Question 4. Do you agree that planning to 2040 is an appropriate date in the future to plan for? If not, what would be a more appropriate date and why?
4.1 Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67). It is widely recognised that a mix of both small and large sites are needed during the plan period. Small sites such as Bedlam Farm can bring forward development early in the plan period while larger strategic sites can take many years to come forward. 4.2 As recognised, Greater Cambridge falls at the crossroads of a number of key economic corridors, including the Oxford-Cambridge Arc, London-Stansted Corridor and the Cambridge-Norwich tech corridor. The Oxford-Cambridge Arc in particular is a key economic priority as recognised by Central Government. It is imperative that the New Local Plan has flexibility to allow for additional growth to come forward to meet the needs of this important initiative as it develops through cross boundary and national discussions take place, potentially within the early/mid stages of the plan period.
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Please see attached Representation Report (page 4). Disagree. 2050 would be a more appropriate date. 3.3 The NPPF (paragraph 22) states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. 3.4 Table 5 of the consultation document sets out a timetable which envisages Local Plan adoption in Summer 2023. However, we are aware that many other authorities are experiencing significant delays in their local plan preparations. This often occurs during the Examination in Public (EiP) phases and is therefore essentially outside of a local planning authority’s control. Any significant slippage in the Greater Cambridge Local Plan timetable could compromise the ability of the Councils to deliver a Local Plan with a minimum 15-year period from adoption. On this basis, a plan period to 2050 would be more realistic. 3.5 In addition to this practical point on timescale, we also note that a plan period to 2050 would correspond with other strategic plans for the area and may provide a better timeframe for long-term strategic decisions.
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Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67). It is widely recognised that a mix of both small and large sites are needed during the plan period. Small sites such as land between Cambridge Road and Bridge Road can bring forward development early in the plan period while larger strategic sites can take many years to come forward.
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3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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Agree - The proposed Local Plan period up to 2040 is considered appropriate and accords with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Paragraph 67).
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Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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Q4: Do you agree that planning to 2040 is an appropriate date in the future to plan for? If not, what would be a more appropriate date and why? The Greater Cambridge Planning Authority’s ambition is to submit a new Local Plan for examination by 2022. Given the complexities of the planning issues associated with Greater Cambridge and its future development, it is reasonable to assume that the examination process will not be straightforward. The original Local Plans were submitted in 2014 and were not adopted until 2018 and even then, were subject to a commitment to an immediate review. While the new Local Plan will be based on a lot of the adopted Local Plan work, a pragmatic time table for adoption from submission would be a minimum two-year period resulting in adoption in 2024 at the earliest rather than 2023 as suggested. Paragraph 67 of the NPPF requires planning policies to identify specific deliverable sites for the first five years of the plan period and specific, developable sites (or broad locations for growth) for years 6 to 10 and where possible for years 11 to 15 of the plan period. The plan should therefore cover a minimum period of 15 years from adoption, if future development is to be based on a genuinely plan lead approach. While the currently adopted Local Plans may provide some certainty, subject to housing delivery and five-year housing land supply issues, for the first five years, i.e. 2018 to 2023, the new Local Plans should follow on for the next 15 years, i.e. up to 2038 as a minimum. If as set out above the reality is that the new Local Plan is not adopted until at least 2024, 15 years on would take it to 2039. Therefore, a plan period to 2040 is considered appropriate, in particular having regard to climate change and the imperative to take action now. However, the plan needs to be visionary, looking forward beyond 2040, in particular, having regard to the Greater Cambridgeshire non statutory plan which covers the period to 2050 and the Government’s commitment to reach Net Zero Carbon by 2050. The plan needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the plan area. Summary of Comments: We agree that the plan period to 2040 is appropriate although the plans vision should be beyond 2050.
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44. We do not dispute that planning for the period up to 2040 is appropriate. However, in accordance with Paragraph 67 of the NPPF, it is more important for plans to identify a supply of specific, deliverable sites for years one to five of the plan period. After this, developable sites or broad locations for growth should be identified for years 6-10 of the Plan and, where possible, for years 11-15 of the Plan. 45. As such, it is clear that there should be a focus on allocating sites for delivery in years 1-5 of the Plan rather than planning for up to 2040. Medium and smaller sites, such as our Site, are best placed to come forward quickly (in years 0-5) as typically, they are not constrained by multiple land owners, viability issues or delays in progressing detailed design. As such, these smaller, well located sites must be allocated now to provide an immediate and robust supply of sites in the short-term.
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Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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2.9 As long as the plan provides a consistent amount of housing provision throughout the course of the plan and the plan is adaptable to change, then planning to 2040 can be considered an appropriate date to be planning towards. 2.10 Moreover, it assures that the Plan when adopted will have at least a 15 year horizon of need at the point of adoption and will avoid the need, experienced by some Authorities, to extend the original period due to delays in preparation or the adoption process. 2.11 Therefore, whilst in terms of setting strategic patterns of growth, we would advocate as long a horizon as possible, in this instance we consider that 2040 reflects an appropriate balance of future planning and certainty of delivery.
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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We agree that 2040 is an appropriate date to plan for delivery of housing on the basis that the minimum housing and employment needs are already set out – i.e. minimum 41,000 new homes between 2017 and 2040, potentially increasing up to 66,700 to rebalance new housing against jobs growth. This is on the basis that there will be a full Green Belt Review undertaken to support the spatial strategy options. Whilst we do not anticipate any significant alterations to the Green Belt boundary to 2040 to deliver strategic-scale growth (as further urban extensions to Cambridge City within this period have been recently been considered through the current Local Plan which resulted in the Cambridge Airport site being removed and safeguarded from the Green Belt), a review of sustainable villages in the Green Belt is long overdue. The evidence base for the Greater Cambridge Local Plan (GCLP) will still need to consider the capacity for additional housing at sustainable Green Belt villages. In the event that this identifies areas of land that are poorly performing in Green Belt terms, and in suitable locations for proportionate growth, these should be removed from the Green Belt and identified for development.
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4.1 Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67). 4.2 As recognised, Greater Cambridge falls at the crossroads of a number of key economic corridors, including the Oxford-Cambridge Arc, London-Stansted Corridor and the Cambridge-Norwich tech corridor. The Oxford-Cambridge Arc in particular is a key economic priority as recognised by Central Government. Further work on the delivery of these initiatives will take place including the need for cooperation between authorities and stakeholders. 4.3 It is imperative that the New Local Plan has flexibility to allow for additional growth to come forward to meet the needs of these important initiatives as they develop through cross boundary and national discussions, potentially within the early/mid stages of the plan period.
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Southern and Regional Developments (Cottenham) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date and covers the minimum time frame. The timescale of any plan should however alsoo respond to long-term requirements and opportunities including major improvements to infrastructure It is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond this proposed plan period so that a sustainable strategic approach is adopted that has longevity. This is demonstrated by the strategic plan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positely to address the associated strategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040, whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adopts. Major infrastructure projects that will provide for long term requirements have already been identified at the New Towns of Northstowe and Waterbeach. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Swavesey must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site to the north east of Cottenham can demonstrate this important contribution to assist in meeting the demanding housing needs for Greater Cambridge. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing to cover this period.
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4.1 Agree - the proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF at paragraph 67 for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan.
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4.1 Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (paragraph 67).
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On behalf of Southern & Regional Developments (Willingham) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date and covers the minimum time frame. The timescale of any plan should however alsoo respond to long-term requirements and opportunities including major improvements to infrastructure It is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond this proposed plan period so that a sustainable strategic approach is adopted that has longevity. This is demonstrated by the strategic plan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positely to address the associated strategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040, whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adopts. Major infrastructure projects that will provide for long term requirements have already been identified at the New Towns of Northstowe and Waterbeach. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Swavesey must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Priest Lane - Willingham provides an assurance of deliverability and would make an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing to cover this period.
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Disagree – whilst the NPPF requires that strategic policies should have a minimum 15 year time horizon on adoption, there would be considerable merit in strategic policies looking beyond this time period to 2050. The development plan system provides for policies to be reviewed every 5 years and hence if there are significant changes in circumstances that would be picked up during a review of strategic policies and trigger an updating of the plan. Planning to 2050 would provide a clear direction and base and would simply mean that in future the plan making process can focus on allocating land to meet agreed development needs, rather than revising and debating growth levels. That would greatly speed up plan making Given the issues at stake and the length of time it has taken for local plans in the area to be adopted, there is a risk that the plan may not be adopted by April 2025. In order to minimise risk of delays, it would be appropriate to look further ahead. A plan period to 2045 would also provide a clearer strategy for investment decisions of both the public and private sector and enable the longer-term planning of infrastructure.
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On behalf of Southern & Regional Developments (Waterbeach) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date and coers the minimum time frame. The timescale of any plan should however alsoo respond to long-term requirements and opportunities including major improvements to infrastructure It is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond this proposed plan period so that a sustainable strategic approach is adopted that has longevity. This is demonstrated by the strategic plan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positely to address the associated strategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040, whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adopts. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Waterbeach must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Waterbeach can demonstrate such deliverability as an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The site at Bannold Road, Waterbeach can demonstrate this important contribution to assist in meeting the demanding housing needs for Greater Cambridge. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing to cover this period.
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The consultation document proposes a 15 year plan period. Paragraph 22 of the National Planning Policy Framework 2019 (NPPF) which states that strategic policies should look ahead over a minimum 15 year period to adoption. Given the future opportunities posed by the Oxford to Cambridge Growth Arc, Persimmon strongly disagrees with the councils’ suggestion that it plan for the minimum period allowable by national policy. Looking to 2040 will not allow for an appropriately ambitious, longer-term outlook at significantly detract from the efficacy of the plan, likely necessitating an early review soon after adoption. We would refer the councils to “The Oxford-Cambridge Arc: Government Ambition and Joint Declaration between Government and Local Partners” released March 2019 by the Ministry of Housing, Communities, and Local Government which states: “We recognise that meeting all these ambitions for the Arc requires us to take a long-term view, at least to 2050, and for us to work collaboratively across geographical, political and thematic boundaries." On this basis, in order to align with the Government’s growth agenda for the region, we would suggest that the councils plan to at least 2050.
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CambridgePPF would not want to see the Local Plan go beyond 2040. The 2018 Local Plan has proposed a significant amount of new development and a substantial increase in population. It will not start to become clear until 2025 and beyond what impacts this growth will have – for example, traffic congestion, overcrowding in Cambridge City Centre, or water shortages in our chalk streams. Therefore, it would seem to us to be unwise to continue to extrapolate growth to 2040 (or beyond) until the impacts of the ‘in-pipeline’ growth are better understood. • Any future Local Plan must be flexible and allow for continuous review in response to changing circumstances. Advances in technology and the effects of climate change are two obvious factors that could have a profound impact on Greater Cambridge, even in the relative shortterm. A fixed and rigid Plan could become a hindrance in addressing future change. It would also be very difficult (maybe even impossible) to suggest that growth levels be lowered if it turns out that significant growth cannot be achieved without unacceptable adverse impacts. How is the necessary flexibility to be built into a Plan that has a 20-year horizon? It is much easier to increase housing targets than to reduce them because it could have serious financial implications. This should argue in favour of the “precautionary principle” in target setting and our preference would be for the new Plan to provide housing requirements to 2035 and to give only an indication of future growth beyond that date. • In the UK we are reliant on census data to inform us of changes in our society and to inform future planning. The last census was nearly 10 years ago, yet Cambridge is changing rapidly. The next census will take place in 2021 with data available in 2022/23. This will clearly create a problem for the creation of the greater Cambridge Local Plan – with the possibility that census data could require changes to the plan once it is at an advanced stage. Has this been considered by the Councils? If so, is the proposed timetable sensible or would it be wiser to put back the process in order to be able to plan, based on new census data? • Any future Local Plan must also take account of National Statutory and Interim Climate Change targets (2050 Net Zero and 2030 Clean Growth Strategy respectively) including those for all existing buildings.
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Agree with 2040 date – 2050 is too long a timescale
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Yes we agree. The end date of 2040 is consistent with that intended for the emerging draft West Suffolk Issues and Options Local Plan and other authorities in Cambridgeshire. Using a consistent date assists in the preparation of joint evidence-based documents.
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Disagree. It is essential that this Local Plan doesn’t just consider detailed requirements up to 2040, but also sets a long-term vision for the future growth of Cambridge, otherwise the opportunity to move to sustainable development will be missed. The sheer scale of growth envisaged from the doubling GVA, CPIER and Ox-Cam Arc proposals will not be sustainable without fundamental changes to the way that development is allocated, planned and delivered. The avoidance of impacts on and large-scale enhancement of the natural environment must be at the heart of a truly sustainable approach. At the current time it is far from clear that the higher levels of growth envisaged could be achieved sustainably. The Greater Cambridge Nature Recovery Network (see below) must form the framework within which all future development is planned. Planning of houses, jobs and infrastructure must not compromise the nature recovery network, but rather sit alongside it and support it. Using the natural environment as the framework within which development is planned is best practice in the design of individual developments and this approach must be translated to Local Plans. Creating a nature recovery network of address the biodiversity crisis, and addressing the challenges of climate change and water resource issues whether adapting to future flood risks or the lack of available water to support the levels of growth envisaged (while still supplying the natural environment), require planning and setting the direction of travel for future growth over a much longer timescale. There is a danger that only planning to 2040 will lead to a continuation of unsustainable growth patterns. This may be the appropriate period for detailed planning, but, a longer term direction of travel will be required if the most sustainable solutions are to be adopted.
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• According to the IPCC, we need to greatly reduce CO2 emissions well before 2030 (IPCC, 2018). • Given that a climate emergency has been declared by both the South Cambridgeshire District Council and the Cambridge City Council we urge them to take swift action to transition the Cambridge region to sustainable transport including cycling. • Local Plan strategies for cycling and public transportation (which include understanding where and how new developments should be located and designed) must assume a radical shift away from cars well before 2040. • Therefore,very powerful decarbonisation and demotorisation strategies need to be implemented within the next 5–10 years, and on development proposals this needs to occur straight away. Planning for 2040 will be too late. “Pathways limiting global warming to 1.5°C with no or limited overshoot would require rapid and far-reaching transitions in energy, land, urban and infrastructure (including transport and buildings), and industrial systems (high confidence) [...] Avoiding overshoot and reliance on future large-scale deployment of carbon dioxide removal (CDR) can only be achieved if global CO2 emissions start to decline well before 2030 (high confidence).” (IPCC, 2018) “Incentives alone may not be enough to encourage developers to incorporate higher sustainability standards. Therefore it is essential that strong climate change mitigation and adaptation policies are developed as part of the Local Development Framework. Policies should set specific targets as far as it is reasonable to do so. They should also be future proofed as far as possible, for rising standards over time, especially for large sites with long build out periods, so that they do not become rapidly out of date.” (Cambridge City Council, 2009) Evidence for our response to Question 4. • IPCC, 2018: Summary for Policymakers. In: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty. • Cambridge City Council (2009). Review of the Orchard Park Development and Lessons to be Learnt for Future Major Developments.
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We understand that the centrally defined process for all areas includes the use of a 20 year horizon from the start of the planning cycle, which allows for the approximately five years from the start of the process to the adoption of the new Local Plan. However, the latter years, relying as they do on extrapolation from the short-term trends (also in the CPIER) can only be at best indicative. There are too many unknowns and economic history shows this smooth expansion is rare. Furthermore, the predictions of the range of possible (by 2040) impacts of climate change which are dependent on the effective action taken in the near term worldwide, make the exercise lack any credibility that far ahead.
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ECC notes that the NPPF recommends that Local Plans provide the policy framework for at least 15 years from adoption. The GCA anticipate that their plan will be adopted in 2023. The recommended timescale is to devise a Joint Local Plan with an end date of 2040. This would provide for 17 years and ECC agrees with the proposal.
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• Given that a climate emergency has been declared by both the South Cambridgeshire District Council and the Cambridge City Council I urge them to take swift action to transition the Cambridge region to sustainable transport including cycling and a comprehensive and free bus network, such as that carried out in Dunkirk. o https://www.theguardian.com/cities/2018/oct/15/i-leave-the-car-at-home-how-free-buses-are-revolutionising-one-french-city o https://www.france24.com/en/20190831-france-dunkirk-free-transportation-bus-success-climate-cities • Local Plan strategies for cycling and public transportation (which include understanding where and how new developments should be located and designed) must assume a radical shift away from cars well before 2040.
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The timescale for the Plan i.e. to 2040is a sensible one. Within this timescale there This length of time is necessary both to meet the requirements of the NPPF and to properly consider how strategic growth can take place in a coordinated way alongside the substantial investment in infrastructure that is planned. The recent ‘Building Better Building Beautiful Commission’ report endorses the Council’s approach informed by the 2050 regional (Peterborough and Cambridgeshire) plan: the Commission envisage a strategic plan of some 30 years as the necessary requirement to deliver place stewardship*. * Living with Beauty p40
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I agree that planning long term is essential. We need a vision for 2040 and interim operational and milestones for 2025, 2030 and 2035. Cambridge must become an effective and exemplary “Sustainable City” as soon as possible. 4 Priorities are crucial. 1. Invest urgently in effective and sustainable public transport delivering significant improvements by 2023 – 2025. 2. Invest in maintaining existing semi natural wildlife habitats in the City and farmed areas; restore and recreate a network of ecologically connected wildlife areas ; restore ecosystem functionality , resilience and ecosystem services of our land, rivers and wetlands and prevent deterioration; restore biodiversity , especially butterflies, moths, wild bees and other pollinators and their services 3. Abolish homelessness and reduce deprivation 4. Make Cambridge a net zero carbon (and methane) emitter as soon as possible and at the latest by 2030; and invest in carbon sinks.
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