Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58235

Received: 13/12/2021

Respondent: Cambridge Past, Present and Future

Representation Summary:

CambridgePPF object to the scale of growth due to the lack of available water supply and subsequent damage to the River Cam and tributaries. We welcome the recognition that this environmental limit to growth must be resolved, but are concerned that water industry plans may be delayed or not fully delivered.
Predicting job growth is difficult and must be monitored throughout the plan period. Employment land in the new settlements must be safeguarded and not lost to other uses. GCSPS must work with other LAs to support the employment requirements of surrounding market towns.

Full text:

We object to the scale of growth proposed due to the lack of available water supply to support human needs without damaging the River Cam and its tributaries, including chalk streams. This includes impacts on water quality. We welcome that you have recognised this as an environmental limit to growth and that if it is not resolved the plan will not be found sound. Even if the water industry plans are put in place to address this problem prior to the Local Plan going for public examination, there will remain the risk that the water industry plans are delayed or not fully delivered. Therefore, you will need to set out in the draft plan how you intend to deal with this scenario.

Following the designation of our area as “water stressed” and the new evidence that has been obtained through your work, we are very concerned that the level of growth already in the 2018 Local Plan is beyond the environmental limits of our water supply. Water industry plans include reducing household consumption, and whilst this is in theory achievable it may not be achieved in practice. We would like to see policies or mechanisms within the draft Plan that set out how development approvals will be aligned to improvements in water supply, and what will happen if those improvements are not achieved. This is to avoid development running ahead at a faster pace than water supply improvements.

Accurately predicting future jobs and employment space, and their relationship to housing at the current time is incredibly difficult:
• The impact of Brexit on the local economy is not yet known. Many scientific and research projects were part funded by the EU.
• Some large employers are leaving Cambridge (Marshalls and the County Council).
• Hybrid/home-working will change the dynamic between where people work and where they live, this is likely to have a number of consequences for planning:
- hot-desking will increase in offices meaning that individual office buildings will support larger numbers of workers/jobs, this could decrease the amount of floor space required.
- People will commute fewer days per week and therefore will tolerate longer commutes in order to take advantage of cheaper housing (eg to afford home office space and/or garden space). On one hand this may make it harder for new housing in greater Cambridge to compete with cheaper housing further away. On the other there may be additional demand close to Cambridge for London commuters. Either way, it is unlikely that the aspiration to co-locate jobs and housing in Greater Cambridge will be achieved.
• The 2021 census might have given some answers but unfortunately this was carried out during the pandemic, meaning that an important source of planning information will not help as it should have.

Given such uncertainty, it is unlikely that the objectively assessed needs will be accurate. Therefore it is essential that there is ability within the plan to review and make adjustments over time to reflect reality. One danger is that employment land allocated for new towns is unused and applications are made for residential development instead, meaning that these settlements become residential dormitories contrary to the vision set out in the plan. As an example, we are aware that employment sites in Haverhill are now being used for residential, placing greater commuting burden on our area.

In 2019 we met with senior planning officers from East Cambs District Council. They were clear that housing provision in their district was providing housing overspill for Cambridge. They also want to create liveable communities that include employment but they reported that they were struggling to bring forward employment sites for development in places like Ely because of supply and demand provision in Cambridge. There is clearly a strong relationship between greater Cambridge and East Cambs and other market towns in terms of housing and employment provision and we would like to better understand what work has taken place to co-ordinate planning for this.