Greater Cambridge Local Plan Preferred Options

We have concerns that this policy will not address the identified need for specialist accommodation for older people in its entirety, nor will it ensure the right type of accommodation is delivered in the right places. In accordance with paragraph 62 of the NPPF, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies, including, inter alia, older people. Older people are defined within the NPPF as:

“People over or approaching retirement age, including the active, newly retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs.”

It is therefore imperative that the Plan makes provision for the delivery of a broad range of housing suitable for older people. PPG (Paragraph: 010 Reference ID: 63-010-20190626) provides a non-exhaustive list as to the different types of specialist housing designed to meet the diverse needs of older people, which include age-restricted general market housing, retirement living/sheltered housing, extra-care and housing-with-care, and residential care homes and nursing homes.

PPG confirms that the need to provide housing for older people is critical, and Greater Cambridge is no exception.

The Homes Topic Paper summarises the findings of the Older People’s Housing: Care and Support Needs in Greater Cambridge 2017-2036, which develops a model to estimate the supply and demand for older people’s housing. Using this model, the report identifies a need for 917 additional age exclusive homes within Greater Cambridge, in addition to 2,741 additional self-contained specialist homes in the form of sheltered accommodation or extra care accommodation. The report also identifies a shortfall, as of 2016 in the provision of specialist accommodation, recommending a total supply at 2035 of 2,036 age exclusive homes, and 6,163 specialist self-contained units.

This highlights a considerable current deficit in the supply of older persons’ accommodation, and a critical need to ensure that suitable and adequate provision is made within the Plan for specialist accommodation.

Policy H/SH confirms that some forms of specialist housing will be delivered through the requirements for all new homes to be built to M4(2) accessible and adaptable Building Standards. Whilst we support the intention to ensure all homes are built to these standards, M4(2) dwellings do not satisfy the broad range of housing needs of older people and should form part of the strategy for delivering sufficient suitable housing for older people.

There is insufficient detail within the Plan to demonstrate that either Policy H/SH or Policy H/HM (Housing mix) will ensure that provision of specialist housing will be required as part of the housing mix of new developments, particularly at new settlements and within urban extensions. This is particularly given these sites make up a considerably small element of the overall housing supply within the Plan period, therefore we question how these sites will be capable of delivering the identified need for specialist housing. Further, 97% of the additional sources of housing supply identified within the Plan are large, strategic sites, many of which, such as Cambridge Airport and the extension to Cambourne, will not be delivered until post 2030, with actual delivery timescales uncertain. A reliance on these sites to deliver specialist accommodation will not ensure timely delivery, not least due to the long lead times associated with developments of this size, which will cause further, considerable delay in meeting identified needs when there is already a substantial undersupply. Additionally, this approach does not ensure that homes will be delivered in locations where needs currently exist, requiring older people to make the choice of staying in a home that is not suitable for their needs, or move away from their existing community to find suitable accommodation.

We raise concerns that the Plan does not include sufficient sites to deliver housing within the short-term plan period in our comments on Policy S/DS, and this is applicable to the deliver of specialist accommodation.

Given the significant need for specialist housing identified within the Homes Topic Paper, and the inability of the Plan as proposed to meet this, we consider it is critical for the Plan to identify additional sites for specialist housing for older people, within sustainable locations throughout Greater Cambridge, to ensure the right type of homes are delivered in the right places. It is surprising that the reasonable alternatives considered did not include the allocation of sites for specialist housing, as part of a combined approach to ensure the diverse needs of older people will be met within the Plan period and, within the locations it is needed.

We disagree with the Councils’ consideration of site-specific arguments for exceptional circumstances for releasing sites from the Green Belt on the edge of Cambridge, particularly in relation to the land to the east of Ditton Lane, Fen Ditton (Site Reference: 40217), for specialist accommodation. Our comments in relation to the assessment of this site within the HELAA are noted against Policy S/EOC, however, the Council state in the Development Strategy Topic Paper (page 209) that the need for specialist accommodation does not justify the exceptional circumstances to release land from the Green Belt. We question how the critical need for specialist accommodation (including a considerable existing undersupply) does not justify the exceptional circumstances to release sites within a highly accessible location on the edge of Cambridge from the Green Belt but releasing sites to meet general housing needs from the Green Belt in other areas which benefit from good accessibility to public transport does, particularly in light of the High Court judgment Calverton Parish Council v Greater Nottingham Councils [2015] EWHC 10784. This confirms that factors that should ideally be considered in deciding whether exceptional circumstances exist include, inter alia, acuteness/intensity of the objectively assessed need and the inherent constraints on supply/availability of land prima facie suitable for sustainable development.

We would highlight the commentary within paragraph 4.40 of the Sustainability Appraisal, which states that whilst also helping to support existing services and facilities, growth within villages may be particularly important for the villages’ older residents, noting that the population in rural areas have a higher average age than Cambridge city. Fen Ditton has excellent access to a number of services and facilities and public transport links, and is an example of a village within Greater Cambridge which would be suitable for specialist accommodation.

Policy S/JH sets out the objectively assessed housing need of 44,400 homes (2,111 homes per annum). We agree with the reasons for discounting the alternative option of a lower figure calculated using the Standard Method and the potential consequences of not reflecting the likely forecast for future jobs; we query whether the Sustainability Appraisal (SA) should have considered the higher jobs forecast as a reasonable alternative. In relation this alternative, the SA states in its assessment of Policy S/JH, that planning for a higher jobs forecast is not considered to be a reasonable option due to this being possible, but not the most likely future scenario.

Given this scenario is a possibility, we consider it should be explored as a reasonable alternative within the SA, to ensure that a robust assessment is undertaken to support the objectively assessed housing need.

We question the approach taken to the distribution of growth within Greater Cambridge, and whether it will meet the objectively assessed housing need. We do not consider this to be the case, predominantly due to the uncertainty surrounding delivery of several of the proposed site allocations. We question how 1,950 homes within the new settlement at Cambourne could be included within the supply, given no specific site has been identified for allocation, and that delivery within this region is wholly dependent upon the East West Rail route and proposed Station at Cambourne, the route and location of which are as yet unconfirmed, as is the anticipated delivery date.

Paragraph 4.26 of the Sustainability Appraisal (SA) quotes the commentary of the Housing Delivery Study (2021), which highlights a risk of relying on delivery from North East Cambridge and Cambridge Airport towards the end of the Plan period, given the uncertainties relating to the relocation of the wastewater treatment works and the relocation of Marshall’s operations respectively. Whilst the Plan provides confirmation as to the likelihood of the site being available from 2030, it is anticipated that the site will be capable of delivering 2,850 dwellings by 2041. We question what evidence exists to support such an ambitious assumption, particularly in light of the conclusions within the Housing Delivery Study (2021) that a traditional market-led approach would be unlikely to exceed an average of 300dpa over the duration of the build-out period. Furthermore, the Study also notes that delivery increases over time to a ‘peak’ in the middle before decelerating. As such, even with an optimistic assumption of completions within 2030, a minimum annual delivery rate of 259 dwellings would be required, including at year 1, which is not realistic.

Whilst we do not dispute the proposed allocation at Cambridge Airport, we do not consider there is sufficient evidence to support the delivery of 2,850 dwellings within the Plan period. As such, the Plan should identify additional sites for allocation to ensure the Plan is capable of meeting the objectively assessed housing need, and to ensure there is sufficient flexibility within the supply should any sites not deliver as expected.

The proposed strategy includes a heavy reliance upon large, strategic sites. The table on pages 77 and 78 of the Development Strategy Topic Paper calculates that the number of additional homes to be identified through the Plan, in addition to existing commitments, is 11,642. The additional sources of supply identified through the Plan include accelerated delivery rates at existing strategic sites, as well as a number of additional large sites. Of the total additional sources of supply identified, which we note is marginally below the identified requirement, 396 homes of the total 11,596 are on small-medium sites, equating to 3.4% of the total supply. Paragraph 68 of the NPPF requires planning policies to identify a sufficient supply and mix of sites, including specific, deliverable sites for years 1-5 of the Plan period and specific, developable sites or broad locations for growth for years 6-10 and where possible, years 11-15 of the Plan. We consider the strategy is focussed on delivery within the latter part of the Plan period, with insufficient small and medium sites allocated to ensure the housing need is met during the short-medium term. Paragraph 69 of the NPPF confirms the important contribution that small and medium sites can make to meeting the housing requirement of an area.

As set out in our comments on the Sustainability Appraisal (SA), Option 5 – dispersal – villages was subject to a number of broad assumptions which we consider resulted in an overly negative score and unduly influenced the limited distribution of growth to village locations. Our concerns are set out in full in our comments on the SA.

Scott Properties considers that Bassingbourn and Kneesworth should be recognised as a single settlement for the purposes of the hierarchy, owing to their close proximity and functional relationship. Both settlements fall within the Parish of Bassingbourn-cum-Kneesworth, served by the same Parish Council and contained within the Neighbourhood Plan Area. Geographically, there is no physical separation between Bassingbourn and Kneesworth to the north of the Causeway, with the parts of Kneesworth along this route benefitting from close proximity to the services and facilities within Bassingbourn.

Bassingbourn is classified as a Minor Rural Centre within the adopted South Cambridgeshire Local Plan, recognised as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire. Kneesworth is classified as an Infill Village, which are generally the smallest villages in South Cambridgeshire whereby it is often necessary for residents to travel outside the village for most of their daily needs. The hierarchy fails to recognise that the residents of Kneesworth would only have to travel a very short distance to access day-to-day facilities that are located adjacent to the settlement and accessible within a short walking and cycling distance.

In order to recognise the functional relationship and close physical proximity between Bassingbourn and Kneesworth, we consider that these settlements should be recognised as a single settlement within the hierarchy. This approach has been taken in respect of other settlements in District, including Great Shelford & Stapleford and Histon & Impington.

As set out in our comments on Policies S/DS and H/SH, we do not consider that sufficient sites are identified to meet the objectively assessed housing need within the Plan period, predominantly due to the uncertainty surrounding the anticipated delivery rates and timescales for a number of the proposed allocations.

The land to the east of Ditton Lane, Fen Ditton (Site Reference: 40217) was assessed as an Edge of Cambridge: Green Belt site, although not selected for allocation. The site has been promoted by Scott Properties through the Plan process to date for specialist accommodation for older people, on a small part of the northern area of the site, with the southern half of the site proposed as open space and landscaping.

The site received a ‘red’ score within the HELAA in respect of suitability, on Townscape and Landscape grounds. Within this part of the assessment, the site is described as ‘an important green separation between Cambridge and the village of Fen Ditton. Development of this site would have an adverse effect on the landscape character for the setting of both Cambridge and Fen Ditton and contribute to their amalgamation. It is considered that there are no options for even limited development on this site.’

We dispute this conclusion. Firstly, limited development of the site would not result in the amalgamation of Cambridge and Fen Ditton, as demonstrated both within the Call for Sites submission and the accompanying Masterplan Concept Layout. The proposals for the site include development of a northern section only, extending to approximately 1.6ha, which would leave the majority of the site open, retaining the separation between the two areas, and providing considerable biodiversity and recreational benefits.

Further, development in the northern area of the site as identified within the Masterplan Concept Layout would not result in an adverse effect on the landscape character. This area is closely related to the existing residential development along Ditton Lane and High Ditch Road, with existing and planned landscaping acting as a considerable buffer to provide effective visual screening from the wider area.

We are unsure therefore, how it can be concluded that there are no options for limited development on the site. For the above reasons, we consider that the site should have received an ‘amber’ score for suitability, recognising that very few sites, including those proposed for allocation, received a ‘green’ for suitability within the HELAA. There are a number of other elements within the site’s assessment which we believe have been unreasonably scored ‘amber’.
We are unclear why sites have been assessed against their compliance with existing policy, particularly when the reason for this process is to produce a new Plan which will supersede existing policy.

We consider that scoring sites ‘amber’ due to being outside of the Development Framework is unnecessary; the purpose of the plan is to identify additional sites for allocation, and it has been established through the initial work undertaken that this will need to include sites outside of existing settlement boundaries.

The site receives an ‘amber’ score for Flood Risk due to the identified small risk of surface water flooding in a small area within the south-eastern corner of the site. However, as detailed within the site’s submission to the Call for Sites and Issues and Options consultation, and the Masterplan Concept Layout accompanying these representations, this area is proposed for landscaping and open space, therefore there would be no development within this area, and as such the site should have received a ‘green’ score.

The site scores ‘amber’ in relation to Historic Environment. This erroneously states that the site is within a Conservation Area. We would refer to the Fen Ditton Conservation Area (Draft Council policy (Ref: DCV 0029) (2005) as well as the South Cambridge Adopted Policies Map, neither of which show the site within the Conservation Area. The conclusions state that ‘development of the site could have a detrimental impact on a designated or non-designated heritage asset or the setting of a designated or non-designated heritage asset, but the impact could be reasonably mitigated.’

The nearest listed asset is noted as being within 100m. There are three Grade II listed buildings along High Ditch Road to the north of the site, however, these buildings are clearly visually separated from the site by considerable existing landscaping to the boundaries of these properties, therefore we agree that any impact on the heritage assets could be reasonably mitigated. As such, and given the site is not located within the Conservation Area, the scored should be ‘green’.

We question why the site received an ‘amber’ score for site access, despite stating that the proposed site is acceptable in principle subject to detailed design. An Access Drawing was submitted in support of the site to the Issues and Options Consultation and accompanies this submission, which shows that a safe and suitable access could be achieved from Ditton Lane. As such, we consider that there are no potential access constraints and therefore this score should be ‘green’.

The site scores ‘amber’ in respect of transport and roads, despite concluding that any potential impact on the functioning of trunk roads and/or local roads could be reasonably mitigated. The assessment also states that passenger transport, walking and cycling links and links to the public transport corridor should be considered. It is detailed with the assessment of accessibility to services and facilities that the site has good accessibility to key local services, transport and employment opportunities, which includes public transport less than 450m from the site. The site could provide connectivity into the existing public rights of way network immediately surrounding the site, which includes a cycle path to the south. This provides alternative and sustainable methods of transport and provides ease of access into the surrounding areas, including the public transport network thereby reducing the reliance on the car. As such, the site’s score should be ‘green’.

In relation to noise, vibration, odour and light pollution, the site scores ‘amber’ with the assessment concluding that the site will be affected by road noise from nearby main roads. We question how a definitive conclusion on this has been reached in the absence of any noise studies having been undertaken on the site. Given that built form on the site would be focused within the northernmost part of the site, adjacent to existing residential development along Ditton Lane and High Ditch Road, with additional landscaping to the south, there would be limited risk of road traffic noise affecting the site. A such, we consider this should be ‘green’.

The Strategic Highways Impact assessment identifies the site as being within Highways England Zone 3 – A14 Cambridge Northern Bypass, which has no capacity for growth. Annex 2 to the HELAA Report confirms that:

‘This assessment was based upon the capacity of junctions, as these are the pinch points on the road network which causes traffic congestion. A catchment area or zone was agreed with Highways England, as shown on the map below. These zones are drawn around each junction on the strategic road network to reflect the catchment area or roads which feed into those junctions.’

The site is located on the very southern edge of Zone 3, and on the border with Zones 1 and 4; Cambridge and the A14 East, both of which have a ‘green’ RAG score, and capacity for growth. The arbitrary approach taken fails to recognise that sites located within the outer proximities of the Zones may actually relate better in transport terms to the adjacent Zones, which have capacity for growth.

We consider that reassessment of the land east of Ditton Lane, Fen Ditton (Site Reference: 40217) shows that it represents a suitable, available and achievable site for development, and as acknowledged within the HELAA, it benefits from close proximity to a number of key services and facilities, as well as public transport links, owing to its location on the edge of Cambridge. It is also closely located to the land north of Newmarket Road, which alongside new homes will deliver community facilities and a food store, in addition to a number of additional cycleways and footways, which run along the southern boundary of the land east of Ditton Lane, and connect into the existing public right of way through the eastern part of the site.

The land east of Ditton Lane (Site Reference: 40217) falls within Parcel FD7 within the Green Belt Assessment. The majority of the area within which built form is proposed falls within an area assessed to have a ‘moderate high’ rating for release from the Green Belt, one of only three parcels within Fen Ditton assessed as such, the lowest of the harm ratings within the settlement. The remainder of parcel FD7, the majority of which is proposed as open space, is assessed as having a ‘high’ harm rating, although this parcel is combined with a parcel of land to the west of Ditton Lane. We question why the assessment fails to recognise the presence of Ditton Lane, which clearly separates the two areas both physically and visually, owing to the presence of mature trees to both sides of Ditton Lane. Neither parcel is visible from Ditton Lane, therefore there is no relationship between the two areas, which the assessment fails to recognise.

Parcel FD7’s contribution to the three Cambridge Green Belt purposes is assessed to be ‘moderate’, with the impact on the contribution of adjacent Green Belt assessed as being ‘minor-moderate’ (for the west and southern parts) and ‘minor’ for the northern part. As such, we question how the assessment could arrive at a conclusion that the overall harm of Green Belt release would be ‘high’ in the absence of any assessment of harm being greater than moderate. As such, the harm rating should be amended to ‘moderate’ to reflect the conclusions of the assessment, which would make it the most suitable parcel within Fen Ditton for release from the Green Belt.

Further, we dispute the accuracy of the conclusions that the release of land within only the north-eastern part of this parcel would still result in the removal of the settlement gap between Fen Ditton and Cambridge (Barnwell). Whilst this is true if development of the entirety of this parcel were to occur, development of part of this area would enable the separation to be maintained, which the assessment fails to recognise. The Masterplan Concept Layout accompanying this submission shows how development of the land east of Ditton Lane could be achieved whilst maintaining a sizeable area of openness to the south, therefore resulting in no merging of Fen Ditton and Cambridge (Barnwell).

As set out in our comments on Policy S/DS, we do not consider there to be sufficient certainty surrounding the proposed extension to Cambourne to justify an inclusion of 1,950 dwellings towards the housing supply within the Plan period. This is particularly as Annex I to Appendix E of the Sustainability Appraisal states in relation to growth in Cambourne, that ‘the allocation of a specific area or quantity of growth has been rejected.’ We question therefore the rationale for including 1,950 homes within the supply, and contending the Plan is capable of meeting the objectively assessed housing need.

As acknowledged by the Councils, the exact locations for the East West Rail route and station are unknown. Additionally, the timescales for the delivery are also unknown, which adds further uncertainty as to anticipated delivery of housing before 2041.

Whilst we do not disagree with Cambourne as a location for future growth, we dispute that there is sufficient certainty surrounding the delivery of a further 1,950 homes within the Plan period within Cambourne. We consider that additional sites should be identified to ensure greater certainty that the objectively assessed housing need can be met within the Plan period.

As set out in our comments on Policy S/DS, we do not consider that the Plan contains sufficient small and medium site allocations, nor does it comply with paragraph 79 of the NPPF, which states that housing should be located where it will enhance or maintain the vitality of rural communities, to promote sustainable development in rural areas. It is clear that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Paragraph E.9 of Appendix E to the Sustainability Appraisal states that ‘The Councils’ evidence shows that Greater Cambridge’s villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of Greater Cambridge’s villages.’ As set out in our comments on the SA, we dispute that the SA provides an accurate and consistent assessment of the options, with many unjustified assumptions made in relation to villages which result in an artificially negative outcome.

Paragraphs E.24 and E.25 of Appendix E to the SA state that the better served villages have been subject to site specific sustainability appraisal, identified as sites at Rural Centres, Minor Rural Centres and Group Villages. It confirms that sites at other villages were not considered as reasonable options, as they would not provide sustainable locations to allocate development.

Whilst we do not dispute this to be the case for the majority of Infill villages, there are some Infill Villages which do benefit from a greater level of facilities and services, and public transport than others, such as Shepreth, which is also located outside of the Green Belt.

Shepreth is the only Infill Village which benefits from a train station and is the location of one of only seven stations within Greater Cambridge. In addition, the settlement already benefits from a number of other facilities, services and employment opportunities. Despite its status as an Infill Village, development within Shepreth would be consistent with the stated influences of the preferred spatial strategy, including reducing climate impacts through compact development located to connect homes and jobs where active and sustainable travel can be maximised, as well as making the best use of existing and committed key sustainable transport infrastructure. It would also support a rural community to thrive and sustain services.

The land at Frog End, Shepreth (Site Reference: 40085) has been promoted by Scott Properties throughout the emerging Plan process, and represents a unique opportunity to deliver a residential-led development outside of the Green Belt and within close proximity to the train station, of a quantum which would be capable of providing significant community benefits and open space. This would include employment use, incorporating smaller units at affordable rates to support Small and Medium Enterprises, as well as start-up businesses, sustainably located to maximise the connectivity the site provides through additional pedestrian and cycle links, as shown in the accompanying Framework Masterplan. The site also provides the opportunity to include further community benefits, working closely with the Parish to ensure those reflect the needs and aspirations of the local community. There is sufficient flexibility owing to the size of the site for this to include sports, leisure, recreational and/or retail uses.

A variety of housing including older persons’ accommodation, self-build properties, as well as key worker housing would also respond to local needs in an area with excellent accessibility into Cambridge.

The site was assessed within the HELAA (reference 40085), scoring a ‘red’ for suitability and ‘green’ for availability and achievability. This is due to the site scoring ‘red’ in relation to Townscape and Landscape, noting a TPO on site, with the assessment concluding that:
‘Development would significantly alter and harm the existing character of this small rural village and could effectively double the size of Shepreth. It would be an encroachment into the countryside, incongruous and an urbanisation of the rural landscape.’

We question how the conclusions have been arrived at, in the absence of any landscape studies forming part of the Plan’s evidence base. This is particularly considering many of the sites assessed within the HELAA are greenfield, edge of settlement locations, which do not receive the same commentary in relation to encroachment into the countryside and urbanisation of the rural landscape. The site is also not within the Green Belt, therefore we consider the site to have received an unduly negative assessment against this criterion.

Further, we would highlight that development of this quantum within Shepreth, which benefits from one of only seven train stations within Greater Cambridge, would enhance the sustainability of the settlement, capable of providing benefits in addition to housing which smaller scale development would be unable to provide. As previously referenced, this includes additional community benefits which could take the form of sports, leisure, recreation and/or retail, in addition to a broad range of housing and employment uses which would respond to many different needs within the area.

The site scored ‘amber’ against a number of criteria within the assessment, which we consider to be unjustified. In relation to flood risk, the site scores ‘amber’ despite being wholly within Flood Zone 1, and with negligible areas of low risk surface water flooding, which could be suitably addressed through a sustainable urban drainage system. As such, the site should receive a ‘green’ score against this criterion.

The site scores ‘amber’ in respect of Biodiversity and Geodiversity, with the assessment incorrectly stating that the site is within a SSSI. Part of the site’s south-western boundary is adjacent to the southern part of L-Moor, Shepreth SSSI, and the assessment notes that close consultation would be required with Natural England, including assessment of increased visitor pressure on the SSSI. The assessment also confirms that there are no priority habitats within the site, although notes the presence of hedges and wooded boundaries that are likely to have ecological value. The assessment confirms that development of the site may have a detrimental impact on a designated site, or those with a regional or local protection but that impact could be reasonably mitigated or compensated.

As shown in the Framework Masterplan accompanying these representations, a considerable landscape buffer would be included between the site’s boundary with the SSSI, and the proposed areas of built form. Further, additional sizeable areas of open space would be included, providing additional and alternative recreational opportunities to the SSSI, which could reduce recreational pressure on the protected areas. The Framework Masterplan also shows proposed diverted public rights of way around the edge of L-Moor Shepreth SSSI, resulting from discussions with the Wildlife Trust, who have confirmed that directing footpaths to the edge of the SSSI (currently through the centre) would be beneficial. Scott Properties are committed to working with the Wildlife Trust to protect and enhance the SSSI, an opportunity which is unique to the land at Frog End.

In addition, and in accordance with the provisions of the Environment Act 2021, the site could deliver a biodiversity net gain in excess of 10%, which would include the retention and enhancement of the boundary features. Owing to the significant biodiversity benefits that could be delivered on this site, owing in part to its location and size, it is considered that the site should be scored ‘green’.

The site is located within 750m of the train station, which provides access into the centre of Cambridge within 12 minutes. This equates to a walking time of approximately 10 minutes, or a cycle time of three minutes, and highlights how the suitability of the land at Frog End as a location for growth.

Shepreth is closely associated with the neighbouring villages of Foxton, Barrington, Meldreth and Melbourn, all of which provide additional services and facilities accessible on foot from the site via the existing public right of way network, or by cycling. Despite this, the site scores ‘amber’ in relation to Accessibility to Services and Facilities, which we consider is inaccurate and should be ‘green’.

As demonstrated within the accompanying Access Drawing, safe and suitable vehicular access into the site can be achieved from Frog End to the south. The HELAA recognises that the proposed site is acceptable in principle, subject to detailed design, yet scores ‘amber’ in relation to both Site Access and Transport and Roads. The accompanying Masterplan Concept Layout also demonstrates that multiple footpaths and cycle links could be provided through the site, providing recreational opportunities and providing sustainable transport options. As such, it is considered the site should score ‘green’ for these elements.

As shown within the accompanying Framework Masterplan, the site’s proximity to the railway has been factored into the design, with proposed open space and landscaping providing a considerable buffer between the proposed built form and the railway line. In addition, there are no issues on site in relation to light pollution or odour. As such, appropriate and effective mitigation can be provided on the site, therefore a score of ‘green’ is appropriate.

In light of the above, it is considered that Shepreth should be considered as a sustainable location for growth, in accordance with the aims of the Plan and the NPPF. The site represents a unique opportunity to deliver significant benefits through new housing, employment and community facilities, owing to its location and size, which would not be achievable on a smaller site or with a smaller quantum of development.

We do not consider that the Plan contains sufficient small and medium site allocations, nor does it comply with paragraph 79 of the NPPF. Whilst we accept that the majority of Infill Villages do not provide sustainable locations to allocate development, we do consider that this overlooks a number of Infill Villages which are distinguished from the rest by reason of their proximity to other, higher tier settlements, such as Kneesworth.

Kneesworth is within the Parish of Bassingbourn-cum-Kneesworth and physically connected to Bassingbourn, which is classified as a Minor Rural Centre and recognised within the adopted South Cambridge Local Plan as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire. These services and facilities are highly accessible to Kneesworth, including the land to the south of The Causeway, Kneesworth (Site Reference: 40216), which has been promoted by Scott Properties for residential development throughout the emerging Plan process.

The site received an ‘amber’ score for suitability within the HELAA, and was scored ‘green’ for both availability and achievability. Having achieved more ‘green’ scores for many aspects of the suitability assessment, it also represents the most suitable site within Bassingbourn-Cum-Kneesworth. As noted in our comments on Policy S/SH, we consider that Bassingbourn and Kneesworth should be recognised as a single settlement for the purposes of the hierarchy, owing to their close proximity and functional relationship, both of which fall within the Parish of Bassingbourn cum Kneesworth.

The site scores ‘amber’ in relation to Accessibility to Services and Facilities. Whilst this recognises that the site is less than or equal to 450m in distance from public transport, these are actually within 200m of the site both to the east and the west of the site, providing regular services to the surrounding villages and to Royston, the centre of which (also the location of the train station) is approximately 3km from the site.

To the west of the site, Bassingbourn is accessible to pedestrians via a continuous footway along The Causeway. As such, it is considered that the sustainability of the site is not accurately reflected within the HELAA, and should have been scored ‘green’.

The site also received an ‘amber’ score in relation to Flood Risk, due to the southern-most part being within Flood Zone 2. As shown within the Masterplan Concept Layout accompanying this submission, this area is proposed as open space, with built form proposed only within the areas of the site with Flood Zone 1. As such, the site does not present any issues with flood risk, and the assessment should be amended to ‘green’.

With regards to Transport and Roads, the site notes that the site is potentially part of a cluster, and may require a cumulative assessment. The site has consistently been promoted by Scott Properties in its own right, and not in conjunction with any other site. Further, this conclusion contradicts with the methodology set out in Annex 1 to the HELAA, which states that ‘sites were assessed individually with no account given to cumulative impacts/constraints of combining them with other sites being tested. If sites near to or adjoining each other are selected for allocation cumulative impacts will be considered during the preparation of the Local Plan.’ As such, and in accordance with the methodology, such conclusions are beyond the scope of the HELAA and in this instance have resulted in an unduly negative assessment of the site, which should be amended to ‘green’.

As recognised within the site’s assessment in relation to Noise, Vibration, Odour and Light Pollution, the site is capable of being developed to provide healthy internal and external environments, therefore should have scored ‘green’. There are no such constraints on the site, which would be developed to reflect the existing pattern and orientation of existing dwellings fronting The Causeway.

More detailed consideration of the settlements of Shepreth and Kneesworth demonstrates that these locations would be suitable for growth, which would be consistent with the aims of the NPPF and the Plan in supporting the vitality of rural settlements. Due to the approach taken, which automatically ruled out any Infill Village from being considered as part of this process, these areas have been unduly overlooked. It does not appear, however, that a consistent approach has been taken in relation to this.

As shown in Table 4.23 of the SA, sites outside of Rural Centres, Minor Rural Centres and Group Villages have been subject to SA appraisal, such as 29 Station Road in Shepreth. We are unclear why this particular site was assessed within the SA, to the exclusion of any others within Shepreth or other Infill Villages. Further, we note that the HELAA states in relation to Landscape and Townscape in the assessment of 29 Station Road, that ‘due to the proximity of the railway line, it is recommended that only employment or industrial uses are considered.’ Despite this, the site has been subject to assessment for residential use within the SA. Whilst we acknowledge that this is not a proposed allocation within the Plan, we highlight this point as a further example of inconsistencies within the evidence base, and, more concerningly, an example of where the conclusions of the HELAA appear to have been overlooked.

As set out in our comments on the SA, we consider that the spatial distribution fails to direct sufficient growth to villages, and therefore does not fit with the contention that this was strongly influenced by the desire to support rural communities to thrive and sustain services.

As set out in our comments on the SA, we consider that the spatial distribution fails to direct sufficient growth to villages, and therefore does not fit with the contention that this was strongly influenced by the desire to support rural communities to thrive and sustain services.

Comberton is a Minor Rural Centre, recognised within the South Cambridgeshire Local Plan as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire.

Scott Properties has promoted the land to the west of South Street, Comberton (Site Reference: 40310) through the emerging Plan process for residential development. The site received a ‘red’ score for suitability, and a ‘green’ score for both availability and achievability.

The site scores ‘red’ against Site Access, with the assessment concluding that there is no possibility of creating a safe access. This conclusion is disputed. As shown within the Masterplan Concept Layout accompanying the submission, Scott Properties has identified a number of potential access points into the site, which would provide safe and suitable access onto a public highway. As such, we consider this should be amended to ‘amber’ to reflect the situation.

It also scores ‘red’ against Strategic Highways Impact. We would reiterate our earlier comments on this part of the site assessment, which draws arbitrary zones that assume all traffic will use the specified junction. Further, Comberton is also located within the north-western corner of Zone 8, within close proximity to Zones 9 and 10 which are noted as having capacity for growth. Additionally, we note from Appendix 2 to the HELAA that a ‘red’ score does not rule out sites at this stage, as development proposals within these zones will need to demonstrate no net increase in vehicle trips on the strategic road network. A red score, regardless of whether this is possible, has acted to rule out sites from consideration for allocation by scoring them ‘red’ for suitability. As such, we consider the sites in the zones identified as having no capacity for growth should be scored ‘amber’ to reflect that this should not rule out development at this stage.

In relation to Flood Risk, the site is located wholly within Flood Zone 1, with only a small proportion of the site area at risk from surface water flooding. Given the limited extent of the area affected, and the ability to effectively mitigate any risk through a sustainable urban drainage strategy, we consider this assessment should be amended to ‘green’.

The site scores ‘amber’ in relation to Landscape and Townscape. We question why views from neighbouring properties into the site warrants a score of ‘amber’, particularly when this is the case for the majority of sites close to a settlement edge and has not been noted in respect of any other site regardless of its proximity to other properties. The inclusion of landscape buffers is also provided as a mitigation measure, although we question what evidence exists to support the requirement for a 15m buffer between the site and existing properties, particularly when development of the site would require minimum back-to-back distances and good design principles to be observed. Given there would be a design solution to mitigate any potential concerns around the site’s relationship to surrounding uses, we consider that the site should be scored ‘green’.

In relation to Biodiversity and Geodiversity, the site scores ‘amber’, noting the requirement for an assessment of increased visitor pressure on the Eversden and Wimpole Woods SAC, which is a considerable distance from the site. The assessment notes that the site may have a detrimental impact on a designated site, but any impact could be reasonably mitigated or compensated. As such, we are unclear why the assessment does not score ‘green’ given there is a satisfactory solution should any mitigation be required (which the assessment assumes but is not confirmed).

The site scores ‘amber’ in relation to Historic Environment, being located within 100m of both a Listed Asset and a Conservation Area. It is clear from the Village Inset Map for Comberton that the main Conservation Area is physically separated from the site by considerable intervening built form.
The secondary Conservation Area, located to the east of South Street and to the south-east of the site is also separated from the site by intervening vegetation, which visually separates the site from this area. The closest listed building is also adjacent to South Street to the east of the site, and is separated from the site by built form and a considerable landscaping which screens the asset from the site.

As such, we question how the site could have any impact on either, and the assessment should be amended to ‘green’ to more accurately reflect the situation.

We would highlight the site’s ‘green’ score in relation to Accessibility to Facilities and Services. Development of the site would fully accord with the Council’s objectives to located development where climate change could be mitigated, close to existing facilities, services and public transport.

The Green Belt assessment concluded the harm rating to be ‘moderate’ for the site (parcel CO10), one of the lower scoring parcels surrounding the settlement.

As set out in our comments on Policy S/DS, we do not consider that the Sustainability Appraisal (SA) provides a consistent and thorough assessment of the options for growth, particularly in relation to Option 5 – dispersal – villages.

We consider that the SA has made a number of broad assumptions in relation to villages, which are not applicable to all, resulting in an overly negative score which has unjustly influenced the decision to distribute limited growth to villages.

In relation to SA objective 1: Housing, we note the conclusions as to the uncertainty with locating homes within new settlements, as this may not result in the necessary range of housing types or sufficient housing to come forward until later in the Plan period. We echo this concern, as set out in our comments on various proposed policies, that there is a heavy reliance upon sites which will not be capable of delivery within the short-medium term period of the Plan, with a concerning absence of sufficient site allocations within this period.

Option 5 – Dispersal – villages is assessed as mixed significant negative and minor positive effects likely in relation to SA objective 2: Access to services and facilities. The assessment states at paragraph 4.37 that this option performs least well as it is most likely to put pressure on existing services and facilities and result in development that is less likely to provide new services and facilities, whilst being more distant from larger
centres. We would highlight that this assumption does not apply to all villages within the settlement, many of which benefit from day-to-day facilities and services, and also transport links which provide sustainable access to additional facilities. We would also highlight the conclusions in paragraph 4.32, which notes the uncertainty of the timings of the railway station and public transport improvements at Cambourne, which would leave residents with less access to services and facilities further afield. As such, we dispute the more positive assessment for the preferred option compared to village locations, which does not reflect the commentary in the SA.

The assessment of village locations which is subject to a number of unjustified assumptions and fails to recognise the sustainability of many villages. These assumptions are also made in relation to SA objective 3: Social inclusion and equalities, resulting in a conclusion that uncertain mixed minor effects are likely. Again, in relation to the preferred option, paragraph 4.38 confirms that many of the proposed services and facilities are not likely to be provided during the Plan period, in addition to the proposed rail route and public transport improvements. The SA notes in paragraph 4.40 that development may help to support existing services and facilities at villages, providing this is distributed between a number of villages.

The SA conclusions as to SA objective 5 – Biodiversity and geodiversity, predicts significant negative uncertain effects for option 5 (dispersal – villages), based on the assumption that it is likely that development would take place on greenfield land and may intersect with or be adjacent to an ecological designation, and mitigation will be difficult to achieve due to the likely smaller scale of development.

Paragraph 4.60 states that ‘as many of the villages across Greater Cambridge contain or are located within close proximity to designated and non-designated biodiversity assets, and development is likely to come forward on greenfield land, both options could lead to loss of biodiversity, depending on the exact location of village growth.’ Again, this is a broad assumption resulting in a negative score, despite this not being applicable to all villages. It is noted that paragraph 4.59 confirms that Cambourne contains a number of designated and non-designated habitats, despite this concludes that minor positive effects are likely for the preferred option. The assessment also states in the same paragraph that ‘it is noted that greenfield sites themselves are not always of particular ecological value, but they can provide supporting habitat for nearby more sensitive locations.’ However, this is not recognised in relation to villages, where instead the assumption is made that greenfield development could lead to the loss of biodiversity. This inconsistency has resulted in an artificially negative score for villages, with the SA appearing to place artificial significant on greenfield land around village locations but not at the preferred option. The SA seeks to justify the approach by contending that larger developments are able to incorporate green infrastructure and ecological networks, however, all sites will be required to receive a net biodiversity gain of at least 10% as required within the Environment Act 2021, so it is not considered that the SA can justify that significant negative effects on biodiversity and geodiversity are likely at villages and in no other spatial options.

Option 5 is also the least performing option in relation to SA objective 6: landscape and townscape. The conclusions in paragraph 4.73 do not support this assessment, however, stating that this option arguably performs best, as more dispersed development is less likely to lead to significant landscape change. Again, this produces an artificially negative assessment and downplays the suitability of villages for growth.

In relation to SA objective 8: Efficient use of land, uncertain significant negative effects are perceived likely for option 5. Paragraph 4.89 states that this ‘performs least well as this option includes development at a broad range of rural locations, so it is likely that development will take place on greenfield land, which has greater potential to be Grade 1, 2 or 3 agricultural land.’ We would highlight the confirmation in paragraph 4.84 that development around Cambourne and the surrounding area would also result in the loss of Grade 1, 2 and/or Grade 3 land, and although is combined with brownfield locations, it is as yet unknown the grade of land that would be lost to development around Cambourne, as no specific sites have been identified.

In relation to SA objective 11: Adaptation to climate change, the SA concludes that the preferred option is capable of mitigating any flood risk (despite no specific sites at Cambourne having been identified), whereas this assumption is not applied to any other scenario. It also assumes that due to the scale of development, Cambourne would be expected to provide new green space, which could incorporate sustainable drainage systems and build climate resilience in the area. Again, this assumption is not applied to any other option, despite sites being required to demonstrate that development does not increase flood risk elsewhere within the NPPF. Other sites would also be required to provide open space, this is not just limited to larger sites, as well as sustainable urban drainage systems in accordance with the NPPF. The SA states at paragraph 4.113 that the Water Study Supplement Study (2021) concludes the least preferable option is option 5, but no reasons are provided.

Option 5 performs least well in relation to SA objective 12: Climate change mitigation, predicted to have significant negative effects, due to it being likely to lead to development with high levels of dependency on the private car. This assumption fails to recognise that many villages within Greater Cambridge contain day-to-day facilities and services which would reduce to need to travel further afield, as well as many which benefit from good public transport links. Despite this, the SA also makes the unfounded general assumption that most villages are not well connected via public transport (particularly regarding the frequency of services) than larger centres. In relation to the preferred option, paragraph 4.118 comments that a substantial number of Cambourne residents commute to Cambridge to work, stating that ‘an increase in development at Cambourne is expected to result in an increase in carbon emissions, although this will be minimised by public transport improvements.’ Despite this, the potential to incorporate low carbon and energy efficient design and designing in walking and cycling are considered to be positives. This is true of all development, not just at the preferred option, and we note that Cambourne is located a considerable distance from Cambridge which would preclude cycling or walking to work.

We would highlight that some village locations are much closer to Cambridge and would offer the opportunity to walk and cycle to work, with others being within close proximity with one another and sharing facilities and services accessible to both by non-car means. As such, the SA is wrong to assume significant negative effects likely in relation to this objective. Further, it overlooks the Government’s commitment to ban the sale of new diesel and petrol engines from 2030, and the rising prevalence of electric vehicles and facilitating infrastructure within the UK.

We echo our comments in relation to SA objective 13: Air pollution, whereby option 5 is the least preferred due to it being likely to lead to development with high levels of dependency on the private car.

In relation to SA objective 15: Employment, we question how the preferred option would result in likely mixed minor effects, despite acknowledgement in paragraph 4.145 that a large number of employment opportunities will not come forward until after the Plan period. Option 5 again performs least well due to the assumption that existing centres of employment are likely to be less accessible to development under this option. This fails to acknowledge the proximity of some village locations to employment opportunities and/or decent public transport links, in addition to sites which are of the quantum able to deliver employment opportunities alongside new housing.

In light of the above, we do not support the suggestion that the Council’s evidence shows that Greater Cambridge’s villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of Greater Cambridge’s villages (paragraph E.9 of Appendix E to the SA). We do not consider that the SA has been undertaken consistently and accurately, nor does it provide a solid foundation on which to support the proposed spatial distribution within Greater Cambridge, which seeks to allocate less than 3% of growth to villages within Greater Cambridge. The approach taken is inconsistent with the NPPF, and the Councils' own objectives to support rural communities to thrive and sustain services.