into Cambridge, a greenway/cycle route through Linton to Granta Park and Babraham Research Campus, and a rural travel hub at Linton. The Greater Cambridge Partnership’s Making Connections project also proposes a more frequent bus service for Linton. As such, there will be realistic alternatives to the car for travel to and from Linton once the Cambridge South East Transport project and Making Connections project have been delivered. Therefore, additional development at Linton would be consistent with the aims of Policy I/ST.
Requested Change

It is requested that the promoted development by Bloor Homes Eastern at land west of Linton is allocated for residential development, in order to support the aims of Policy I/ST e.g. reduce transport emissions, reduce the need to travel, and encourage the use of sustainable modes of transport.

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic, and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Bloor Homes Eastern that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable, and in respect of villages it appears that the assessment against sustainability objectives is not robust because it does not critically review the evidence provided by the Councils. For example, some villages have good access by sustainable modes of transport and contain a good range of services and facilities, there is an identified need for affordable housing in most villages which is ignored in the assessment process, and there is limited capacity within existing settlement boundaries for villages to accommodate additional development.

The sustainability objectives that are relevant to the Bloor Homes Eastern representations are: SA1 Housing; and, SA2 Access to Services and Facilities.

The Bloor Homes Eastern representations and requested amendment to the assessment of policy options in the Sustainability Appraisal are as follows:

• Table 5.4: Policy S/DS: Development Strategy: A ‘significant positive effect/uncertain’ score is identified in the assessment for the housing sustainability objective (SA1). However, as set out in the Bloor Homes Eastern representations to Policy S/DS for land west of Linton, there are no housing allocations made in most villages, including Linton, and as such the identified needs for affordable housing in the villages would not be met by the preferred development strategy. South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified affordable housing needs for those with a local connection in all villages – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. That information is not reflected in the assessment contained in Table 5.4. The identified need for 50 affordable dwellings in Linton will not be met by the preferred development strategy, which must be a negative outcome for the housing related sustainability objective. Bloor Homes Eastern has requested that land west of Linton is allocated for housing and affordable housing to deliver positive housing related sustainability outcomes.

• Table 5.6: Policy S/SB: Settlement Boundaries. A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). As set out in the Bloor Homes Eastern representations to Policy S/SB and S/SH (Settlement Hierarchy) the settlement boundaries at most villages have remained largely unchanged since 2004 and there has been no assessment of capacity within settlement boundaries to accommodate additional development. The assessment in Table 5.6 does not consider whether any capacity exists within the settlement boundaries to accommodate the identified needs for affordable housing. Linton is an example where there are no opportunities within the boundary to accommodate major developments that would require affordable housing i.e. 10 or more dwellings. As set out above there is an identified need for at least 50 affordable dwellings in Linton. It must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Linton, will not be met by the currently defined settlement boundaries.

• Table 5.20: Policy S/RSC: Village Allocations in the Rural Southern Cluster: A ‘mixed significant positive and minor negative effect’ score is identified for the housing sustainability objective (SA1). A ‘mixed significant negative and minor positive effect / uncertain’ score is identified for access to services and facilities objective (SA2). As set out above there is an identified need for 50 affordable dwellings in Linton, and it must be a negative outcome for the housing related sustainability objective if affordable housing needs of villages, including Linton, will not be met by the development strategy or the strategy for rural southern cluster. Linton contains a very good range of services and facilities, including primary schools, secondary school, convenience stores and post office, village hall, health services including a medical centre, public houses, cafes and restaurants, and bus services which are due to be improved by Greater Cambridge Partnership projects. The accessibility to services and facilities is very good for Linton, but this is not reflected in the assessment for this sustainability related objective, and additional development in this village would improve the sustainability outcomes and support the existing services and facilities. In addition, the promoted development includes land for a GP surgery and early years facility.

It is requested that land west of Linton is allocated in emerging GCLP to deliver better and more positive sustainability outcomes compared with the preferred development strategy.