Question 5. Do you think we have identified the right cross-boundary issues and initiatives that affect ourselves and neighbouring areas?
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The boundaries should be changed so that Cambridge City and South Cambs become one authority. There are far too many layers of local Government and this results in piecemeal policies.
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The Trumpington Residents’ Association agrees that the correct cross-boundary initiatives have been identified.
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‘Connectivity and movement’ is missing. Should be a major theme as transport will significantly affect other ‘Big Themes’. See Q6.
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The plan cannot be developed without consideration of London’s economy and unmet housing need. London exerts a powerful influence across a wide area, including Greater Cambridge. London’s unmet need is now considered to be around 140,000 homes over the period 2018 to 2028. If consideration is not given to the implications of that it is likely that there will continue to be under provision with negative economic, social and environmental impacts.
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Great Cambridge has identified the following cross boundary strategic issues: • Assessing housing need, including Gypsy & Traveller accommodation needs. • Wildlife habitats and green infrastructure. • Carbon offsetting and renewable energy generation. • Transport. • Water, including supply, quality, waste water and flood risk. Whilst Huntingdonshire District Council agree with the above issues, we would also suggest the following additional strategic issues that may impact upon the district and therefore require consideration. • Distribution, location and amount of growth: housing and employment. • Potential implications of growth on the Great River Ouse and the Ouse Washes, the Fens and South East Claylands, nearby designated and undesignated heritage assets. • The protection and enhancement of green and blue infrastructure corridors and linkages to the benefit of flora, fauna and recreational uses. • Tourism impact on visitor destinations and neighbouring villages such as Fenstanton and Houghton and Wyton in relation to potential increase in usage due to population growth.
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I think collaborative work between the different authorities and regions is essential; there are many different needs to consider but we shouldn't let that stop the plan focusing on its four key aims with climate change being a particularly important focus. The plan should rest heavily on evidence and be consistently applied. For example, I'm not sure the below quote is quite true about many of the current new developments in and around Cambridge - design quality and the prioritisation of sustainable transport are often compromised in both large and small ways. "Greater Cambridge has a reputation for design excellence and has focused on new development that is innovative and promotes the use of sustainable modes of transport."
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Whilst we agree, it imperative that the discussions with neighbouring authorities “on strategic matters that cross administrative boundaries” (National Planning Policy Framework (‘NPPF’) paragraph 24) are evidenced which confirm strategic policy-making authorities have collaborated “to identify the relevant strategic matters which they need to address in their plans” (NPPF, paragraph 25). The importance of this cannot be underestimated given a number of Local Plans have recently been found unsound owing to a lack of evidence in relation to the Duty to Cooperate (‘DtC’) on cross boundary strategic matters such as housing. We therefore suggest sufficient flexibility is incorporated into the spatial strategy that allows for inter alia, having to absorb neighbouring authorities unmet housing need, if required.
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Issues in Greater Cambridge and Peterborough area identified in the Cambridge and Peterborough Independent Economic Review (CPIER) include: doubling its economic growth in the next 25 years, catering for an ageing population, clean growth and creating an inclusive society where economic growth works for everyone. The need for new housing in Cambridge is high and the adopted Local Plan sets out how the objectively assessed need for 14,000 additional homes between 2011 and 2031 can be achieved. The Councils’ agreed in a Memorandum of Understanding that the housing trajectories for both areas be considered together for the purposes of housing delivery, including calculations of 5 year housing land supply. Other cross boundary initiatives includes the Oxford-Cambridge Arc, which signifies an area of significant economic potential, including a joint declaration of ambition between government and local partners. The emerging Local Plan should promote policies which encourages the growth of this joint declaration and build on its economic potential. The NPPF is very clear that Local Plans must be “based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground” (paragraph 35). Any Plans that fail in this regard would be found to be unsound. For this reason and given the geographical nature of the Greater Cambridge area, it will be essential that the Local Plan Review is prepared in very close collaboration not only between Cambridge and South Cambridge but other adjoining local authorities to assist in meeting the strategic housing requirement of the wider area.
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It is not clear to me that commuting has been properly taken into account. People working in London live in Cambridge because it is cheaper. This displaces people working in Cambridge, who then live in (eg) Haverhill, because it is cheaper than Cambridge, and so on. Commuting is bad for people and for the environment, and more effort should be made to reduce the drivers for long distance commuting, and to make local commuting more efficient.
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We welcome mention of water, flood risk, green infra and biodiversity. We would like to be clear that with water resources in particular, Greater Cambridge is influenced beyond its immediate neighbours, and across the Anglian Water, Affinity Water and Cambridge (South Staffs) Water companies. Whilst ideally this would fall to regions (as previously with RSS14) the C&P Combined Authority is best placed to do this. In the absence of such join-up, the duty would fall to Greater Cambridge to consider the supply and demand for water across the affected water resources zones. For flooding, the whole River Cam catchment is significant as regards impact on the plan area, and further downstream for impacts from the growth. The duty to cooperate with such authorities and related stakeholders will help determine the approach to take. The Integrated Water Management Study and input from the C&P Combined Authority are necessary steps which we support. The plan and SEA should take account of growth impacts based on the effectiveness of existing legislation, and not assume all flood risk will be mitigated. For example much urban creep and small infill plots carry out no surface water attenuation, and SUDs are often not fully maintained in the long term. This may impact downstream. Water resources The water companies have recently produced water resources management plans (WRMP), which set out how the companies will maintain customer supplies over the period 2020- 2045. The assessments will show which companies have sufficient supplies to meet growth but also any strategic schemes that are needed to achieve this, along with reducing demands and leakage. We recommend that GC considers the long term feasibility and viability of supplying new developments in view of climate change. There is currently no assessment of ensuring that developments built in the plan can still be served for the 100 year minimum lifetime of the development, or beyond that. Also there needs to be consideration of how the phasing of growth links to the timings of the planned new strategic schemes, such as reservoirs, which would be at least 15 years off. Evidence to consider: The Anglian River Basin Management Plan https://www.gov.uk/government/publications/anglian-river-basin-district-river-basin-management-plan considered the status of all rivers and aquifers in the Region. This showed many waterbodies did not have the flow required to support the ecology and groundwater units not meeting good status. Given the pressure the Chalk aquifer faces, we cannot rule out future further reductions in the supplies available to water companies to prevent deterioration of the water related ecology. The council should seek the water company’s assurance that it can meet the needs of growth without causing deterioration. The Environment Agency advises that current levels of abstraction (not just in Cambridge) are causing environmental effects. Any increase in usage within existing licenced volumes will increase the pressure on a system that is already failing some environmental targets. We recommend any proposed development considers water resources as a key issue and GC recognises the damage of any long term increases in abstraction due to growth. We recommend this development takes into account the combined effect of growth in the area and the overall change (increase) in demand for water over that period. Cambridge Water company has recently (November 2019) published a new water resources management plan (WRMP), which sets out how the company will maintain customer supplies over the period 2020- 2045. The plan can be viewed here: https://www.cambridge-water.co.uk/about-us/our-strategies-and-plans/our-water-resources-plan The company is planning for housing growth of 2,500 properties in 2020-21, 2,400 in 2021-22 and then 2,000 per year between 2022/23 to 2025/26. After this point, the company forecasts new build growth to decline, ending up at 1,200 per year until 2044/45. This takes its total household property supplied from 101,400 in 2019/20 to a forecasted 158,530 in 2044/45. This appears to be in strident contrast to growth aspiration of GC, and in particular the C&PCA upper aspirations. The company’s assessment (using its own modest longer term growth assumptions) is that it will have sufficient supplies to meet this growth. The company’s plan is to increase the utilisation of its abstraction licences whilst seeking to reduce individual customer demands and reduce leakage. It should be noted that whilst the company has sufficient supplies available, this will result in an increase in overall abstraction and the pressure on groundwater aquifers, which are already over abstracted. This poses a risk to the rivers which are linked and supported by these aquifers. The Anglian River Basin Management Plan https://www.gov.uk/government/publications/anglian-river-basin-district-river-basin-management-plan considered the status of all rivers and aquifers in the Region and looked at what it would take to ensure they met good ecological status and reverse the over abstraction related to historical licensing of water. The measures required to make these improvements were subject to a cost benefit test. The assessment of the measures needed to get the entire aquifer and river system back to supporting good ecological status were deemed to be disproportionately expensive. The plan did approve some measures to improve the status of the rivers that were failing to meet their ecological flow needs where it was cost beneficial Given the pressure the Chalk aquifer faces, we cannot rule out future further reductions in the supplies available to CWC to protect water related ecology. At this point, we are not planning on further reductions before 2025, but there is a high likelihood that further reductions could be required after this period. Any resultant loss in available supplies would need to be addressed in the company’s next WRMP (2024). CWC’s next WRMP will need to reassess its ability to meet the demands of existing and planned customers should its abstraction licences require reductions. Significant new supplies are unlikely to be available locally as the groundwater aquifers are over abstracted and new consumptive abstraction will be permitted only by exception. Many of the rivers fed by groundwater are also over abstracted and exhibiting signs of environmental stress. Therefore, any significant new resource is likely to be part of a wider strategic scheme that involves bringing water in from other parts of the country either directly, or by linked transfers from neighbouring water companies. These types of schemes are highly likely to have significant lead in periods (10 plus years) before they could become operational, and are likely to be outside the GC planning area. The quantum and phasing of growth (through the duty to cooperate) will need to take this into account. The underlying condition of the rivers and groundwater aquifers is set out in our Cam and Ely Ouse Abstraction Licensing Strategy https://www.gov.uk/government/publications/cams-the-cam-and-ely-ouse-abstraction-licencing-strategy This shows the stress that the hydrological system is presently under as a result of abstraction. Given the pressures on local water resources and the potential risk of deterioration as a result of increased levels of abstraction, we advise that new development in the Cambridge area, and adjacent water resource zones aims for the highest levels of water efficiency. The council should also seek CWC’s assurance that it can meet the needs of the SEA growth scenarios without causing water body deterioration, or excessive water transportation and associated impact on the areas in Anglian Water’s or Affinity Water’s zones that would be affected. The Building Regulations allows local plans to specify optional standards with regards to water efficiency targets in new homes. Building regulations specify a target use of 125 litres per person per day. It is noted that both Cambridge City Council and South Cambs District Council have already applied the optional standard of 110 litres per person per day and we would advise that this is at least maintained in future plans. Given the water stress of the area as detailed above, we would also wish to see the Councils encouraging developers to aim for even higher levels of water efficiency (80 litres per person per day). However in the absence of legislative back up for this, it should not be relied upon in assumptions. Water efficiency measures in new development are highly unlikely to achieve the kinds of reductions in demand needed to keep high levels of growth within sustainable levels. Investment in leakage reduction and demand management by existing communities and businesses will play a big part, as will seasonal abstraction and storage. New consumptive uses such as basements that need dewatering, water reliant agriculture, food processing and some manufacturing may individually and will cumulatively have a significant impact on water availability. Suitable protective policies will be needed to manage these impacts. Water Quality and Wastewater The Greater Cambridge Local Plan appears to be a very comprehensive, environmentally centred, public focused plan. It is encouraging to see the level of consideration for climate change, biodiversity and green spaces, which the Environment Agency supports. The Greater Cambridge Local Plan, like any new development, which is inherently linked to population increase, risks a degradation of water quality. New development would undoubtedly put pressure on the river quality of the Greater Cambridge area and beyond. Any increase to wastewater discharge and water usage will need to be discussed with Anglian Water, whose role it is to accommodate the additional wastewater flows. They may need to increase capacity at the Water Recycling Centres or adjust their permits to treat wastewater to tighter permit conditions, to maintain river quality. The Water Framework Directive prohibits a deterioration in water quality and aims to achieve ‘Good’ status in each waterbody. Anglian Water need to continue to develop their Drainage and Wastewater Management Plan while collaborating with local authorities and the Environment Agency. Anglian Water’s wastewater treatment centres need to adapt and evolve to accommodate the proposed growth within Greater Cambridge. Climate change could potentially exacerbate the impact of development on river quality. Dry weather reduces river flow and increases pollution concentration in the waterbody. Conversely, more intense rainfall episodes creates additional surface run-off from rural and urban areas, which increases the potential for water pollution. Additional rainwater in the sewerage network will likely lead to the treatment sites using overflow tanks, some of which may spill – as they are designed to do – into the rivers. These abovementioned events potentially contribute to a deterioration of water quality. In conclusion: -New developments are likely to increase pressure on the environment; -Water companies need to adapt their infrastructure to accommodate the proposed Local Plan, and use demand management for existing communities and businesses. -Climate change will intensify the existing pressures, and these need evaluating. -An integrated approach to water management (IWM) is essential to managing the related factors. -We support GC’s emerging IWM study, but recognise that the duty to cooperate goes far beyond GC, and the C&P Combined Authority has a primary role in ensuring that the duty is fulfilled. -It is imperative through the River Basin Management Plan that delivery of the Local Plan does not lead to a deterioration in water quality through over-abstraction or wastewater. We defer to Natural England in respect of biodiversity, and recognise the role that healthy rivers play in providing habitat and connectivity.
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I think we need a Unitary Authority for South Cambs and Cambridge City. We need joined up targets joined up plans to deal with the rapid changes that are needed. The level of bureaucracy makes bold, decisive and quick action impossible as this slowness is amplified by the fact that too many organisations are involved.. One only needs to look at how the meetings schedules of all the organisations involved to realise this. Such a slow and time wasting process.
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Overall targets for carbon reduction should be agreed cross boundary. These will be supported by objectives about off-setting carbon, renewable energy, green infrastructure and transport objectives.
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From the outset, the approach to planning in the local area which combines the City Council’s administrative area and South Cambridgeshire administrative area is the correct one. There have been discussions over many years about setting a policy framework across both administrative areas and it is entirely appropriate that a new Greater Cambridge Local Plan is now in train to ensure that there a coherent strategic plan covering both authorities. On a more strategic scale, it is the case that the Greater Cambridge Local Plan should be developed in partnership with the neighbouring authorities having regard to the potential for the economic growth of the region to impact increasingly in a ring of market towns including Ely, Newmarket, Mildenhall, Haverhill, Saffron Walden, Royston, St. Neots, Huntingdon and indeed any other emerging locations within transport and infrastructure corridors leading into and out of Cambridge. The duty to co-operate remains a key matter in the formulation of plans and the evidence base for development plans needs to firmly establish that such cooperation is in place in the event of the plan moving towards adoption.
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So far, only narrow thinking has been applied and many of the flaws in the adopted Local Plans ignored. Repeating those flaws wold be tragic with the wrong number and type of homes built in the wrong places, increasing the need for personal transport and forcing exotic and unaffordable transport schemes to be developed to join them up. People do not choose to travel to work for average wages; they have to in order to support their families and they will reduce costs by using diesel-engined cars and burning logs. The only affordable transformational technology is telecommunications; which does have the potential top reduce he need for travel.
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Agree with identification of main growth corridors, but consideration should also be given to Cambridge/Ipswich, Cambridge/Kings Lynn and Cambridge/Peterborough/Birmingham, thus building on existing transport corridors. These routes already carry a significant amount of rail commuter traffic into Cambridge and can thus be regarded as being within the economic orbit of Cambridge. Housing requirements should take into account growth in these areas and the dispersal which is already taking place. West Suffolk DC lies within the same housing area as SCDC & City and should, perhaps be singled out as a major collaborator. Cross border communication has not been good in the past eg with Uttlesford over, for example, that authority's recent proposal to include a major new settlement at Gt. Chesterford on the immediate southern boundary of SCDC. Growth corridors to be considered should be extended. Cross border working with neighbouring authorities should be improved.
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No opinion
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A Unitary Authority is urgently required to cover the Cambridge sub-region (Cambridge, South Cambs and possibly slightly larger). The current system is a threat to democracy, as with so many different authorities and bodies involved without consistent political leadership (Cambridge City Council, South Cambs District, Cambs County, The Mayor of Cambridgeshire and Peterborough, MPs, GCP etc) there is no real accountability – so developing planning policies becomes a technocratic exercise in evidencing how proposals meet dictated overall objectives e.g. on number of new homes required. The next local plan should not be decided on the basis of a questionaire or consultation like this - there needs to be recognition that many of these questions are political issues (like how fast should Cambridge grow), and they should be decided by politicians making a case, and people voting for those that outline the plans they most agree with. With better democratic accountability, we could have real choice to be bolder and more radical, and with less scope for objections blocking good plans, and less likelihood poor developments will be permitted. All local authority leaders should be urgently calling on the government to create a single unitary authority to allow greater Cambridge to reach its potential.
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Yes but we reserve the right to make further representations.
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I think so see answer below
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The five cross boundary issues highlighted within the consultation document are supported in principle; however, economic growth, employment and jobs should be added to reflect the overarching objectives for the Oxford-Cambridge Arc. Delivery of new homes and infrastructure; and in particular transport and social infrastructure, will be critical in achieving the wider objectives and priorities of Government, the Combined Authority and the Greater Cambridge authorities. When assessing housing need, it is important that the needs of all communities are considered and addressed; including particularly those in need of affordable housing; those wishing to access the housing market for the first time; those wishing to rent; and the provision of homes for an ageing population. It is noted that the various Local Plans and strategies informing the future direction of growth and investment across Cambridgeshire and Peterborough are at different stages of preparation. There is a risk, therefore, that the wider strategic objectives for the entire area, encompassing the Combined Authority, will not be achieved as a consequence of disjointed plan-making. For example, as matters stand the Local Transport Plan is being prepared in advance of the Non-Statutory Spatial Framework and the constituent Local Plans, meaning that transport infrastructure for strategic housing and economic growth is not being planned for or prioritised in a coordinated way. The strategies for growth across Cambridgeshire and Peterborough must be approached in a comprehensive fashion and with an open mind to ensure that all possible growth scenarios can be explored, tested and developed to achieve (or indeed exceed) the ambitious strategic housing and economic growth ambitions for that Arc envisaged by Government.
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Southern & Regional development (Joscelyn) identifies that it is essesntial for a Local Plan todemonstrate that it has discharged its statutory Duty to Co-Operate with neighbouring authorities and other relevant organisations to ensure that it is sound. Without due consideration of cross-boundary issues, including housing requirements and economic functions, a Plan will not have demonstrated its requirements as contained within the Duty to Co-Operate. Although the Greater Cambridge Local Plan is at an early stage of its preparation, it is vital that is able to demonstrate that it has taken into appropriate consideration cross-boundary issues. These issues will influence the strategies of the new Plan, including the approach in achieving residential and other types of development across the Local Plan area. Those issues which have been identified within the Issues and Options document address significant considerations which will inform the trajectory of the Plan during the preparation process. It is considered that those areas of concern relating to cross-boundary factors are appropriate. Although it is recognised that the Cambridge HMA is relatively self-contained, with a travel to work area similar in size and pattern to the housing market area itself, this should not result in a Plan which reduces the significance in cross-boundary impacts on the ability of the Planning Authorities in delivering their housing needs. For instance, given that the neighbouring Authorities are generally unconstrained, with no Green Belt, it is likely that they will be able to meet their own needs within their own jurisdiction. As such, there may be lesser need for Greater Cambridge to assist in accommodating cross-boundary housing numbers. However, it is considered that the emerging Local Plan must take into account the impacts that a rapidly growing local economy will have on these cross-boundary issues. This includes the influence of strategic infrastructure projects, such as East-West Rail and the Oxford-Cambridge Expressway which will open the housing market up further to additional influxes of people commuting to the expanding job market within Cambridge. This in turn will have a material impact on strategic residential need as a result of increasing demand and exacerbate housing costs. A careful approach to cross-boundary considerations is therefore required, to ensure that the new Plan remains responsive to these issues given that they arise from outside the Local Plan area and are beyond the control of the Local Authorities. Summary of Comments: The list of cross-boundary considerations is appropriate, however the Local Plan should acknowledge the degree of importance and significance to each.
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Strongly Agree For nature to recover it is critical that authority boundaries do not create a barrier to wildlife moving throughout the habitat network. If we are to achieve our ‘doubling nature’ target in Cambridgeshire, the Greater Cambridge Plan authorities need to work closely with neighbouring authorities to deliver ambitious and strategic habitat creation projects and a coherent green infrastructure network that is joined up across authority boundaries. RSPB believes that many of the most significant opportunities lie in districts neighbouring the Greater Cambridge area, but rely on and will benefit the development planned for the area.
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4.3 Neither agree nor disagree – the joint nature of the proposed plan across both the administrative areas of Cambridge City Council and South Cambridgeshire District Council is a positive step towards ensuring cross-boundary issues and initiatives are captured and planned for. The work of Cambridgeshire and Peterborough Combined Authority and the implementation of the Local Industrial Strategy is key for supporting existing, and also growing a range of employment opportunities. The New Local Plan should acknowledge and plan for the Cambridgeshire and Peterborough Combined Authority ambition, as set out in the devolution deal, to double GVA over 25 years.
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I work in the Connecting Cambridgeshire team at Cambridgeshire County Council. I understand that specific policies have not been included at this stage however I wanted to take the opportunity to request that a policy relating to Digital Infrastructure is included within the Local Plan – I believe this relates to Q5 (it will support working together across boundaries) and Q6 (It will support at least 3 of the big themes – Climate Change, Wellbeing & Social inclusion and Great Places).Please find my comments in relation to this in black text below: “The National Planning Policy Framework describes the importance of ‘Supporting high quality communications’ within a Local Plan including its role being ‘essential for economic growth and social well-being’. The availability of highly quality communications facilitates modern businesses operations from payments to supply chain management to research projects as well providing access to residents for online services, education and an ability to stay in contact with family & friends. The importance of high quality gigabit capable digital connectivity has been highlighted by the Government setting a target of having full fibre coverage across the UK by 2033 as well as recently announcing their investment alongside Mobile Network Operators (MNOs) in a Shared Rural Network (SRN) to significantly reduce rural ‘not-spots’ where mobile coverage is unavailable across the UK. Going forward it is essential that Digital Infrastructure is included in the detailed design of new developments to ensure the benefits of high quality gigabit capable digital connectivity are realised for all residents and businesses. This needs to be included in the planning policy as: • Any new development of any size by default will not have Full Fibre connectivity without engagement with suppliers and having the right infrastructure installed. • A new development site may have poor mobile coverage and/or impact on the capacity of a MNO’s existing network without a requirement to review the current situation and facilitating improvements if required. • The availability of Full Fibre technology is considered to be a pre-requisite of future 5G rollout and other future facing technologies. Ensuring Digital Infrastructure is included in the Local Plan and therefore development design provides multiple benefits to developers, service providers, local councils, highway authorities, businesses and residents: • It ensures the design and equipment locations for communication infrastructure are integrated in to the full design of the development. • There is a significantly lower cost to install ducts, chambers, power cables and cabinets at a time when footways/carriageways are being constructed and other utilities installed. • Disruption to residents and commuters is minimised by ensuring a majority of the construction work takes place at the same time and primarily before occupation. • The quality of finish for new surfaces, in particular footways and carriageways is maintained by avoiding the need to retrofit underground apparatus. • The availability of high quality communications is becoming an increasingly important factor for potential residents and businesses in their location decisions. Failure to include Digital Infrastructure as part of the development design and site construction is likely to lead to significant delays in the provision of high quality gigabit capable communications to the development. This is due to the higher costs and inherent additional difficulties in retrofitting infrastructure where suppliers are likely to be prioritise other locations where there will be a quicker return on investment.” The Connecting Cambridgeshire team would be happy to help develop this policy to fit Greater Cambridge’s growth ambitions and I have attached an early draft example of what this might look like going forward subject to further input from yourselves and other stakeholders to ensure it is appropriate for use.
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