USS supports the ambition to update the existing retail policies to reflect the new Use Class E. USS also supports the city centre approach to retail, recognising that this is the most sustainable location for such uses.

USS notes the ambition to use proposed policy J/RC to support the retention of retail and leisure
uses with the revitalisation of high streets. However, it is critical that the policy allows sufficient flexibility for complementary uses to come forward in retail areas. The well documented decline in demand for retail space means that for high streets and town centres to thrive, there needs to be an element of re-purposing and an increased leisure and residential offering in these areas. For example, footfall in Cambridge is considerably down on 2019 levels and the COVID-19 pandemic has accelerated the long-term trend of a shift to online shopping. Whilst footfall is likely to increase post-pandemic, it is unexpected to rebound to pre-pandemic levels due to the advances in online shopping and associated shopping habits.

To enable asset managers to effectively respond to these changes, proposed policy J/RC should support all uses within Use Class E in retail areas. This is vital to ensure that an overly restrictive retail policy does not stifle economic growth and risk the creation of unoccupied and/or derelict sites. USS has previously submitted the attached topic paper (Greater Cambridge Local Plan and Retail Evidence Base Response on behalf of Universities Superannuation Scheme, dated July 2021) to the Council which sets out background to the current retail trends. USS requests that this evidence is considered in the development of a more flexible retail policy.
USS is also supportive of non-Class E uses within the city centre such as cinemas and leisure facilities which can complement retail uses and ensure retail areas in Cambridge continue to flourish. Consumer demand is pivoting towards experience-led shopping destinations and accessible convenience-oriented retail places and planning policy needs to reflect this.

USS recognises that different retail areas across Greater Cambridge operate in different contexts. USS therefore supports the proposed approach of developing a specific approach to retail policy for Cambridge city centre, including its shopping centres. USS is pleased to note the following in the proposed approach: “Through development of future guidance, the Council would seek to work through the issues with landowners with the objective of achieving vitality and vibrancy for these important parts of the City.” As a major landowner of retail assets within Cambridge city centre, USS looks forward to working collaboratively with the Council on how to continue to achieve vitality and vibrancy for its assets and the wider city centre in the future. USS has previously provided the Council with a topic paper to inform the development of the retail policies and are encouraged that the Council is taking a more flexible approach to retail in Greater Cambridge.

USS disagrees with bullet point three which states that where planning permission is required, the
Council will continue to resist the loss of retail or other town centre uses in existing centres and primary shopping areas where it would undermine their vitality or ability to serve local communities. If planning permission is required, it is unlikely that the new use would undermine vitality, otherwise the use would not be coming forward. USS therefore considers it unnecessary to include this in the proposed policy. USS would also strongly object to any Article 4 Directions that sought to restrict alternative uses as these can often improve the vitality of city centres by diversifying the mixture of uses and bringing more people into city centres at different times of the day.