Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options

Representation ID: 49767

Received: 24/02/2020

Respondent: Martin Grant Homes Ltd & Harcourt Developments Ltd

Agent: Savills

Representation Summary:

This sections of the scoping report refers to some key documents, all of which support growth, not just in
relation to the needs of Cambridge and South Cambridgeshire, but the wider region.
3.2. The MHCLG document of March 2019 titled ‘Oxford-Cambridge Arc’* is a joint declaration of ambition
entered into by the Government and local partners envisages substantial growth in the Arc. It establishes
a target of building up to 1 million homes by 2050. These homes are necessary to deliver the
Governments industrial strategy, which envisages increased productivity in order to boost economic
growth and prosperity, and to deliver higher incomes (p14, ibid). To date, no local authority within the Arc
has provided for any additional growth in their local plans above the standard housing requirement that
would assist in reaching this target. The Greater Cambridge Plan should recognise and accommodate
part of this wider growth. If it does not do so, it will set a precedent for other local authorities within the Arc
(such as the highly productive city of Milton Keynes) to lower their ambitions, and the Government’s
strategy for increased growth will fail.
3.3. Housing affordability is a key issue for equality both nationally and more significantly, within Greater
Cambridge. It is also an international issue. International companies able to offer better living standards
with a smaller portion of wages needed to pay for living accommodation can tempt workers from the UK
to other destinations across the globe. The government and local authorities recognise in the Oxford-
Cambridge Arc document that median house price to median income ratio has been increasing across
the UK, and increasing more significantly across the Arc.
Savills estimates that for its economic potential to be reached, 9.6 million sqft of business floor spaces is
needed across the Arc, with 680,000 homes beyond the existing pipeline.** If the Arc is to deliver its
employment potential, housing affordability must be addressed through the building of significant
numbers of homes.
3.5. It is noted that connectivity is a key theme of the government-local authority declaration on the Arc.
Transport connections are key to the allocation of new development in sustainable locations.
3.6. Protection of the environment is a key theme running though all legislation relating to development
planning. A requirement for net-gain in biodiversity does much to ensure that delivering growth is not at
the cost of the environment.
The Cambridgeshire and Peterborough Strategic Spatial Framework (CPSF) and the Cambridgeshire
Local Transport Plan (CLTP) are referenced as a key development plan document in the Scoping Report.
This document has considerable overlap with the preparation of the Greater Cambridge Local Plan. The
Sustainability Appraisal should prefer policies and allocations that ensure links are made between the
ambitions of the CPSF and the proposed transportation projects in the CLTP. Transportation matters and
traffic generation should be key issues for the SA to consider, and to inform the Greater Cambridge Local
Population, Health and Wellbeing
3.8. The scoping report correctly notes that the delivery of services and facilities (and access to them without
recourse to a car) is an issue of health and equality. This should favour larger sites able to deliver access
to such infrastructure when the sustainability appraisal of sites is carried out.
3.9. One of the key issues for the delivery of housing in Greater Cambridge is the need to deliver large
numbers of homes as quickly as possible, as set out in the Greater Cambridge Housing Strategy 2019-
2023, which notes the key priority to ‘increase the delivery of homes, along with sustainable transport and
other infrastructure …’. Consideration should be given to the ability of existing sites to deliver additional
homes quickly, when considering options for densification, or additional delivery at locations already
committed for development.
3.10. Table 3.1 in this section provides an interesting comparison of development locations, identifying that the
majority of growth in current Local Plans is to be provided on the edge of Cambridge, with a significant
number being delivered in the Cambridge Urban Area, and the total number of completions, commitment
and new sites in the rural areas amounting to more development than that proposed for new settlements
or at Cambourne (an urban extension). The Sustainability Appraisal should consider this balance of
locations very carefully. In order to maximise sustainability and reduce carbon emissions, new
development should be located where: -
There are good public transport links;
- Where there is employment within walkable distance;
- Where leisure and retail facilities are within walking distance;
- Where existing facilities and services can be complemented with new facilities.
3.11. Guidance from the NHS and wider international research indicates that the provision of green open
spaces has a linear relationship with activity levels, and a direct correlation with health. Larger sites able
to deliver both incidental open spaces and good access to strategic formal sports and parkland will
therefore offer better outcomes for population health. This should be factored into the Sustainability
Appraisal of potential development sites.
Air and Noise Pollution
3.12. The Scoping Report correctly identifies that air and noise pollution are key health issues for many groups
in Greater Cambridge. Whilst there is a reflection that noise can to some extent be mitigated by traffic
reductions and other measures in paragraph 3.68, there is no similar mitigation recognised for air
pollution. Table 3.3 outlining the key sustainability issues for the Local Plan should strongly reflect the
impacts of traffic on health and inequality outcomes in the SA objectives.
3.13. Section 2 of the Scoping Report notes the high level policy requirements introduced by the Government
for the part that the Oxford Cambridge Arc is to play in the prosperity of the region (that is briefly
mentioned in paragraph 4.24). ‘Partnering for Prosperity’, the new deal for the Cambridge-Milton Keynes-
Oxford Arc is briefly referenced at paragraph 4.9. These documents together identify the high levels of
employment growth that the Government expects across the Arc. The SA scoping should be clear that
proposals that seek to deliver integrated employment growth at the higher levels expected from
Government in relation to the Oxford Cambridge Arc will be favoured in the assessment. This criterion
needs to be factored into SA objectives 14 or 15.
Transport and Air Quality
3.14. The national policy guidance listed generally contains policies that are aimed at reducing emissions from
vehicles, or making emissions les noxious. These documents give very little prominence to the reduction
of vehicle movements, in contrast to the reduction of vehicle emissions. The former aim is much better in
all respects: reducing vehicle movements (and encouraging active travel) are both good for the
environment and our health due to better air quality, but also improve health through activity.
The Air Quality Action Plan identifies (on page 18) that modal shift from private car to public transport and
active travel will impact positively on air quality. Table 2.3 of the Action Plan identifies monitoring targets
relating to increases in bus patronage, cycling trips, journeys to school by means other than car, and
traffic congestion. The ability to meet these measures should form a part of the SA objectives: i.e. policies
and potential site allocations are rated as higher / better the more likely they are to achieve these modal
shifts. This should be considered in answering the Appraisal questions under SA Objective 13.
3.16. Local Transport Plan 2 contains targets to restrict any increase of transport within Cambridge city centre.
The ability of policies, and sites, to reduce or limit traffic congestion should be a measure of how
sustainable they are, and included in the SA objectives. Table 5.1 notes that the existing policies in the
adopted Local Plans that promote sustainable and active transport based on sufficient population
densities. The ability of new development to support public transport and active travel should be a key
part of the Sustainability Appraisal assessment,
Climate Change Adaption and Mitigation
3.17. Page 97 and Table 7.1 of the Scoping Report identify that transport makes the largest contribution to
carbon emissions (over 34%) in South Cambridgeshire. Whilst it is correct that the peat fens create
significant mitigation, the reduction of vehicular traffic and emissions from traffic is likely to have
significant impacts on climate change adaption. This lends weight to the criteria that include the ability to
reduce vehicular traffic as key assessment elements for the Sustainability Appraisal.
SA Framework
3.18. Table 11 sets to the SA Framework for the Greater Cambridge Local Plan. Paragraph 1.5 of the Scoping
Report seeks views on any additional SA criteria that should be included. MGH comments below on each
of the SA Objectives, and additional objectives that should be included to ensure a robust assessment.
Commentary is also provided on the appraisal questions associated with each objective.
SA 1: Housing
3.19. The Scoping Report identifies (as set out in the sections above) a larger number of policy documents,
from government to local level, that indicate housing is needed to support economic development; and
that high levels of economic development are required. The SA objectives (including SA objectives 14
and 15) do not include this link between housing and employment. There are two alternatives: an
objective is added, or an existing objective is amended to include an objective: To deliver sufficient
housing to support employment growth, locating new jobs near to new homes, and balancing jobs with
homes. The Appraisal questions should include: Does the Plan support increased employment delivery
with sufficient homes to support employment growth? Have homes been provided where they are
accessibility to jobs, particularly by public transport, is maximised?
SA 4: Public health
3.20. Appraisal question 4.2 touches on the issue of transport choices, but neglects any specific reference to
public transport. Studies show that increased public transport has clear benefits to activity patterns19, in
addition the removal of harmful emissions from vehicles, the increase in equality provided by public
transport, and the benefits to mental health (and productivity) in reducing commuting times. This is set out
in the Scoping Report, see inter alia paragraphs 3.14 to 3.16 above. A separate Appraisal Question
should be added: Does the Plan promote increased levels of public transport use, and better public
transport density?
SA 12: Minimising climate change
3.21. SA 12.4 relates to public transport provision, but simply asks whether the Plan supports access to public
transport. As set out above, public transport is a key element relevant to multiple factors affecting
sustainability. SA 12.4 should therefore be strengthened to read: Does the Plan support the growth of
public transport networks, modal shift away from private cars and onto public transport, and access to
public transport options?
SA 14: Facilitating the economy
3.22. The Appraisal questions included do not reflect the importance of economic growth that is highlighted in
the Scoping Report itself, and referenced above in paragraph 3.13. SA14.1 asks whether the Plan
provides for an adequate supply of land to meet Greater Cambridge’s economic and employment needs.
SA 14.5 asks whether the Plan supports stronger links to the wider economy of the Oxford Cambridge
Arc. The Scoping Report indicates a much greater requirement. Greater Cambridge is within the Arc, and
new infrastructure, including East West Rail has already been announced on the basis of higher levels of
economic growth. Government expects Greater Cambridge to deliver higher levels of employment to
support additional growth within the Oxford Cambridge Arc; and the economic reports accompanying the
evidence base produced to date (in addition to other independent research) show that substantial growth
can be achieved in the area.
SA14.1 should therefore be amended to read: Does the Plan provide for a supply of land and the delivery
of infrastructure that will meet the enhanced level of growth envisaged across the Oxford Cambridge Arc?
SA 14.5 is therefore no longer needed, but could be used as a separate question to relate the SA and
provision of employment to infrastructure. SA 14.5 should therefore be amended to: Does the Plan
provide adequate infrastructure in the right places to support enhanced levels of economic growth?
Appendix 1
Assumptions regarding distances
3.24. The assumptions regarding distances are broadly appropriate, assuming that they are applied equally to
all sites. It would be helpful to also assess sites in relation to their accessibility by bicycle, journeys which
are increasing, particularly with the rise in use of micro-transport2*** including e-bikes and scooters.
SA Objective 1
3.25. MGH propose that this objective should include a requirement To deliver sufficient housing to support
employment growth, locating new jobs near to new homes, and balancing jobs with homes. The criteria
for the assessment of this objective should not be based simply on housing need, or the proposed small
10% increase in housing need, but should instead be predicated on meeting the housing need for
employment aspirations. Without such a requirement the Plan cannot provide sufficient housing for
everyone to live in a decent home, whilst also meeting the Governments aspirations for economic growth.
The criteria should therefore be: sites that fail to provide sufficient land for total housing need to support
the highest economic forecasts will have negative effects (-). Sites that deliver sufficient land to support
the full economic projections for the area will have significant positive effects (++).
SA Objective 3
3.27. The criteria and assumptions in the Scoping Report suggest that public transport implications are
considered elsewhere and therefore do not need to be considered in relation to social inclusion and the
equality act. This approach is incorrect. Public transport is a vital element of many of the sustainability
objectives, and should therefore be considered in relation to each objective, ensuring that the weight
given to support for public transport (and modal shift away from private car usage) is equal to its
3.28. MGH propose that two criteria are added to the assessment assumptions. 1. If a site is within walking
distance of regular public transport (1 journey every 15 minutes at peak hours) it will have a neutral effect.
If a site is within walking distance of two or more bus routes with regular public transport, it will have a
positive (+) effect. If a site is within walking or cycling distance of strategic transport, such as rail, guided
bus, park and ride or proposed Cambridge Autonomous Metro, it will have a significant positive effect.2. If
a site is able to support additional public transport provision it will have a minor or significant positive
effect, depending on the quality and quantum of public transport improvements that can be supported.
SA Objective 4
3.29. This objective includes a criteria that relates to the beneficial proximity of development to healthcare
facilities. A further criterion should be added to include that: Sites that are able to deliver new healthcare
facilities within walking distance of employees or residents, will have a significant positive effect.
SA Objective 5
3.30. MGH disagrees that sites within 400m of locally designated sites will have an uncertain negative effect.
This will depend on the site’s size and ability to offer mitigation, or its ability to offer biodiversity gains in
relation to the designated site. The assumption should therefore be amended so that the uncertain
negative effects apply only to sites where development is proposed within 400m of locally designated
SA Objective 6
4.15. The impact of development at North Cambourne is difficult to categorise in relation to this objective, as it
is not specifically related to a new settlement, and therefore does not have the potential negative impacts
that relate to development Option 4. MGH await the detailed SA of sites in order to comment more fully,
but would welcome the opportunity to discuss potential impacts on the distinctiveness of Greater
Cambridge’s landscapes and townscapes in more detail. There is an opportunity at North Cambourne to
add to the distinctiveness of Cambourne, building on the existing identity of the town and creating a
strong sense of place.
SA Objective 7
4.16. MGH strongly disagrees that North Cambourne would be likely to have a detrimental effect on the
qualities, fabric, setting and accessibility of Greater Cambridge’s historic environment. There are very few
heritage assets related to the site, and impacts on them through development would be limited. This
issues can be explored in more detail during the SA of specific development sites.
SA Objective 11
4.17. The SA concludes at paragraphs 3.86 and 3.87 that because development is likely to lead to a reduction
in permeable surfaces flood risk will increase. This is not accurate. All development is required to deliver
surface water drainage in a sustainable way, including measures that mitigate against climate change. In
other words, new development will normally mitigate flood risk by providing storm water attenuation that
slows water run-off to rates based on increased rainfall. This offers flood mitigation, contrary to the initial
findings of the SA. This would be the approach adopted at North Cambourne, which lies outside of any
designated flood zones. MGH therefore expects that the detailed SA for the site will conclude that it can
provide benefits to flood risk minimisation, and adaptability to climate change.
SA Objective 12
4.18. Assessment against this objective is particularly sensitive to the provision of public transport and the
ability of development proposals to limit the impacts of vehicular traffic, as recognised in paragraph 3.92.
Option 2 (the Cambridge Airport) is assessed as being of sufficient scale to be able to deliver a range of
homes, jobs, services and facilities, which could reduce the need for people to travel elsewhere. MGH
has carried out an assessment of the potential increase in self-containment that could be achieved at
Cambourne, together with a shift away from car usage and onto public transport. The evidence to support
this approach is set out in Appendix 1, together with the assumptions made about what could realistically
be achieved. Our evidence shows that there is potential to deliver a large number of homes at North
Cambourne with a net zero (or minimal) effect on car journeys to Cambridge.
4.19. It is clear that, should new settlements (or expansions of existing settlements such as North Cambourne),
also be located on public transport corridors, they will not necessarily have the balanced positive and
negative effects of new settlements as shown in the table on p39. It is more likely that they would have
the significant positive effects associated with development Option 6.
SA Objective 13
4.20. Objective 13, similar to Objective 12, is influenced strongly by patterns of commuting and car usage. The
comments made above in relation to Objective 12 are also relevant to this objective, with likely positive
effects from development at North Cambourne.
SA Objectives 14 and 15
4.21. The assessment of this objective would be similar for Cambridge Airport and North Cambourne; or for
public transport corridors and North Cambourne. The North Cambourne proposals are of sufficient size
suitable to create a strong and vibrant community, well-connected to Cambridge with public transport,
which would be attractive to global and local employers. The provision of a mixed-use community at North
Cambourne, including a variety of employment types, would be likely to generate significant positive
effects to the economy.
4.22. MGH are mindful that this is a high level initial appraisal of options. It is clear that the MGH site, unlike
Cambridge Airport, does not fit neatly into any one of the broad development options. However, it does
benefit from the positive effects of new settlements, and the positive effects of development on public
transport corridors. MGH looks forward to the conclusions of the individual site sustainability appraisals,
and would welcome the opportunity to engage with the Councils in this process.

*Oxford Cambridge Arc, MHCLG, March 2019
**The Oxford Cambridge Innovation Arc, Savills, 2019 p3