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Critique of the Interim Sustainability Appraisal
Issues and Options 2 Part 1Cambridge South ConsortiumBroad Location 5 – Land to the south of Addenbrooke’s RoadFebruary 2013
Cambridge South ConsortiumBroad Location 5 – Land to the south of Addenbrooke’s RoadFebruary 2013
Quality Assurance
Site name: Broad Location 5 – Land to the south of Addenbrooke’s Road
Client name: Cambridge South Consortium
Type of report: Critique of the Interim Sustainability Appraisal Issues and Options 2 Part 1
Prepared by: Helen Thompson MLI MRTPI AIEMA
Signed
Date 18 February 2013
Reviewed by: Karen Beech BSc (Hons) MSc MRTPI
Signed
Date 18 February 2013
Cambridge South ConsortiumBroad Location 5 – Land to the south of Addenbrooke’s RoadFebruary 2013
Table of Contents
Executive Summary ................................................................................................................................... 1
1 Introduction ........................................................................................................................................ 2
2 Joint Working and Duty to Co-operate ................................................................................................ 4
3 Concerns about SA process ............................................................................................................... 5
4 Green Belt.......................................................................................................................................... 7
5 Green Belt versus Sustainability Objectives ........................................................................................ 9
6 Site Assessment Pro-forma for Edge of Cambridge Sites ................................................................. 11
7 Summary Assessment of GB sites ................................................................................................... 13
8 Cambridge South and the Emerging Plans ....................................................................................... 14
9 Conclusion ....................................................................................................................................... 16
Cambridge South ConsortiumBroad Location 5 – Land to the south of Addenbrooke’s RoadFebruary 2013
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Executive Summary
The following points are made:
The Localism Act and the NPPF require Councils to work together on planning issues that
cross administrative boundaries. The Councils should therefore work together across the
whole sequence of the Development Strategy from the most sustainable to the least
sustainable options as any decisions they make on constraining development on the edge
of Cambridge will have repercussions on options lower in the sequence;
The Duty to Co-operate should also include the County Council, especially as Highway
Authority. If development is constrained on the edge of Cambridge to the locations lower
in the sustainable sequence including new settlements, the requirements for new
infrastructure are likely to be significant;
SA has not been undertaken on the Development Sequence, or the effects of the
proposed constraint on the edge of Cambridge. The Councils are not in compliance with
the SEA Directive as they have not tested the environmental effects of the Plan nor the
alternatives;
The predicted environmental effects of the Plan including the alternatives are not
presented to the public or decision makers and not therefore in compliance with the SEA
Directive;
As the Plan currently stands, the Councils are saying that the Green Belt is more important
than all the other Sustainability Topics and Objectives together without understanding the
effects on sustainability issues;
The Plan does not comply with the NPPF in that it is not delivering sustainable
development; and
Sites on the edge of Cambridge and specifically Broad Location 5 should not be rejected
so that development can be delivered in the most sustainable sequence of development
and the Plan made sound.
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1 Introduction
1.1 Bidwells has been instructed by the Cambridge South Consortium (CSC) to review the
Sustainability Appraisals associated with the second stage of the Issues and Options consultation
of Cambridge City Council and South Cambridgeshire District Council as part of their promotion of
Broad Location 5 – Land south of Addenbrooke's Road. The site will be referred to as Cambridge
South (CS).
1.2 Strategic Environmental Assessment or SEA Directive 2001/42/EC applies to all plans and
programmes which fall within the scope of the Directive. The Environmental Assessment of Plans
and Programmes Regulations 2004 (Statutory Instrument 2004 N0. 1633) transpose the Directive
into UK law.
1.3 Sustainability Appraisal (SA) according to the Directive and Regulations is integral to plan making
and ensures that the environmental, economic and social effects of a plan are assessed and that
reasonable alternatives are considered.
1.4 The first stage in the SA process is to establish the scope. Both Councils have undertaken a
Scoping Report which sets the baseline and identifies the key Sustainability Topics and Objectives
which each Council considers important to its plan making and which are used to test policy and
site options.
1.5 The National Planning Policy Framework (NPPF) states that the purpose of the planning system is
to contribute to the achievement of sustainable development and that there are three dimensions
or roles to sustainable development: an economic role; a social role; and an environmental role.
1.6 Paragraph 150 of the NPPF states that "Local Plans are the key to delivering sustainable
development that reflects the vision and aspirations of local communities" and paragraph 152 "that
Local Plans must be prepared with the objective of contributing to the achievement of sustainable
development".
1.7 NPPF paragraph 152 states that "local planning authorities should seek opportunities to achieve
each of the economic, social and environmental dimensions of sustainable development and net
gains across all three".
1.8 NPPF paragraph 158 states that "each local planning authority should ensure that the Local Plan is
based on adequate, up-to-date and relevant evidence about the economic, social and
environmental characteristics and prospects of the area".
1.9 The Plan should be justified in being the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence (NPPF paragraph 182).
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1.10 The Issues and Options 2 (stage 2) is the current stage of plan making for both authorities. This
critique will focus on Part 1 of stage 2 which is a joint consultation by both authorities addressing
the development strategy for the sub-region, sites at the fringe of Cambridge in the Green Belt, and
options for sub-regional sporting, cultural and community facilities. In particular the development
strategy and sites at the fringe of Cambridge in the Green Belt will be considered here.
1.11 A joint Interim Sustainability Appraisal (ISA) has been prepared by the Councils to accompany the
current consultation on Part 1.
1.12 The current development strategy established by the adopted Cambridgeshire and Peterborough
Structure Plan and subsequently carried forward by both local authorities aims to locate
development in the following sequence:
within the urban area of Cambridge;
on the edge of Cambridge;
in the new town of Northstowe; and
in the market towns and better served villages in South Cambridgeshire.
1.13 Each authority has a separate Part 2 consultation addressing site options and other district specific
issues with an accompanying SA and these have also been considered.
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2 Joint Working and Duty to Co-operate
2.1 The Localism Act and the NPPF have introduced a requirement for Councils to work together on
planning issues that cross administrative boundaries. It requires Councils to engage constructively
and actively and on an on-going basis on strategic matters regarding sustainable development or
use of land that has or would have a significant impact on at least two planning areas.
2.2 The Councils have decided to prepare separate Local Plans for Cambridge and South
Cambridgeshire, but are undertaking a joint consultation on the development strategy as it affects
the edge of Cambridge sites as well as the Sub-Regional Sporting, Cultural and Community
Facilities.
2.3 We are concerned that the Councils are undertaking a myopic decision making process which
does not look at the wider implications of restricting development on the second tier of the
sequence of sustainable development locations.
2.4 The edge of Cambridge sites are the lowest tier of the sequence as it relates to CCC but growth is
still needed in Cambridge. For SCDC, however, the edge of Cambridge is the highest tier in the
development sequence.
2.5 Restricting development on the edge of Cambridge has direct and severe consequences for both
Cambridge, South Cambridgeshire and the County Council specifically the Highway Authority.
2.6 Retreating to the previous development strategy prior to 1999, with a tightly drawn Green Belt and
development away from jobs, there will be consequences of pollution, congestion, the economy
and quality of life issues with people spending hours commuting to and from their work place.
2.7 The consequences for South Cambridgeshire are that development will have to be provided in
much less sustainable locations away from jobs and with likely long lead-in times and significant
infrastructure requirements in new settlements. It is unlikely that South Cambridgeshire will be
able to fulfil the development need in the Plan period if they follow this strategy.
2.8 The Duty to Co-operate should extend through the full sequence of the development strategy with
a SA undertaken so that the consequences of restricting development on the edge of Cambridge
can be considered in entirety.
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3 Concerns about SA process
3.1 Our overall and major concern is that neither jointly nor separately have the local authorities
undertaken SA on the current development strategy nor, most importantly, the consequences of
the departure from the strategy due to constraining sites on the edge of Cambridge.
3.2 If an SA was undertaken on the current development strategy it would be clearly seen that edge of
Cambridge sites would rightly be the second tier of the sustainable development sequence
supporting both CCC and SCDC in their Sustainability Topics and Objectives.
3.3 Allowing only very limited development on the edge of Cambridge will force development to the
lower tiers of the sustainable development sequence; namely in South Cambridgeshire to new
settlements and better served villages.
3.4 The Cambridge and South Cambridgeshire Sustainable Development Strategy Review (November
2012) is the closest the options in the development strategy have come to being assessed in terms
of sustainability issues. It clearly shows that the edge of Cambridge sites are considerably more
sustainable overall and specifically in terms of the economy, housing and transport than locations
lower in the development sequence. It is also acknowledged in this publication that the
deliverability and viability of edge of Cambridge sites is more sustainable than the other options
lower in the sequence. The Sustainable Development Sequence Matrix produced as part of the
November 2012 Review is reproduced here in Figure 1.
3.5 Neither CCC nor SCDC have produced evidence which underpins their decision to depart from the
most sustainable sequence of development by restricting land released for development on the
edge of Cambridge. There is no evidence of the effects on the economy, on social issues, nor on
environmental issues such as the impacts of vehicle emissions, energy, congestion and the
impacts on climate change. Under these circumstances this major decision can not be considered
objectively.
3.6 The Stage 2 Part 1 ISA is clear that the decision to restrict development at the edge of Cambridge
is critical. The Councils have drawn the conclusion that Green Belt issues are more important than
all the other Sustainability Objectives and Topics together without knowing the full implications of
their decision. Restricting development on the edge of Cambridge will have cumulative adverse
environmental, social and economic consequences which will increase over time so that the
adverse impacts will be compounded.
3.7 Informed judgement on the appropriate balance between protecting land on the edge of Cambridge
which is currently Green Belt, and delivering development away from Cambridge in new
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settlements and better served villages can not, and should not, be made under such
circumstances.
3.8 The SA therefore fails to discharge the requirements of the Strategic Environmental Assessment
Directive as the environmental, economic and social effects of the plan are not assessed and
reasonable alternatives have not been considered. Consequently the information is not available
to the decision makers or the public.
3.9 This means that the SA so far undertaken fails the SEA Directive on two counts:
preparing an Environmental Report of the likely significant effects of the draft plan and
reasonable alternatives; and
carrying out properly informed consultation on the draft plan.
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4 Green Belt
4.1 Currently the Plan as it stands has determined that Green Belt considerations override all the
Sustainability Topics and Objectives the Councils have separately identified as important in their
plan making.
4.2 The DETR 1998 'Planning for Sustainable Development: Towards Better Practice' stated that 'there
may be exceptional cases … where releasing Green Belt land would offer a more sustainable
solution than greenfield development elsewhere'.
4.3 The National Planning Policy Framework (NPPF) states in paragraph 83 that "once established,
Green Belt boundaries should only be altered in exceptional circumstances, through the
preparation or review of the Local Plan. At that time, authorities should consider the Green Belt
boundaries having regard to their intended permanence in the long term, so that they should be
capable of enduring beyond the plan period".
4.4 The exceptional circumstance for Green Belt review is to deliver development, including
employment and affordable homes, high in the sequence of sustainable locations which are
deliverable and not likely to require major infrastructure.
4.5 Paragraph 84 of the NPPF states that "when reviewing Green Belt boundaries local planning
authorities should take account of the need to promote sustainable patterns of development. They
should consider the consequences for sustainable development of channelling development
towards urban areas inside the Green Belt boundary, towards towns and villages inset within the
Green Belt or towards locations beyond the outer Green Belt boundary".
4.6 Paragraph 85 continues "when defining Green Belt boundaries local planning authorities should
(amongst others): ensure consistency with the Local Plan strategy for meeting identified
requirements for sustainable development".
4.7 The Councils have jointly undertaken a review of the Green Belt, the 2012 Inner Green Belt
Boundary Study December 2012 according to how land supports the purpose of including land
within the Green Belt. They claim that the land around Cambridge has increased value for Green
Belt purposes and have concluded that it is not appropriate at this time to consider large Green
Belt releases on the edge of Cambridge that would cause significant harm to the Green Belt. We
do not concur with the Councils' perception that the land on the edge of Cambridge has an
increased value for Green Belt purposes as outlined in our Green Belt Critique submitted with the
representations.
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4.8 The Councils' review indicates that the majority of land reviewed in the 2002 Inner Green Belt
Boundary Study is of Very High level of significance to the purpose of the Green Belt.
4.9 We consider the methodology is based on a false premise as outlined in the submitted information
regarding Green Belt issues. There is an exceptional need to alter the Green Belt and land should
be found on the edge of Cambridge which can deliver sustainable development.
4.10 The Councils should be considering sustainability issues in their approach to a Green Belt review
as required by the NPPF and SEA Directive.
4.11 We also conclude that within the Councils' methodology the consideration of significance to the
purpose of the Green Belt is flawed in that it is based on large areas of land with the worst case
taken for any part of the area within that parcel of land to the total area thereby reflecting the 'worst
case scenario' over the whole tract of land. This skews the findings toward a higher significance
over large areas when this is not the actual case. The methodology is not refined enough to
undertake a proper and relevant review of the Green Belt as it is now.
4.12 It is unsound to make important decisions such as restraining development on the second tier of
the sustainable development sequence on such flawed methodology. The review of the Green Belt
should take into account sustainability issues.
4.13 The Councils' consideration of the Green Belt does not take account of the emerging masterplan
for Cambridge South which will deliver a development which would include significant tracts of
open space which would protect and enhance the setting of Cambridge as a compact and historic
setting and open up access to the river for the first time.
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5 Green Belt versus Sustainability Objectives
5.1 It is not clear how Green Belt issues have been factored in to the assessment, or why Green Belt
issues have been weighted over and above all the other Sustainability Topics and Objectives the
respective Councils have identified as important for the preparation of their plans. All through the
preparation of the Local Plan, the Councils concede that development on the edge of Cambridge is
second in the sequence of sustainable development. It is then abandoned for reasons of
'protecting the Green Belt' the Councils claim.
5.2 The Councils have not undertaken a SA of the current Development Strategy, and most
importantly, have not undertaken a SA of their proposed departure from this strategy. The
Councils admit that the current development strategy is the most sustainable and yet they have no
idea of the consequences of largely deleting the second best location for development in the
sequence. The Councils expect a meaningful consultation and engagement without an
understanding of the consequences of them coming to a view on whether there are specific areas
of land that could be considered for release from the Green Belt and developed in a most
sustainable way.
5.3 The Councils are effectively saying that the levels of significance to the Green Belt which they have
determined (even though we have shown it is based on a flawed methodology which is not detailed
enough for current circumstances) is more important than all the other Sustainability Topics and
Objectives put together.
5.4 To overcome the discrepancies in the SA process the Council needs to:
undertake SA on the development strategy;
undertake SA on the proposed departure from the most sustainable development strategy
reviewing the effects on all of the Sustainability Topics and Objectives the Councils
consider important for their plan;
undertake a comprehensive Green Belt review which will deliver the exceptional need for
development on the edge of Cambridge by introducing sustainability criteria into the
review;
report on the findings of the SA by presenting the predicted effects of the plan and
alternatives; and
take account of the SA report and opinions expressed in their determination of the Plan.
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5.5 We consider that development can take place on the Cambridge South site within an area of the
current Green Belt without affecting the attractive setting of Cambridge and at the same time
providing employment opportunities and residential development where it is needed. If the
Councils continue with their proposed development strategy, growth will continue in a very
unsustainable way.
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6 Site Assessment Pro-forma for Edge of Cambridge Sites
6.1 The Councils have adopted a Pro-forma to assess sites on the edge of Cambridge.
6.2 At Appendix 1 of the Issues and Options 2 Part 1 ISA, the Pro-forma is shown with the links to
Cambridge SA Topics and South Cambridgeshire Sustainability Objectives.
6.3 Whilst this purports to be a SA, many of the criteria are not SA matters. The Councils
acknowledge this. Some of the criteria are not SA topics for CCC, others are not SA topics for
SCDC. It is conceded here that with joint working there will be a dovetailing of the Sustainability
Topics and Objectives.
6.4 However, it is clear that some criteria are not an SA matter for either Council and should therefore
not be used as part of the SA.
6.5 The criteria on the Green Belt are purportedly linked to Cambridge SA topic: Landscape,
Townscape and Cultural Heritage and to SCDC Sustainability Objective: 7. Maintain and enhance
the diversity and distinctiveness of landscape and townscape character.
6.6 The purpose of the Green Belt however is not to protect the landscape. Whilst the NPPF is silent,
PPG2: Green Belt in paragraph 1.7 states that "although Green Belts often contain areas of
attractive landscape, the quality of the landscape is not relevant to the inclusion of land within a
Green Belt or to its continued protection". This must still be the case as Green Belts contain a
variety of landscapes.
6.7 The Green Belt criteria utilised in the Pro forma are not therefore linked to a CCC Sustainability
Topic, or SCDC Sustainability Objective as Green Belt is not a landscape issues and should not be
used as part of the SA.
6.8 In addition, many of the Green Belt criteria listed in the Pro forma are not Green Belt but purely
landscape issues. For example, important views, soft green edge to the City and distinctive urban
edges are not Green Belt issues and should not be used as Green Belt issues in the SA.
6.9 At page 31 of Appendix 1 of the ISA, the methodology for drawing conclusions is set out.
However, it is not clear whether the assessment of the criteria which are not linked to any SA
Topics or Sustainability Objectives are included to identify sustainability issues.
6.10 The significance to the Green Belt is examined through a Green Belt review. Including Green Belt
issues in the SA means that the importance to Green Belt is double counted. Green Belt is not an
SA matter. Paragraph 167 of the NPPF states that "assessments should be proportionate, and
Cambridge South ConsortiumBroad Location 5 – Land to the south of Addenbrooke’s RoadFebruary 2013
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should not repeat policy assessment that has already been undertaken". Double counting in this
way skews the assessment away from edge of Cambridge sites.
6.11 Some of the factors which Cambridge South scores poorly on do not take into account either the
emerging proposals including the employment aspect of the development, that the quantum of
development proposed will generate its own services and facilities and its close proximity to the
Park and Ride site.
6.12 Cambridge South scores badly on matters important to the special character and setting of
Cambridge, the merging of communities into one another and the quality of the setting of
Cambridge.
6.13 The emerging masterplan will retain a green foreground setting to the City which will offset the
potential harm the Councils perceive. The merging of communities is not an issue as the proposed
development will not give the perception of communities merging.
6.14 The current edge is perceived to be soft and green. However, the new development currently
under construction will change the edge considerably. The development of Cambridge South
provides an opportunity to benefit the edge.
6.15 It is considered that the character of Great Shelford and Hauxton would be affected. However, the
site is quite separate from these villages and will not affect them if developed.
6.16 The Councils consider the landscape has a strong rural character, however the reality is that the
land lies between the M11 and the new Addenbrooke's relief road which bring urbanising factors to
the landscape so that it no longer has a strong rural character.
6.17 The Sustainable Transport Criteria are marked down. However, the site will generate its own
delivery of public transport and cycle routes will be provided. No account is taken of the close
proximity of the Park and Ride.
6.18 Cambridge South is marked down because of its proximity to the M11 AQMA. However, providing
development in a sustainable location could reduce air pollution over the longer term by providing a
science park on the edge of Cambridge thereby reducing traffic flow through the City and by
providing housing close to jobs.
6.19 Lastly the site is marked down because it would lead to the loss of the best and most versatile
agricultural land and not make use of previously developed land. This is the same for the other
edge of Cambridge sites and new settlements.
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7 Summary Assessment of GB sites
7.1 Appendix 2 of the Issues part 1 shows a map of the rejected Green Belt sites and the Summary
Assessment of the Green Belt sites.
7.2 Appendix 2 of CCC Interim SA Report 2 Issues and Options 2 Site Options January 2013 listing the
relationship between Sustainability Issues and the Site Appraisal Criteria for Fringe Sites in Table 2
suggests that for the SA issue of Landscape Townscape and Cultural Heritage there is a Site
Appraisal Criterion for the overall effect of development on the Green Belt. Recognising the role of
the Green Belt in maintaining the character of the City and the quality of its historic setting is an
important consideration, but so too is the consequence of not developing on the edge of
Cambridge sites.
7.3 The relationship between the SA, Sustainability Topics and Sustainability Objectives with the Site
Criteria is blurred. ISA 2 Appendix 3 Site Appraisal Criteria and Decision Rules Table 4 Fringe
Sites indicates one site appraisal criterion for the Green Belt: "What is the overall effect of
development on the Green Belt?" However the Green Belt Site and Sustainability Appraisal
Assessment Pro-forma lists eleven Green Belt criteria with performance indicators. It is not clear
how these are related, nor is it shown in Appendix 3 Summary Assessment of Green Belt sites
which appear in the Issues and Options 2: Part 1.
7.4 This uncertainty of the relationship between the individual Council's appraisal and the Joint
Working on the edge of Cambridge sites is not helpful for the consultation.
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8 Cambridge South and the Emerging Plans
8.1 Cambridge South can be developed in such a way as would provide a green foreground setting to
the City on this major approach.
8.2 The Summary Assessment in Appendix 3 of the Issues and Options 2 Part 1 does not take into
account the provision of a Science Park on the edge of Cambridge and the residential development
is sizeable enough to create its own momentum with regard to the provision of community facilities
and services.
8.3 No consideration is taken of Broad Location 5's close proximity to the Park and Ride site and thus
is extremely well placed in terms of public transport access and opportunities within Cambridge
and should not be given a red indicator in the Summary Assessment of Green Belt Sites Issues
and Options 2: Part 1 Appendix 3.
8.4 Very important is the acknowledgement that Broad Location 5 is an extremely good site in terms of
transport and pollution for SCDC. This is the crux of the matter. The edge of Cambridge sites are
the most sustainable location in the sequence for SCDC. The new settlement sites were
compared alongside the edge of Cambridge sites by SCDC against its Sustainability Objectives in
the Initial Sustainability Appraisal Report July 2012. The edge of Cambridge sites were assessed
as undoubtedly more sustainable. This document notes that "in terms of sustainable transport this
option has the best potential to support journeys by sustainable modes, by providing homes closest
to the largest concentration of jobs (Cambridge)".
8.5 There is no consideration on the effects on the economy if sites on the edge of Cambridge are not
developed.
8.6 All these aspects of sustainability have not been assessed. The edge of Cambridge is the most
sustainable location for development after the inner Cambridge sites. If due consideration was
given to the emerging masterplan for Cambridge South it would be seen that the sustainability of
the site is high.
8.7 This is a flaw in the SA process. No SA is undertaken on the current development strategy and the
effect of the proposed departure from this strategy with development on the edge of Cambridge
constrained. If the Councils follow this strategy of constraint there will be long lasting
repercussions in terms of future sustainable development in the two local authorities, likely to lead
to increased vehicle movements, increased pollution, economic and quality of life issues, delay in
delivery due to the requirement to provide major infrastructure and questionable viability.
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8.8 The Council have not taken into account the information submitted about the sustainability of the
site so far. The requirements of the SEA Directive have been overlooked as there is a requirement
to provide for a high level of protection of the environment and to contribute to the integration of
environmental considerations into the preparation and adoption of plans with a view to promoting
sustainable development.
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9 Conclusion
9.1 We respectfully recommend that the Councils' Joint Working should include the whole
Development Strategy to understand the full implications of the emerging Plan. The new
settlements are much less sustainable than the edge of Cambridge sites. The Councils are
currently not in an informed position to be able to say that the Green Belt is more important than all
the other Sustainability Topics and Objectives of their Plan. The SA should encompass the
strategic development options.
9.2 The SA is unsound as it does not conform to the requirements of the SEA Directive in that it does
not test the plan against the SEA Objectives and Topics, nor does it develop strategic alternatives
and predict and evaluate the effects of the plan, including those alternatives.
9.3 The SEA Directive is not met because the predicted environmental effects of the Plan, including
alternatives, are not presented to the public or decision-makers.
9.4 The Plan does not comply with the requirements of the NPPF in that it is not delivering sustainable
development.
9.5 The Councils have no knowledge of the effects of diverging from the most sustainable
development sequence by constraining land releases on the edge of Cambridge within the Green
Belt. An SA should be undertaken on the current development strategy and the effects of
departing from this sequence to see what the consequent effects are on the Councils' own
identified Sustainability Topics and Objectives. Without this information neither Council will
understand the likely effects of their Plan on sustainable development. The options are not fully
tested as required by the SEA Directive.
9.6 No SA been made on the implications on traffic congestion, air pollution, greenhouse gas
emissions and other quality of life issues if the edge of Cambridge sites are constrained and
development shunted to the lower level locations in the sequence.
9.7 As the Plan currently stands, the Councils are saying that the Green Belt is more important than all
the other Sustainability Topics and Objectives together without even understanding what the
effects on the sustainability issues are.
9.8 Lack of knowledge and understanding of potential effects not only hampers the local authorities in
ensuring the future sustainable growth of their districts; it also negates the consultation process as
stakeholders are not able to draw any conclusions on the likely effects of the Plan.
9.9 Broad Location 5 should not be rejected due to:
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it is on the edge of Cambridge and second in the sequence of sustainable development;
Cambridge South is sustainable because it is in close proximity to major employment
centres and the Park and Ride transport hub; and
Cambridge South can be developed in such a way as to provide a green foreground
setting to the City.
9.10 The consequence of restricting land release on the edge of Cambridge will be to revert to the
constraint and dispersed pattern of housing which was a consequence of planning policy prior to
1999, leading to unsustainable growth and which the policies of the last fourteen years have tried
to redress.