critique of the interim sustainability appraisal issues ... · scoping report which sets the...

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


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


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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


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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.


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critique of the interim sustainability appraisal issues ... · scoping report which sets the...

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