S/JH: New jobs and homes

BioMed Realty (Granta Park JCO1 Limited)

Amend
Draft Policy J/NE: New employment and development proposals states that Employment development (classes E(g), B2 and B8) will be supported in defined ‘established employment areas in the countryside’.

Granta Park must be clearly referenced within the terms of this policy. However, the boundary of the Established Employment Area much be regularised/extended to include the extant consent which was been granted under application S/1110/15/OL, which is subject to a reserved matters submission, which is pending determination. The proposed alteration to the site boundary is identified in green on the attached plan.

Support

Draft Policy J/NE: New employment and development
This states that proposals for new Employment development (classes E(g), B2 and B8) will be supported in defined ‘established employment areas in the countryside’ (listed below).

Recognising that a number of business parks are located in the rural areas of South Cambridgeshire these key employment sites outside the green belt were identified in the Local Plan 2018 as ‘Established Employment Areas in the Countryside’. It is proposed to continue this designation for the sites previously identified to support their continued evolution. The reference of Granta Park as an ‘established employment areas in the countryside’ is supported.

Comment
The ‘Established Employment Areas in the Countryside’ designation supported and must include reference to Granta Park.

Please find enclosed comments on Policy S/JH.

Section: S/JH: New jobs and homes
Whilst Bridgemere Land Plc support the approach that the Council have taken in setting a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth over the Plan period and accordingly that this needs to be supported by a higher level of housing provision in the emering Local Plan.
Full Text:
The Council states that the emerging Local Plan will meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs; and,
• 44,400 homes.

The housing figure equates to an average of 2,114 homes per annum, with a suggestion that this will meet an objectively assessed housing need for 2,111 homes per annum that has been rounded upwards in deriving the total figure. It is noted that the Plan seeks to provide for approximately 10% more homes than are calculated as being needed, a total of around 48,840 homes.

In justifying a housing need figure above the standard method, the First Proposals cite evidence assembled in the following two studies, with the higher need predicated on supporting anticipated economic growth within Greater Cambridge:

• Greater Cambridge Local Plan: Housing and Employment Relationships (November 2020), GL Hearn; and,
• Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020), GL Hearn, SQW and Cambridge Econometrics.

The latter of these two studies presents two alternative forecasts of potential economic growth over the Plan period:

• A Central Scenario under which 58,400 new jobs would be created, claimed to represent the ‘most likely outcome taking into account long term historic patterns of employment’ with the Housing and Employment Relationships study also describing it as ‘a business as usual growth scenario’;
• A Higher Scenario under which 78,700 new jobs would be created, with this ‘higher outcome placing greater weight on fast growth in the recent past, particularly in key sectors’ and the Housing and Employment Relationships study describing it as ‘a plausible but more aspirational growth outcome’.

The Housing and Employment Relationships study concludes that housing provision in line with the standard method will not support either of these economic growth scenarios. It estimates the housing need associated with supporting both as follows:

• Central scenario – 41,900 to 44,310 homes (1,996-2,110dpa) with the range reflecting alternative commuting assumptions, the upper end assuming that there is a 1:1 or balanced commuting ratio for new jobs and the lower end assuming continued in-commuting
• Higher scenario – 53,500 to 56,490 homes (2,549-2,690dpa) with the range again reflecting alternative commuting assumptions

The emerging Local Plan is proposing to deliver 44,400 homes, which supports 58,500 new jobs, aligning with the Central Scenario for growth in the District over the Plan period.

As set out in the Council’s Topic Paper on the Development Strategy (September 2021) at Section 5.3, the evidence base has identified that Greater Cambridge is a centre of excellence and a world leading economy of international importance. Whilst the focus is within the knowledge-based economy, other types of industry provide a wide diversification of jobs and services in Greater Cambridge, including education, retail, leisure, tourism and agriculture, all of which are highly important. This together with the important strategic position of Greater Cambridge within the Oxford-Cambridge Arc means that there is significant opportunity to plan for the higher jobs scenario of 78,700 new jobs, which in turn needs to be supported by a higher housing requirement of between 53,500 – 56,490 new homes to ensure that an appropriate level of market and affordable homes can be delivered within the Plan period.

Whilst Bridgemere Land Plc support the approach that the Council have taken in setting a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth over the Plan period.
Attachments:
2021_12_13_Bridgemere Representations, Hauxton_As Issued.pdf

The following is a summary of the of the overarching representations submitted on behalf of Endurance Estates by Barton Willmore. The full report is appended to these site-specific representations for completeness.
The First Proposals draft Plan sets out that the Greater Cambridge Partnership will seek to deliver an objectively assessed need of 58,500 jobs and 44,400 (48,800 inc. 10% buffer) homes during 2020-2041. This represents the Councils' medium+ growth scenario, with the maximum growth scenario (78,700 jobs and 56,500 homes) being discounted on the basis that it does not reflect the most likely level of jobs growth when reflecting on long-term employment patterns.
Within paragraph 5.22 of the Councils' Employment Land and Economic Development Evidence Study, it is in fact recommended that a preferred range for jobs growth would be 'between a central and higher growth scenario'.
The 'central' growth scenario represents an annual average employment growth rate of 1.1%. This is significantly below other assessments of growth for the Districts. The CPIER report quotes ONS 2010-2016 average growth rates of 2.4% and 2.3% across the City and South Cambridgeshire respectively, whilst their own 'blended rate' shows rates of 2.4% (equal to ONS) and 4.2% (significantly more than ONS).
These figures suggest that the First Proposals are not planning for sufficient employment growth and therefore not enough housing to support it.
The employment and housing growth figures for the Local Plan through to 2041 should be revised upwards substantially, in order to accommodate the demonstrable growth potential of the Districts.

Shepreth Parish Council (SPC) notes that the local economy will continue to expand significantly. The assumptions underlying the plan are reasonable.

An expanding economy will place added strain on an already tight housing market. SPC supports the plan to build 11,600 homes over the next 20 years.

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure with four different authorities claiming responsibility for some aspects of transport planning and delivery, coupled with the divided responsibility for rail infrastructure between Network Rail and East West Rail Company Ltd is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.

Contents
1. Summary of submission paras 1 – 5
2. Review of present proposals paras 6 – 20
3. Some official figures giving as different view paras 21 – 27
4. Consequences of adopting the proposals paras 28 – 36
5. Risk and uncertainties of present proposals paras 37 – 41
6. Absence of usual benefits paras 43 – 47
7. The decision facing the authority paras 48 – 57
8. Images – inspiring or misleading? paras 58 – 63


Summary of submission
1. The First Proposals for the Greater Cambridge Local Plan published in November 2021. Lead Councillors of both Local Authorities have welcomed their ambitious approach to meeting environmental challenges and also felt that the proposals would protect the rural areas of South Cambridgeshire from inappropriate development, although there was some note of caution as to the availability of adequate water supplies for the proposals’ full realisation.

2. While the First Proposals go some way to describing the current planning pressures, challenges and opportunities facing the Greater Cambridge area, lack the essential balance required in order to achieve an optimal outcome over the period 2021 -2041. They leave the way open for the even the minimum goals on climate change to be compromised and for significant avoidable harm to be done to the natural and built environment.

3. It is open to question whether the proposal to use a method other than the Government’s Standard Method for calculating future housing need can be justified and refers to an alternative official calculation for comparison and discussion.

4. There is urgent need for the most rigorous measures to reduce Co2 emissions to a minimum following the Government’s undertakings at the Glasgow COP 21 conference. To help to achieve this –

(i) the number of currently unoccupied dwellings in the Greater Cambridge area should be properly taken into account within the ‘in the pipeline’ figure and

(ii) the number of new dwellings in addition to that calculated according to the Standard Method should be as far as possible secured to the sole occupation of the families of employees of scientific and technical undertakings in the fields of life sciences and health care.

5. The effect of the visual image used in the public presentation of the proposals the Smart Survey and other public documents is examined. The image shows a graphic version of a tree with various benefits embedded in its foliage. It is argued that this as a misleading image as it suggests that the proposals represent to best way of achieving the benefits, whereas the benefits in question either already exist or can be achieved by other and less damaging means. The use of the image therefore indicates a significant flaw underlying the proposals.


Review of present proposals

6. The key element in the proposals is the use of a new method to be used in calculating the number of new homes required for the Greater Cambridge area up to 2041. It is set out in the GL Hearn report ‘Greater Cambridge Local Plan: Housing and Employment Relationships dated November 2020 (‘Hearn 1’), the basic principles of the approach being set out at paras 1.1 to 1.10.

7. The report proposes that instead of using the Government’s Standard Method of calculating housing need, other economic projections from various sources as to the growth of various industries in the area are used to calculate the number of jobs which would be created by the predicted rate economic expansion. The number of homes that would then be required to support these jobs is calculated from that figure by using the Standard Method in reverse.

8. The approach by the Hearn 1 study in relation to economic projections was to consider estimates of historic employment by various organisations such as the Business Register and Employment Survey (BRES), the Centre for Business Research (CBR), a study by CBR using ‘blended’ data from CBR and BRES, an East of England Forecasting Model that relies substantially on BRES and Cambridge Economics’ own estimates, similar to those underpinning BRES. These five datasets had broadly similar views on employment levels in 2017 but their rates of change back to 2011 differed, “… making future forecasting problematic.” The EEFM is an integrated model for economic, demographic and housing trends and uses forecasts by Cambridge Economics but can fail to account for rapid change occurring in some sectors.


9. The Hearn reports do not contain any reference to use of this method to date by other planning authorities, and we do not know of any such previous use.

10. The results of each of the two methods of calculating future increases in population and job numbers are very different. The Government’s Standard Method of calculating needs for homes and jobs for the period 2021 – 2041 would indicate an additional 45,800 jobs, supported by an additional 36,600 homes (Hearn 1 para 3.72 at p 32).

11. The economic-forecast-based method however would indicate the number of jobs needing to be ‘supported’ is much greater. Table 17 of the report at p 37 shows the more conservative ‘central’ estimate is 58,441 jobs while the ‘higher’ estimate (as explained at para 4.9) is 78,742 jobs.


12. To calculate the number of new homes that would be required to support these jobs, the Standard Method has then simply been applied in reverse, ‘translating’ this figure into a labour supply and population growth by taking into account the factors of unemployment numbers, double jobbing, commuting patterns and levels of economic activity.

13. The effect of commuting for the additional jobs created can be calculated by two possible methods. One is to assume the commuting patterns shown in the 2011 census remain substantially the same. The other is to assume a 1:1 relationship between jobs growth and the number of economically active residents (ie Greater Cambridge would not draw in any additional labour above that already assumed by applying the Standard Method and existing patterns).

14. The numbers of additional economically active residents needed to ‘support’ the number of jobs predicted in Greater Cambridge, applying all factors including the ‘2011 census’ commuting assumption are shown in Table 18 as 45,552 (‘central’ figure) and 63,938 (‘higher’ figure). Table 19 shows the figures using the ‘1:1 relationship’ commuting assumption. They are somewhat greater – 49,341 (‘central’ figure) and 68,525 (‘higher’ figure).

15. The annual housing growth needed to accommodate these future employees is set out in Table 22 and Table 23 on p 40 of the report. Over the 20-year period to 2041 this annual figure would require, using the 2011 census commuting pattern, 1996 x 20 dwellings (‘central’ figure) and 76,470 dwellings (‘Higher’ figure) and using the ‘1:1 relationship commuting pattern, 42,222 dwellings (‘central’ figure) and 53,800 dwellings (‘higher’ figure).


16. The Report on the Greater Cambridge Local Plan: First Proposals (Preferred Options) prepared for consultation by the Joint Director of Planning and Economic Development concludes (at p 5 - Development Strategy) that the need for jobs and homes in the context of national planning policy and guidance is 58,500 jobs and 44,400 homes. This figure of 44.400 for the number of new homes is reasonably close to the ‘Central’ figure using the ‘1-1’ commuting ratio and based on Table 23 of Hearn 1.

17. However an earlier document, the Local Plan ‘Issues and Options 2020’ document states at the Executive Summary:


“One big question affecting all these themes (Climate Change, Biodiversity and Green Spaces, Wellbeing and Social Inclusion and Great Places) will be the number of jobs and homes to plan for. Central Government has set us the target of planning for a minimum of around 41,000 homes between 2017 and 2040. We are doing more work to understand future jobs growth and housing growth to support it. However, to give an indication, if the recent high jobs growth was to continue, there may be a case for making provision beyond the local housing need to include flexibility in the plan and provide for about 66,000 homes during this period. We already have about 36,400 homes in the pipeline for this period, but it will be for the new Plan to find sites for the rest.”

18. The same passage also appears in the ‘First Conversation’ document published in January 2020, which includes a Welcome from Cllrs Tumi Hawkings and Katie Thornburrow.

19. As the Development Strategy Options Summary Report makes clear, the Councils have not at this stage reached any view on the preferred approach for the new Local Plan, so it seems that the possibility of ‘including flexibility in the plan’ allowing for 66,000 new homes as stated in the First Conversation document remains in the background.


20. This figure of 58,500 jobs is very close to the 58,441, the ‘central’ figure for Greater Cambridge in Table 17 of the GL Hearn report, and the annual number of new dwellings required is said to be 2,111, the ‘central’ figure in Table 23 of the report. An annual 2111 new dwellings over the 20-year period would produce a total of 42,220.

21. We therefore have several actively considered figures for the required number of new dwellings up to 2041. They are:
According to the Standard Method calculation –
1743 per annum x 20 = 34,860 (Hearn 1 Table 1)
‘Reverse Standard Method’ based on projected job figures -
‘Central’ figure (2011 commuting assumptions) : 1,996 pa x 20 = 39,920 (Hearn 1 Table 22)
‘Central’ figure based on ‘1–1’ commuting ratio: 2,111 pa x 20 = 42,222 (Hearn 1 Table 23)
‘Higher’ figure (2011 commuting assumptions): 2,549 pa x 20 = 50,980 (Hearn 1 Table 22)
‘Higher’ figure based on ‘1-1’ commuting ratio: 2,690 pa x 20 = 53,800 (Hearn 1 Table 23)
In the background -
Local Plan – Issues and Options 2020 : 66,000

Some official figures giving a different view

21 The employment forecasts referred to in section 5 of the Hearn EL and EN Study certainly appear to provide strong evidence of such dynamic growth over the period to 2041. The most striking information in the Study report (para 5.8) is that the 2018 Local Plan drew on EEFM data which assumed that 44,100 jobs would be created between 2-11 and 2031, in fact 35,800 jobs had been created between 2011 and 2017, 81% of the total. This observation, which tests the accuracy of previous forecasts in the light of subsequent developments, is strong and convincing and points to a rate of growth in areas such as life sciences (Health and Care and Research and Development) which is far stronger that predicted.

22 Nevertheless there must be strong reservations about the advisability of basing the planning policy for 2021 -2041 entirely on the figures set out in Hearn 1. It should be remembered that the Standard Method was introduced by the Government in 2017 in order to set an ‘ambitious target’ of providing 300,000 new homes across the whole of the UK. Far from being an outdated formula, it is a recently set, ambitious target calculated to meet the needs of an expanding economy.

23 In the circumstances it is worth bearing in mind that other statistical exercises on this question have had a very different result.

24 In August 2020 Robert Jenrick, Secretary of State for Housing, Communities and Local Government introduced a White Paper Planning for the Future. In the Introduction Mr Jenrick said that his aim was, “ … tackling head-on the shortage of beautiful, high-quality homes and places where people want to live and work … supporting sustainable growth in all parts of the country and rebalancing the economy”. The White Paper proposed inter alia that the Standard Method of calculating housing need should be revised to help to achieve this aim.


25 On 1st October that year the House of Commons Library published an analysis by the firm Litchfields which compared the results when applying the present Standard method with the results when applying the proposed Standard Method to calculate housing need in all Local Authorities. Using the current method, the new housing need for Cambridge was 1,085 homes annually while the proposed method showed the annual need was 745 per year, an actual decrease of 312 or 29%. For South Cambridgeshire the current method showed an annual need of 658 a year while the proposed method showed an annual need of 745, an increase of 87 or 13%.

26 In other words the recently proposed method of calculating housing need, designed to achieve the aims as stated by Mr Jenrick above for all parts of the country, would show that the Greater Cambridge area should plan for an annual reduction of 225 in the number of new dwellings planned for the area.


27 It would appear from the disparity between the authorities cited above that the Councils would be well advised to take seriously the qualification expressed on employment levels and therefore housing need in the Hearn 2 report at para 5.5:
“Although the above data sets have broadly similar views on the level of employment at 2017, the count and therefore the rate of change differed substantially, making future forecasting problematic.”

Consequences of adopting the present proposals

28 If we assume, however, that the figure of 44,400 new homes is the one finally adopted as policy, what are the consequences of this decision?

29 Our first concern is for the environment. The central concern of this year’s Glasgow COP Conference was to restrain the increase in Co2 emissions to 1.5% of the pre-industrial level. At the conclusion, the most optimistic answer to the question ‘Is 1.5 alive?’ was that it was on life support.


30 The National Planning Policy Framework (NPPF) states at para 7 that the purpose of the planning system is to contribute to the achievement of sustainable development, sustainable development being defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

31 The current continual occurrence of floods, fires, droughts and destructive storms over much of the globe already severely restricts the ability of many of even this generation to meet their own needs, and it can scarcely be doubted that any increase in Co2 emissions over 1.5% will further compromise present and future generations and must therefore inevitably be characterised as unsustainable.


32 Para 2 of the NPPF states inter alia that planning policies must reflect international obligations, which we believe includes the undertakings make by the UK at the Glasgow COP Conference. Within the UK, the carbon budget set out in the legislation of June 2021 requires that emissions are reduced by 63% by 2035. The need to achieve the true purpose of the planning system, to contribute to sustainable development, must mean that in the current situation there is a particularly urgent duty on planning authorities to take the strongest and most rigorous means of ensuring that the carbon footprint of any development, whether arising from its nature or its extent, must be kept to its absolute minimum.

33 The present proposal is that 44,400 new homes are to be constructed over the 20 years to 2041. According to an article by Sir Mike Berners-Lee in the Guardian on 14/10/2010 to build a simple two-bedroom cottage at that time, ie the production of the materials and the construction of the building, would create 80 metric tonnes of embodied Co2, and the building would then emit 2,5 metric tonnes of Co2 annually.


34 The UK Green Building Council’s 2021 ‘Construction Carbon’ report says that since that time, “efforts to improve the energy of buildings has seen an impact on operational Co2 emissions while embodied carbon (ie that created by producing the construction materials and by the building process itself) have remained stubbornly consistent at 50MtCo2e.”

35 According to Hearn 1 above, the Government Standard Method of calculating housing need would produce a figure of 34,860 new homes. The current proposal is to build 44,400 new homes, ie 9,640 additional to the Standard Method figure. If this were rounded up in practice to 10,000 additional homes, a conservative estimate of the additional Co2 created can be calculated on the assumption that since 2010 the amount of embodied carbon could be reduced by 25% and of operational carbon by 50%.

36 The above figures are included for illustration and to promote further research. On this basis, however, a conservative estimate would be that 600,000 metric tonnes of Co2 would be produced by the initial building process and 12,500 metric tonnes would be produced annually, pro rata to construction up to 2041 and in full thereafter.

37 To put this into context, the whole of the City of Cambridge produced only 489,000 metric tonnes of Co2 emissions in 2019, with South Cambridgeshire producing 1,213,000 metric tonnes – a total of 1,702,000 metric tonnes (Data Tables – UK Local and Regional Co2 Emissions published by the Department for Business and Energy June 2021). An annual addition of 12,500 metric tonnes would increase this total to 1,714,500 metric tonnes, cancelling out almost two years of carbon reductions over the Greater Cambridge area.


Risks and uncertainties underlying the present proposals

38 The Councils’ Topic Paper 2 on Climate Change published in September 2021 refers at p 9 to s 182 of the Planning Act of 2008 which places a duty to ‘secure the contribution of development and the use of land in the mitigation of climate change’. It also acknowledges at p 10 the target set under the Climate Change Act as amended in May 2019 for reductions of emissions to net zero by 2050. We believe that the earlier duty to secure the ‘contribution’ of the development to the ‘mitigation’ of climate change is now far too weak to ensure the action needed to deal with the real danger that climate change now poses, and would to that extent be incompatible with the legal duty created by the target set by the May 2019 amendments to the Climate Change Act.

39 The paper refers to the March 2021 report of the Cambridge and Peterborough commission on Climate Change. In their initial recommendations they note at p 11 that,
“…the region’s emissions are approximately 25% higher per person than the UK average, and that if the area continues on this trajectory, we will only have six years remaining before we have exhausted our ‘allowed’ share on emissions to 2050. Urgent action is therefore required, with the report noting that local government powers in transport and planning, amongst others, will be critical in driving transformation.”

40 It is incumbent on the Greater Cambridge as a planning authority to be aware that the urgency of our situation with regard to climate change has altered significantly since 2008 and now to readily acknowledge the implications of the later legislation.

41 Most of the language in the Topic Paper itself however appears to be inspirational rather than informative. The environmental principles for the Oxford-Cambridge Arc include ‘working towards’ a target of net zero by 2040. New settlements will ‘contribute towards the achievement’ of net environmental and net carbon zero. There is a ‘vision’ for Cambridge to be net carbon zero by 2030, ‘subject to’ actions by Government, the regulators and industry. On p 16 it is noted that, “ … with net zero carbon comes the need to change the metrics used to define the performance of buildings. It is clear … that buildings constructed using current metrics are not performing as they should and that a new approach is needed …”


42 Topic Paper 2 dealing with climate change appears to some extent to be a document of signposts rather than milestones. The signposts are useful and the result of good work, but are of questionable value as a basis for policy. Section 4.5 does set out many specific technical requirements for operational emissions, in particular the requirement that all new domestic and non-domestic buildings ‘should achieve’ a space heating demand of 15 – 20 kWh per meter squared a year in accordance with the CCC’s ‘Housing Fit for the Future’ report. However wording such as ‘should achieve’ indicates that the aspirational element is still present and in relation to embodied carbon the document simply states at page 14 that ‘consideration will be given’ to the carbon associated with the construction process, and acknowledges at page 17 that,

“ … there are no nationally defined targets for reducing the embodied carbon associated with new developments. A further challenge faced by the industry is a lack of consistent measurement, leading to mis-aligned benchmarks, project targets and claims.”

43 This uncertainty with regard to fundamental environmental considerations is of course also of great concern in the case of water, in relation both to the possible – even probable - inadequacy of supply and also to the inevitable damage to the County’s system of chalk streams and associated wildlife. As is highlighted in the Executive Summary to the GCLP: First Proposals (Preferred Options) (Regulation 18) consultation paper:

“The First Proposals make clear that the proposed development strategy is contingent upon there being clear evidence that water supply challenges can be addressed before the plan moves to the draft plan stage.”

Absence of usual benefits of development

44 With regard to the proposed developments, the Hearn 1 report acknowledges at para 3.68 that as far as unemployment is concerned, “for the purposes of this report it has been assumed that there are no changes in the number of people who are unemployed moving forward from 2020 to 2041”.

45 It is also argued that the housing situation in Greater Cambridge is subject to the pressures of a speculative bubble which is of no benefit to the majority of ordinary residents and that the proposed development offers little in the way of relief because of the distorting effects of speculation.

46 As the Hearne HER Report makes clear at para 3.4, the ‘affordability’ step in the Standard Method already makes provision for increase in housing to the point where dwellings become affordable by applying a formula which relates the local median price of homes to median workplace earnings.


47 Further, the Report states in relation to employment figures at para 3.68 that, “The analysis shows a clear increase in unemployment until about 2010 -11 and that since then the number of unemployed people was back close to (or below) the level observed in 2004. This would indicate that there may be limited scope for further improvements and for the purpose of analysis in this report it has been assumed that there are no changed in the number of people who are unemployed moving forward from 2020 to 2041.

48 It is therefore difficult to see that any departure from the Standard Method of assessing housing need can be justified either in relation to any improvement in housing provision for the existing or predicted population or in relation to any reduction in unemployment figures in the joint planning area.

The decision facing the planning authority

49 The Greater Cambridge as a planning authority is now in an unusual and critically important position. It has to make its decisions where we can see an unprecedented risk of harm to the environment but can also see unprecedented opportunity for nurturing scientific developments which can bring huge benefits to human society in the UK and the world.

50 There is a third factor however which complicates the situation and makes decisions and policy implementation still more difficult. This is the development, in parallel with the expansion of scientific and technical research in the area, of a speculative property bubble, as a result of which property in Cambridge can become, and in many cases has become, simply a vehicle for opportunistic speculative investment, of no benefit either to ordinary residents or to the scientific community. Construction and development of property for this purpose contributes to the damage to the environment without furthering or supporting scientific and technical research.

51 In light of this, the aim must be to influence future job creation in such a way as to achieve the best possible outcome, not only in terms of the prosperity and wellbeing of the planning area itself but also in terms of a proper contribution to the prosperity and wellbeing of the UK as a whole.


52 The challenge now facing the Greater Cambridge planning authority is, in the current critical post-COP 21 situation, to balance these three factors so as to achieve the optimum outcome in relation to the economic, social and environmental objectives as set out at para 8 of the National Planning Policy Framework (NPPF).

53 It would appear, therefore, that interests of the scientific and technological and also the environmental factors would be better promoted, and the influence of the third factor – the speculative property bubble – restrained, by a decision to take the following measures:


i. To ensure that the total of existing unoccupied dwellings (above the normal percentage to allow for turnover) was established and included in the ‘already in the pipeline’ figure in calculating the number of new dwellings required, and to explore all possible means, by incentive, penalty or otherwise, of ensuring that such unoccupied dwellings are let or sold within a reasonable time, and

ii. To set the requirement for the number of additional new dwellings above that set by the application of the Government Standard Method at the number of new dwellings directly and specifically related to identified and authentic scientific and research undertakings in the Greater Cambridge planning area, with the future sale of such dwellings restricted by covenant or otherwise to purchasers primarily employed in such undertakings.


54 The effect of the first measure would be to allow the most realistic figure to be arrived at for the number of new dwellings required, while the second measure would operate to restrain unjustified speculative building while at the same time sustaining scientific and technological research and development. The fact that new employees in scientific and technical undertakings could be properly housed outside the conventional housing market would of course to that extent reduce the number of buyers in the conventional market and so operate to increase affordability.

55 The second measure would appear to be appropriate in relation to developments such as the Addenbrooke’s Hospital and Cambridge Biomedical Campus, Brabraham Research Campus, the Wellcome Trust Genome Campus, Granta Park, Sagentia Research Park, Melbourne Science Park, St John’s Innovation Park and the Cambridge Science Park.


56 A policy of allowing certain new dwellings only if they are to be occupied by people employed in a certain industry would be similar to existing policies in relation to new dwellings for employees in the agricultural industry, and would be amply justified by the particular situation in the Greater Cambridge area relation to the need to promote local scientific industries in the critical context of current climate change.

57 Planning conditions used to achieve the purpose of the second measure set out at (ii) above would we believe be based on considerations which would satisfy the test as material considerations established in Newbury DC v SoS for the Environment [1981] HL and in R (Wright) v Forest of Dean DC and Resilient Energy Severndale Ltd [2019] UKSC.

58 It must be the case that permissibility of the developments in all proposed sites in the joint planning area is contingent upon this, as even where a particular development itself is found to meet all relevant planning criteria, its permissibility will automatically fall into question if the overall increase in number of dwellings over the period to 2041 cannot be justified in planning terms.


Images – inspiring or misleading? The underlying flaw in the proposals

59 In its public presentation of the current proposals, the Planning Authority has used a striking image which appears in the Opus consultation document ‘Greater Cambridge 2041’ above the words ‘Our Vision’, on the front of the Smart Survey document in the First Proposals and in the Summary of the GCLP Issues and Options 2020. It is of a tree with four areas of leafy vegetation, the top one being ‘Climate Change’, the second ‘Biodiversity & Green Spaces’, the third ‘Wellbeing & Social Inclusion’ and the fourth ‘Great Places’.

60 There are two messages conveyed by the tree image. The first is that the tree – which symbolises the proposals – will bring four benefits, ie an improvement of our position with regard to climate change, provision biodiversity and green spaces, the fostering of wellbeing and social inclusion and the creation great places. The second message conveyed by the tree is that the tree, ie the proposals, is/are the essential means by we can achieve these benefits.

61 The image is misleading because either we already have the benefits are promised, without the implementation of the proposals, or they can be achieved by other simpler and less destructive means. In fact the proposals will degrade, to an indeterminate extent, our position with regard to climate change. The biodiversity and green spaces already exist. The ‘great places’ already exist and the proposals will to an indeterminate extent urbanise them. Any improvement in wellbeing and social inclusion can and should be achieved by simpler and more practical measures which operate on a smaller scale and answer to the real needs of the people they are meant to serve, one example being community and mutual schemes to reduce unemployment in the Arbury ward which the Hearn 1 report says will not be changed by the proposals.

62 It is of course to be welcomed that any development will have well-constructed, well- designed buildings, and will be planned in such a way as to promote and sustain wellbeing and a thriving local community. It would however be wrong to attempt to justify the proposals in these terms, because the benefits shown on the tree either already exist, and would be inevitably diminished by the proposals, or they can be achieved by other simpler and less otherwise harmful means.

63 The only justification for the construction of more dwellings than the Standard Method requires is the need to foster and sustain the remarkable advances in life sciences and healthcare led by the particular strength of scientific and technical expertise in Cambridge and the surrounding area. The Planning authority should use all its powers to ensure that the number of additional dwellings is sufficient for this purpose but should not go beyond it, as to do so would inevitably, to a greater or lesser extent, imperil our position with regard to climate change at this critical time.

Introduction
Thank you for consulting Central Bedfordshire Council (CBC) on the first proposals consultation for the Greater Cambridge Local Plan 2041. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continuing the good working relations that CBC has already forged with the two substantive authorities. We have provided some comments below on the consultation documentation which we hope are useful. Please do not hesitate to contact us if you have any further questions.

General Comments on Strategy

Overall, the Council supports the approach you have taken in terms of undertaking a joint local plan to ensure a consistent approach to planning and building across both Cambridge City Council and South Cambridgeshire District Council up to 2041.

We support the proposed Vision for the Greater Cambridge Plan especially as it places climate impacts at the heart of key decisions. It states that Greater Cambridge will be a place where a big decrease in your climate impacts comes with a big increase in the quality of everyday life for all your communities. It also promotes new development minimising carbon emissions and reliance on the private car; creating thriving neighbourhoods with the variety of jobs and homes you need; increasing nature, wildlife and green spaces; and safeguarding your unique heritage and landscapes. CBC considers this to be a laudable, succinct overarching Vision that we hope you will be able to carry through to effective policy and decision-making on the ground.

CBC considers that the proposed strategy outlined within the First Proposals could help ensure that Greater Cambridge makes a valuable contribution to the Oxford to Cambridge Arc and to the overall delivery of the Government’s ambitious growth aspirations. However, the Council considers that it would be useful to include reference to the emerging Arc Spatial Framework, identifying that alongside the NPPF, this will set the overarching strategic framework for the area with which all local plans within the Arc must accord. CBC would be keen to understand the timescales for the delivery of the Greater Cambridge Plan and how the emerging Spatial Framework will be taken into consideration to inform future iterations of the plan.

We appreciate that the Plan is at an early stage of development, and at the current time you are considering locations that could be delivered alongside allocated sites being carried forward from the adopted 2018 Local Plans for Cambridge and South Cambridgeshire, as well as sites which already have planning permission.

We note that you are proposing to meet in full your objectively assessed needs of 44,400 new homes to 2041, which is supported by CBC and is necessary to ensure needs can be met across the area.

CBC recognises that Cambridge has seen significant economic and jobs growth in recent years and that there is an ambition to maintain this direction of growth as the impacts of the recent pandemic subside. As stated in our comments made in response to your Issues and Options Consultation in February 2020, we would not support a level of jobs growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations. CBC therefore supports the housing numbers proposed to meet the OAN and the identified buffer and welcomes the move away from the higher job number which were put forward in your Issues and Options consultation. We agree that the higher jobs forecast previously considered would not be the most appropriate scenario to pursue. Overall, CBC considers that the proposed level of housing of 44,400 new homes and complementary economic growth of 58,500 new jobs across all sectors including business, retail, leisure, education and healthcare, is an appropriate level of growth to deliver for over the plan period.

The First Proposals have suggested 19 new possible locations that might be suitable for additional development to meet your needs across the Greater Cambridge area up to 2041. Overall, CBC supports the proposed approach taken to the geographical spread of these sites and welcomes the inclusion of sites in the most sustainable locations around the Cambridge urban area and on the outskirts of the City, where existing and future residents can take most advantage of the proximity to jobs and services using public transport and active travel options. The proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice is logical and fully supported.

It is noted that the consultation material suggests that the majority of your objectively assessed need can be provided for in the core preferred strategic sites of North East Cambridge, Cambridge East and Cambourne. This approach is supported as the locations will reduce potential climate impacts through the delivery of well connected, sustainable, compact development where active and sustainable travel can be maximised.

CBC have not provided detailed comments on all of the proposed 19 sites included within the consultation material but note the proposals for new strategic scale development at Cambourne which lies in close proximity to Central Bedfordshire. It is noted that in total, there are 3 development sites proposed for Cambourne - two of these are existing allocations; Cambourne West which has capacity for 2,590 units and Bourn Airfield which has capacity for 2,460 units, alongside a new proposed broad location for growth at Camborne - expected to deliver 1,950 homes.

CBC recognises that whilst a final decision has not yet been announced, the preferred East West Rail route between Bedford and Cambridge will likely result in a new stopping station at Cambourne and that this will transform the area, maximising sustainable opportunities for growth. Whilst we support the opportunities that the proposed new station would potentially bring, CBC would suggest that any future transport impact assessments and traffic modelling associated with the proposals should consider the cumulative impacts of both existing and proposed development at Cambourne and any implications for the wider area, including potential impact upon the strategic and local road network within Central Bedfordshire. It is likely that there will be cumulative impacts from growth at Cambourne on communities within CBC related to an increase in demand on the A1, particularly if / when the A428 dualling and Black Cat works are carried out, and also the more minor roads through areas like Potton, Sandy, Biggleswade. Whilst outside of the Greater Cambridge plan area, the capacity of the A1 in this area is already a key concern that affects a much wider area and must be considered carefully and comprehensively when decisions are being made in relation to future growth.

We would, therefore, welcome further engagement to understand the scale of those impacts and their likely implications for Central Bedfordshire communities as the work on the local plan and the sites themselves, progresses. We would welcome being involved in early engagement with National Highways in relation to these impacts. We would also be keen to look at opportunities to secure sustainable links (via public transport) between CBC and the development areas to the west and south of the Greater Cambridgeshire area.

As noted above, whilst a formal decision is yet to be announced in relation to EWR between Bedford and Cambridge, or indeed the location of a new stopping station at either Tempsford or to the south of St Neots, CBC consider it essential that the Greater Cambridge Plan considers the wider context of strategic growth within the Arc, particularly in terms of future connectivity opportunities that will undoubtedly arise as proposals within neighbouring authority areas emerge. Your approach to enabling some development within smaller villages is supported as this will support rural services and the vitality and viability of villages and their shops and services contributing to overall sustainability. We appreciate that it is unsustainable to encourage high levels of growth where car travel predominates and that therefore, in smaller villages you will continue to support infill development and affordable housing on suitable sites only. This approach is supported, especially given the very rural nature of the areas close to the Central Bedfordshire border.

The 7 Themes
We welcome the approach taken in this consultation to identify 7 key themes and we have provided some high-level comments on each of them below. It is understood that each of the themes will influence how you will plan homes, jobs and infrastructure and ultimately where growth will be directed. In our previous response to the Issues and Options stage of consultation (February 2020) we suggested that “connectivity” both within and beyond the Greater Cambridge area should perhaps be considered as an additional theme. Whilst we note this suggestion has not been taken onboard, CBC considers that connectivity is the ‘golden thread’ that runs through all the key themes and could potentially be referenced as such within the Greater Cambridge Plan.

Climate Change
We support your aim to help Greater Cambridge to transition to net zero carbon by 2050 through a number of comprehensive measures including ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks. It is clear that responding to climate change has influenced the shape of the plan as an important factor in determining where future development should be located and how it should be built. CBC would be keen to have future conversations to share experiences and to understand how net zero carbon can be achieved in terms of viability, and to explore how this can be monitored to ensure the approach is successful. In terms of detailed policy, Policy GP/QD could benefit by also referring to building orientation to maximise the opportunities for renewables.

Biodiversity and Green Spaces
We support your aim for biodiversity and green space policies to increase and improve your extensive network of habitats for wildlife and green spaces for people, ensuring that development leaves the natural environment better than it was before. We also welcome confirmation that the Oxford to Cambridge Arc Environmental Principles have informed your approach to this theme, in particular, we welcome and support the ambitious policy to require 20% Biodiversity Net Gain. As this will be an issue for all Local Authorities within the Arc, CBC would also be keen to discuss how this could be delivered and the impacts this might have not only on site viability, but
the delivery of other key services and facilities across the Arc .

Wellbeing and Social Inclusion
We support your aim of helping people in Greater Cambridge to lead healthier and happier lives ensuring everyone benefits from the development of new homes and jobs.

Great Places
We support your aim for the delivery of great places through policies that sustain the unique character of Cambridge and South Cambridgeshire and compliment the area with beautiful and distinctive new development, creating a place where people will want to live, work and play.
The themes from the Cambridgeshire Quality Charter for Growth covering the four “Cs” of Community, Connectivity, Climate and Character is a sensible approach consistent with the National Model Design Code.

Jobs
CBC supports the aim of your proposed jobs policies in terms of encouraging a flourishing and mixed economy which includes a wide range of jobs while maintaining the areas global reputation for innovation. The Council considers the policies are positive and forward thinking in the current climate in that they seek to reflect how the approach to working environments is changing, by supporting remote working and improving facilities on employment parks.
We support the inclusion of a remote working policy but consider that it could be strengthened to refer to the provision of home office space in new dwellings as the emphasis is currently on the delivery of external hubs or extensions of existing dwellings.

Homes
As commented above, the Council supports the proposed strategy to plan for and deliver enough housing to meet your objectively assessed needs, including significant amounts of affordable housing and a mix of tenures to suit your diverse community’s needs. The proposed policy requiring 40% affordable housing in new developments is particularly supported.

Infrastructure
We support the approach taken that the relationship between jobs and homes and sustainable transport opportunities has been a key consideration and influence of the development strategy proposed. Recognising that infrastructure is not limited to the provision of new roads, CBC also supports the recognition for the need to consider and plan for water, energy and digital networks, and health and education and cultural facilities in the right places and at the right times to ensure your growing communities are supported. Looking to the future, your policies on electric vehicle charging points and digital infrastructure will be key given the need to move away from carbon-based vehicle fuels and the shift to homeworking that has been accelerated by the pandemic. We also note that whilst there is an objective for Air Quality within the Sustainability Appraisal, there is no objective included for Transport and Access.

We welcome this opportunity to comment on this latest stage of your development plan proposals and largely offer our support to the approach you have taken. We also appreciate how you have digitally presented and structured the documentation in order to make it as accessible as possible to everyone. The use of maps and diagrams throughout the document is an effective way of setting out the context and portraying the information within the text. In addition, the ability to explore the documentation through the “themes” and “maps” is a particularly helpful way of organising the consultation.
I hope you find these comments useful and look forward to continued engagement as your plan progresses.

Swavesey Parish Council Greater Cambridge Local Plan First Proposals: Consultation response 14th December 2021

Swavesey Parish Councillors have examined the proposals in the draft plan and are extremely concerned about the impact of the proposed growth on flooding and whether there is adequately planned infrastructure. Parish Councillors are also very concerned over the level of housing growth proposed and how the infrastructure, particularly in South Cambs, will cope, such as roads, increase in traffic, social services and health provision. Specific concerns are detailed below.

Flooding
Flooding in Cambridgeshire is increasing. The instances of prolonged heavy downpours of rain and the inability of the existing foul and surface water infrastructure to cope with this deluge of water is extremely concerning. Especially within village communities. Within the current growth of housing development in Cambridgeshire, the foul water infrastructure is already nearing capacity and the increased pressure on this will be unsustainable. The infrastructure required to deal with increased foul and surface water resulting from current developments is not sufficient. Foul water is being pumped long distances to existing treatment works and then treated water pumped through to the river via villages and communities which are miles away from the new developments. The flood risk in doing this increases for communities which are not in the new development areas. Swavesey in particular is having to cope with huge increases in treated water flowing through its drain system to the River Gt Ouse from development in Cambourne, Northstowe and yet to come from Bourn airfield site. These developments continue to increase and all of that water puts excessive flood risk on Swavesey.

Surface water management.
The existing surface water system is failing and often unable to cope with the changes we are experiencing in weather as well as increased development pushing more water into the system (rather than soaking into greenfield sites). This is happening now in Swavesey where properties have flooded due to surface and foul water systems unable to cope within the last year. Exacerbated by new development in the village. Proposals to continue to develop greenfield sites and increase housing and business development will increase flood risk. Proposals for new business development at land south of the A14 Cambridge Services (promoted by JAYNIC) raises strong concerns by Swavesey Parish Council. This will create increased foul and surface water flows into the Swavesey system on top of those already mentioned above. This is just not sustainable.

Water supply
Councillors are concerned about the level of housing being proposed and how those houses will be supplied with fresh water. The draft Local Plan states that ‘new sources of water supply, including potential new reservoirs, are being developed but won’t be built quickly enough to supply housing when it is needed. Without speeding up that process and additional interim action, development levels may have to be capped to avoid unacceptable harm to the environment, including the region’s important chalk streams. This may lead to housing in the area becoming even more unaffordable so that those who work in Greater Cambridge may have to commute from further afield, increasing carbon emissions and congestion. We are hoping for quick and decisive action on this from central government and the water industry.’ Additional information states that development won’t go ahead without a resolution to the water supply issue. We strongly urge the authorities to maintain this commitment.

Health and social care provision
Health and care services in Cambridgeshire are under severe pressure as they try to recover from the pandemic. There is a chronic shortage of workforce, particularly GPs, which means that waiting lists for consultations, treatment and care are long and increasing. We are concerned that the proposed increases in population will put more pressure on these already fragile and underfunded services. The current system for increasing provision is fragmented and frequently does not result in any increase.

Traffic and travel
Councillors are also concerned about transport and roads to and from new development sites. In Cambridgeshire if the new East-West Rail goes ahead a new rail station will be built at Cambourne. This will increase the traffic on the roads to/from Cambourne and many of these through and around the villages to the north cannot cope with existing traffic levels let alone increased levels. The funding to Cambridgeshire County Council for general highway maintenance cannot cope with existing demands.

Proposals for business development at land south of the A14 Cambridge Services will create increased traffic, particularly of HGVs in this area and around the already busy Swavesey A14 junction. Swavesey Parish Council has raised concerns with JAYNIC the proposer of the site, however these concerns must be considered within this Local Plan proposal and by Cambridgeshire Highways as the impact the increased traffic will have, will affect villages surrounding this site. This site is in addition to the already being developed business site at Bar Hill and another proposed business site at Slate Hall Farm, off the A14 and as well as the Northstowe development close by. The Parish Council cannot see how all of this is going to be sustainable in this area.

Quality of consultation information
We note the complexity of the information contained in the Local Plan and would observe that it is not easy for local people to understand the proposals sufficiently to meaningfully comment. We would ask that future consultations use simpler language and format. Testing readability of materials with non-planning people could help with this.

Compendium of Environment Agency Comments

Vision and aims
The vision on page 20 is positive bringing to the forefront decreasing climate impacts, minimising carbon emissions, increasing nature, wildlife and green spaces. Reflecting on the paragraph on page 18, you outline the aim for the Local Plan is simple: to ensure sustainable development. This means planning for homes, jobs and supporting infrastructure in the right places, alongside protecting and enhancing the environment. We recommend the vision reflects this objective of ‘sustainable development.’ For example, we suggest the following revision as follows: New development must be sustainable: minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes. This will align closely to the aims of the NPPF (paragraphs 7 and 8) and also demonstrate the importance of this for Greater Cambridge given the unique challenges and opportunities the area faces.

We support the references within the aims to highest achievable standard for water use and resilient to current and future climate risks. The biodiversity and green spaces aim is also positive in its focus on improving the network of habitats and ensuring development leaves the natural environment better than it was before. All these aims will help GC achieve the stated vision and it’s important that the interrelationship and interdependencies between these aims are recognised. Recognising the interdependencies will strengthen and ultimately achieve better outcomes for GC. One example is the ecological health and water quality of rivers and water dependant habitats (e.g. wetlands) is also dependent on the availability of water in addition to the contribution developments will make in creating and enhancing habitats and green space. Healthier rivers and water dependant habitats will in turn restore nature, improve the health and wellbeing of communities and have economic benefits. Serving the environment in tandem with growing communities is mutually beneficial and secures long-term resilience. This also reflects the paragraph 153 of the NPPF: ‘plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes’ etc.

S/DS Development Strategy
We welcome the section on ‘Ensuring a deliverable plan – water supply’ on pages 41 and 42, which recognises this as a significant issue for the Local Plan. We remain genuinely concerned about whether the growth proposed (48,800 new homes inclusive of 10% buffer and 37,200 from previous plans) can be sustainable without causing further deterioration to the water environment. We understand the regional and water company water resource planning is still ongoing and the next version of the IWMS Detailed WCS will be updated as these plans come to fruition. We offer our support to work collaboratively with all the parties involved.

Current levels of abstraction (not just in Cambridge) are causing environmental effects. Increase in usage within existing licenced volumes will increase the pressure on a system that is already failing some environmental targets. The Anglian River Basin Management Plan shows many waterbodies do not have the flow required to support the ecology. Abstraction licencing reductions are likely to reduce the supplies available to water companies in our efforts to prevent deterioration of the water environment. As the plan and evidence base progresses it will need to be clearly demonstrated that the water companies plans can meet the needs of growth without causing deterioration.

As a best case scenario the strategic water infrastructure (new Fenland reservoir) would be available from the mid-2030s and its foreseeable this could be later i.e. the 2040s. It is the short to medium term period coinciding with the majority of the plan period for which rapid and viable interim solutions are needed. There is currently uncertainty about whether water supplies can be provided (both supply and demand management) in a way that is both sustainable and sufficient for the proposed growth over the plan period.

We support the idea of development limited to levels that can be supported by a sustainable water supply (phased delivery) until the time the strategic infrastructure is in place, though we are mindful this may lead to heavily back loaded delivery. If the Council approaches neighbouring local planning authorities as you already recognise it is likely they will have similar issues, though some may have more options for interim solutions. This highlights the importance of cooperating across planning boundaries and growth plans being considered in the context of the combined pressure on water supplies at a regional scale. As previously mentioned, 2050 may be a more appropriate end date for the plan period given the challenges being faced which in reality require a longer lead in time to support development, e.g. strategic water resources infrastructure, climate change resilience, etc. This would also align with paragraph 153 of the NPPF ‘plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes’ etc.

Integrated Water Management Study – Outline Water Cycle Strategy
The WCS will rely on further evidence coming forward from both regional and water company water resource plans. The WCS will need to demonstrate that feasible and deliverable mitigation measures are available for the interim period until new strategic water resources options will come online.

As noted, the WCS will need to base its assessment on the forthcoming water resource plans (WRMP24) rather than the existing, as this will have a more accurate picture of the water resources situation taking into account abstraction licence reductions. Both Cambridge Water and Anglian Water are likely to require further sustainability reductions in PR24. This could mean some or all of the current water surplus’s (available headroom) are no longer available for transfer.

The reliance on demand management options is currently high-level. These will require assessment of feasibility, effectiveness and how implementation will be monitored and measured corrected if they are not working.

In facing what is collectively a significant challenge we offer our support to work collaboratively with the interested parties ahead (and beyond) the next consultation in 2022.

S/NEC: North East Cambridge
We note the intention of the policy is to set out the place-making vision and a robust planning framework for the comprehensive development of this site. There are both environmental risks and opportunities to developing this site sustainably. Ensuring sustainable water supplies, improving water quality and the effective remediation of land contamination will be key considerations in achieving this. The proposed policy direction anticipates the site (once developed in full, which will extend beyond the Local Plan period of 2041) will deliver 8,350 new homes. The IWMS Detailed WCS will need to provide evidence the new homes (and employment) can be sustainably supplied with water in time for the development phases.

The existing site at Fen Road, Chesterton continues to be a source of ongoing local water quality and environmental health problems due to inadequate foul drainage provision. There have been a number of reports of foul sewage from the site discharging into the River Cam, causing chronic on-going pollution. The relocation of the existing Milton sewage works and extensive redevelopment of North East Cambridge presents the opportunity to incorporate mains drainage connection into the Fen Road site.

Policy S/NS: Existing new settlements
With regard to the existing allocations NS/3 and SS/5 Northstowe, we are investigating flood risk management options to reduce the risk of flooding in Oakington. This will take account of measures looking to attenuate water upstream (on the upper reaches of Oakington Brook and as part of the Northstowe development), potential channel modifications and natural flood management. We note that early phases of Northstowe are under construction. We recommend the emerging policies include this as an opportunity both in terms of delivering flood risk management measures or securing financial contributions towards this project.

CC/WE: Water efficiency in new developments
We support stringent water efficiency in water stressed areas. We recommend reviewing the document The State of the Environment: Water Resources (2018) prepared by the Environment Agency. This document outlines the challenges we now face summarised as follows. Water supply (resource) is under increasing pressure from population growth, land use change, and climate change (including hotter weather increasing evaporation, less rainfall in summer, and intense rainfall events not recharging aquifers efficiently). Without increasing our supply, reducing demand, and cutting down on wastage many areas will face significant deficits by 2050, if not sooner. If not addressed this represents an immediate and measurable blocker to future growth. We need to consider development in the context of available water resources, balancing economic growth with protecting and enhancing the water environment. We will need to ensure that there is enough water for both people and the environment, that water is used efficiently, that water is protected as a precious resource, and that wastewater is treated efficiently to cut associated carbon emissions.

We agree the evidence of the water resources situation in Greater Cambridge justifies the tighter standard of 80 litres/person/day for housing. The risk of this standard not being met is an increase in abstraction risking deterioration of associated water bodies. As page 150 recognises (with reference to the Deregulation Act 2015) GC Council will need to be satisfied that this standard can be legally and practically implemented in the context of current legislation (Water Industry and Development Industry), national policy and building regulations. This affects the practical implementation of this policy. It would need to be determined the evidence/metric applicants would be expected to submit to demonstrate this standard has been achieved. It would also need to be evidenced how the policy standards would be implemented, and how this would be monitored to ensure the policy is effective.

A positive standard is proposed for non-residential development, which we support. Water neutrality should also be explored, noting the references made to water reuse and offsetting.

The Integrated Water Management Study (IWMS) states that 80 litres/person/day is achievable by making full use of water efficient fixtures and fittings, and also water re-use measures on site including surface water and rainwater harvesting, and grey water recycling. It comments that the cost effectiveness improves with the scale of the project, and that a site-wide system is preferable to smaller installations.

Currently the policy direction has a caveat of ‘unless demonstrated impracticable.’ This should be explored further in the WCS so the Council has clear guidance on the circumstances where achieving this standard would be impracticable. This will help ensure planning applications can be fairly and reasonably assessed. This will also help ensure the overall goal of the policy is not weakened or undermined. Similarly this evidence needs to be drawn out for the non-residential standard. The WCS should also set out the backstop position should the standard of 80 litres/person/day be practicably unachievable.

Although we support water efficiency measures in new development, we consider that the plan is currently unlikely to achieve the kinds of reductions in demand needed to keep the proposed levels of growth within sustainable levels. As noted with policy S/DS, the evidence base (IWMS Detailed WCS) will need to demonstrate how the water companies’ plans can meet the needs of growth without causing unsustainable abstraction and associated deterioration. We offer our support to work on this collaboratively with the interested parties both ahead of the next consultation in 2022 and beyond.

Page 150 references the Shared regional principles for protecting, restoring and enhancing the environment in the Oxford-Cambridge Arc. We recommend this is also considered and referenced elsewhere in the plan with regards to net zero, net gain, tree cover and strategic resource infrastructure provision.

CC/DC: Designing for a changing climate
The proposed policy intends to set out how the design of developments should take account of our changing climate, for example, extreme weather events including flash flooding. We welcome the reference (p. 152/153) to site wide approaches to reduce climate risks, including sustainable drainage systems as part of landscape design, urban greening, increased tree canopy cover and integrating green spaces into new developments. In the context of flooding and climate change it would also be appropriate to reference flood resistance and resilience measures (see PPG: https://www.gov.uk/guidance/flood-risk and-coastal-change#Flood-resilience-and-flood-resistance). Site wide approaches should also include adaptive measures such as setting a development away from a river so it is easier to improve flood defences in the future. In addition, making space for water to flood and be stored will be critical to long term adaptation. Planning to avoid future flood risk is as much about creating storage or contributing to nature based flood risk reduction measures (e.g. creating wetland habitats) as it is avoiding flooding to new properties.

In shaping this policy, we recommend GC Council also consider the ADEPT local authority guidance on preparing for a changing climate (2019) and the new TCPA The Climate Crisis, A Guide for Local Authorities on Planning for Climate Change (October 2021).

The Fens Baseline Report (available at https://www.ada.org.uk/knowledge/future-fens/) indicates that rising sea levels to 2115 will mean water will not drain by gravity to the sea, requiring the pumping of vast quantities of water. The carbon and engineering implications of this are significant but not yet calculated. There is a compelling case for surface water to infiltrate into permeable ground ensuring that water resources are not depleted of water. In areas of less permeable geology, net gains in surface water attenuation and re-use of the water as ‘green water’ in homes, businesses or agriculture has been considered through this study.

CC/FM: Flooding and integrated water management
We welcome the inclusion of Policy CC/FM. We agree a policy that responds to the local water management issues is needed. As climate change will intensify the existing pressures on water availability, water quality, drainage and flood risk an integrated approach to water management will be essential. As stated this should include a robust approach to drainage and water management. The proposed policy direction is a good starting point but given the water challenges (our comments to Policy S/DS) it should strive to secure both mitigation and betterment through growth.

The local policy approach should be informed by the IWMS Water Cycle Studies, the Level 1 SFRA and other relevant strategies. We would expect to see the policy content evolve with the following considerations:

1) Though the policy direction indicates that policies will require that the risk of flooding is not increased elsewhere, it should seek to secure betterment and reduce flood risk overall, wherever possible, as part of GC’s strategy to adapt to climate change. This aligns with our previous comment that making space for water to flood and be stored will be critical to long-term adaptation. Floodplain storage, natural flood management and surface water attenuation are all measures that will contribute. Protection of potential flood storage land (including functional floodplain/Flood Zone 3b) and financial contributions towards flood risk schemes could also benefit communities at risk of flooding are also much needed options. Although many sites are located in Flood Zone 1 (low probability of flooding from rivers) there are also many sites located on the fringes of Flood Zones 2 and 3 meaning these are at risk of reducing (potentially eliminating) future flood storage options for adapting to climate change. In the background, urban creep and small infill developments which do not attenuate for surface water impact drainage systems and watercourses downstream. In planning to manage future flood risk in GC, creating extra storage to allow space for flood waters is a vital element of that plan.

2) We expect the policy to include provision for water supply and waste water infrastructure, ensuring water quality and treating and re-using waste water. We recommend that the provisions of Policy CC/7, ‘Water Quality’, of the South Cambridgeshire Local Plan 2018 are considered and brought forward into the Greater Cambridge Local Plan. Site policies may also need to include specific infrastructure requirements. These should become apparent, and be informed by, assessments carried out in the IWMS Detailed Water Cycle Study.

3) There needs to be a policy approach that recognises a clear integration encompassing water resources, water quality, flood risk and recognising the role of green infrastructure. Although the value of green infrastructure and river corridors is recognised in policy BG/GI and BG/RC, it is worthwhile including it as part of the integrated water management policy. The Greater Cambridge Green Infrastructure Opportunity Mapping Study touches upon this relationship under the Water Storage bullet as follows: Our rivers are a source of flood risk. Restoration of natural flood plains where practicable and provision of green infrastructure can help reduce flood risk along the rivers itself and beyond. Wet woodland will self set and grow where conditions are right and management allows. Providing the right conditions for trees to grow in appropriate locations in river corridors can support flood risk mitigation and biodiversity.

Integrated Water Management Study – Outline Water Cycle Strategy (WCS)
For water quality we welcome that the Outline WCS has been amended based on our previous feedback. However a number of issues raised remain unresolved which we can expand upon in a more detailed response to the Council’s consultants. Some of the information presented does not represent the proper ‘baseline’ for subsequent assessments and the extent of the challenge of delivering the quantum of growth proposed in the Local Plan. For example, 2019 WFD classification data is presented but waterbody objectives are from 2015, also the information in chapter 6 does not take account of river quality improvements delivered by AMP6 or AMP7 schemes. The identified assessment methods need to be sufficiently robust, and potential mitigation actions will need to be shown to be viable. The Detailed WCS will need to provide evidence to demonstrate the delivery of foul drainage provision can be provided whilst protecting water quality of rivers.

Climate change topic paper (IWMS Level 1 Strategic Flood Risk Assessment)
We have reviewed the Level 1 SFRA. The majority of sites are in fluvial Flood Zone 1 with a proportion of sites with partial Flood Zone 2 and 3 either within the site boundaries or close to boundaries. Surface water flood risk also affect most of the sites to a limited or greater extent. Flood risk and climate change adaptation is an important consideration of the Local Plan in view of the predicted impacts of climate change on flood risk. Page 39 of the Climate Change Topic Paper states that the Level 1 SFRA (2021) has been used to support the selection of development sites through the application of the Sequential Test. This statement within the topic paper is helpful, however, it does need to be more obviously demonstrated how the Sequential Test and sequential approach to all forms of flooding has been applied. The Planning Practice Guidance advises a number of options for this including a standalone report, Sustainability Appraisal commentary, etc. This will need to be produced in time for the next draft plan consultation so it is clear how the test has been applied and demonstrated.

Page 42 explains that where necessary a Level 2 SFRA of sites in the draft plan will be carried out to ensure that designs and capacity fully reflect management of flood issues. We think that a Level 2 SFRA is necessary particularly for those sites located on the fringes of Flood Zones 2 and 3, or partially within those zones. In predominantly flat or fenland areas, breaches in flood defences can cause flooding in Flood Zone 1 due to the concentration of floodwater in one part of the floodplain, for example, the Waterbeach New Town allocation. Some sites have unmapped ordinary watercourses running alongside or through them and often these have not been modelled as part of the indicative flood map due to their limited upstream catchment size. As such there is some uncertainty over the level of flood risk to the site, with the potential that fluvial flood risk may be greater than the Flood Map for Planning. These sites will 7 require further investigation to better refine the flood extents (including climate change) preferably by flood risk modelling or utilising the Flood Map for Surface Water (FMfSW). For some sites, fluvial climate change assessment is required as this is not modelled.

A Level 2 SFRA could also identify suitable land or techniques that could be used for flood storage to adapt to climate change and urban creep. Even if these cannot be brought forward at this stage in the plan, these could be protected for future plans or for infrastructure to bring forward at the appropriate time. The LLFA may also have areas of surface water flooding to be further investigated. The Level 2 will help determine whether the site can be developed safely, mitigation measures required, sequential approach and applying the Exceptions Test (NPPF paragraph 164). The Level 2 SFRA should inform the site specific polices within the plan that will form the planning framework for the sites. We can provide a separate list of the sites we think would require L2 SFRA assessment if helpful.

BG/BG: Biodiversity and geodiversity
This policy will control biodiversity impacts from development and set out Biodiversity Net Gain requirements (aiming for 20% BNG). We welcome and support the Council’s policy direction on this. It should be clear that BNG is in addition to the standard requirements of the mitigation hierarchy i.e. avoid harm where possible, mitigate for the effects or compensate (paragraph 180 of NPPF). We recommend that local authorities adopt a natural capital evidence approach to underpin their local plan. This is mentioned briefly in the evidence base within the green spaces topic paper. Information can be found here. Natural Cambridgeshire have done some work in this area, looking at opportunity mapping. Also, the recent Oxfordshire Plan 2050 (Reg 18) had some good natural capital and ecosystem services wording (policy option 09) that we recommend you consider. Preparation of a natural capital evidence base and policy is something we (and likely Natural England) could advise on in advance of the next consultation stage.

Wider environmental net gains is also identified as a potential policy requirement which we support, and pending further guidance from a national level. We recommend that geodiversity is also considered.

We recommend ambitious maintenance requirements to protect and ensure longevity of net gain enhancements. The Environment Bill mandates 30 years but ‘in perpetuity’ should be aimed for where possible.

The proposed policy direction includes that off-site measures must be consistent with the strategic aims of the Greater Cambridge green infrastructure network strategic initiatives. We welcome the GI initiatives so far identified within the GC Green Infrastructure Mapping which include revitalising the chalk stream network, the River Cam corridor and enhancement of the fens.

This work can also help to inform a future Local Nature Recovery Strategy in identifying valuable sites, sustainable land management and how the loss and/or fragmentation of existing habitats should be avoided as much as possible. The creation of bigger, better and joined-up habitats will be beneficial to wildlife, contributing towards the local plan’s objective of doubling nature. The creation of large networks will also support ecological resilience to predicted future impacts from climate change and are likely to overlap with net gains in flood risk management.

We recommend this policy also acknowledge the significance of invasive non-native species (INNS) and their impacts on wildlife and the environment. INNS are considered one of the top five threats to the natural environment. They can impact on wildlife, flood risk, water quality and recreation. Costs to the economy are estimated at £1.8 billion per year. Prevention through adopting biosecurity measures can help to reduce the spread and impacts of INNS.

BG/GI: Green infrastructure
We support the policy direction which will require all development to include green infrastructure, and protect/enhance water environments. We welcome the list of green infrastructure initiatives on page 8 173/174 which includes revitalising the chalk stream network and references the River Cam. It’s positive that developments will be expected to help deliver or contribute towards these to enhance the existing green infrastructure network.

In addition, we consider ‘connectivity’ as a key component of this policy. As noted in the Sustainability Appraisal (Non-Technical Summary p. 15) fragmentation and erosion of habitats can be detrimental to wildlife. Existing and new habitats and greenspaces should be retained and enhanced, in connection with existing habitats and the wider countryside, establishing a coherent ecological network, as per the NPPF. We support the references to ‘providing links’ and connecting to the wider ecological network as part of this policy, as this will be invaluable to both green infrastructure provision and nature recovery.

Existing areas of habitat and green spaces within proposed development footprints should be protected and incorporated within landscape designs where possible. As well as protecting existing areas of habitat, mitigation and environmental enhancements can be delivered through appropriate design that includes creation of new habitats and green spaces. New habitats should be representative of and complement the local landscape character, whilst being linked to existing features and the wider countryside, creating joined-up, resilient ecological networks

BG/RC: River corridors
We support the inclusion of a policy to manage development that has an impact on river corridors and proposes to protect, enhance and restore natural features, supporting re-naturalisation. This is particularly important for Cambridge due to the presence of chalk streams and the role rivers and their associated floodplains play in managing flood risk and provision of habitats. The proposed policy direction includes ‘ensure that the location, scale and design of development, protects and enhances the character’ and we recommend this includes the provision of appropriate setback of developments from rivers to provide sufficient space for flood waters as well as safeguarding the integrity of the river banks and the development itself. Rivers unless they have been artificially straightened move through their landscapes through natural processes of erosion and deposition. Although river migration occurs over long time periods, developments should be set back generously to account for this alongside climate change. Natural flood management also has the potential to deliver multiple benefits. Tall buildings can have an adverse effect if located too close to a watercourse by introducing overshadowing impacts and artificial lighting which disrupts natural diurnal rhythms of wildlife such as bats.

Wellbeing and inclusion – general comments
We recommend reviewing the document The State of the Environment: Health, People and the Environment (2020).This report, prepared by the Environment Agency, highlights the substantial body of evidence indicating the physical and mental health benefits of spending time in the natural environment. Access to the natural environment is not equally distributed, those living in deprived areas often have poorer quality environments with less accessible green and blue space. The GC Local Plan presents an opportunity to level-up communities, tackling this green inequality at scale and improving the health and wellbeing of those living and working in the GC area, by creating and contributing to healthier, greener, and more accessible environments. This must, however, be achieved in balance with the need to protect the environment, by providing appropriate wildlife refuges from human disruption and interference.

WS/HS: Pollution, health and safety
We would welcome a policy that details how land contamination should be considered, ensuring the land is suitable for the end use but also ensuring that water quality of the underlying aquifers is protected.

There are some plans and strategies that will be relevant to inform this policy. In 2018 the Government committed through the 25 Year Environment Plan to ‘achieve clean air’ and to ‘minimise waste, reuse materials as much as we can and manage materials at the end of their life to minimise the impact on the environment’. The State of the Environment: Health, People and the Environment (2020) highlights the extent of the threat that air quality poses to health in the UK, shortening tens of thousands of lives each year. Analysis also shows that areas of higher deprivation and those with high proportions of ethnic minorities are disproportionately affected by high levels of air pollution. Growth plans provide the opportunity to address these inequalities by improving the quality of the environment and strategically planning the location of land use types.

We welcome that the policy will provide protection to and from hazardous installations. However, Waste management facilities also have the potential to pollute the environment, cause nuisance or amenity issues through dust and particulate emissions to air, release to ground and surface water, and to leave a legacy of contaminated land. Studies have found that more deprived populations are more likely to be living closer to waste sites, and can therefore at times be subject to greater impacts such as noise, litter, dust, odours, or increased vehicular traffic. Strategic planning of waste and resource use provides the opportunity to address this issue.

H/RC: Residential caravans
This policy will set out the criteria to be used when considering proposals for new residential caravan sites. Annex C ‘Flood risk vulnerability classification’ of the National Planning Policy Framework (NPPF) classifies caravans, mobile homes and park homes intended for permanent residential use as highly vulnerable. Permanent caravans, mobile homes and park homes if located adjacent to rivers are at significant risk from being inundated very quickly from floodwaters, without sufficient warning or adequate means of escape. There are additional dangers from the potential for floating caravans (if they become untethered), cars and objects/debris becoming trapped beneath the caravans will increase the risk by displacing floodwater elsewhere.

Page 295 states that an accommodation needs assessment is currently being developed. The Sequential Test (paragraph 161 of the NPPF) should also be applied to the accommodation needs assessment to avoid where possible locating accommodation sites in areas at risk of flooding. This should be informed by the Level 1 and where necessary a Level 2 SFRA. We recommend given the high vulnerability of this type of accommodation that flood risk is a key consideration within the policy criteria.

H/GT: Gypsy and Traveller and Travelling Show People sites
The proposed policy direction includes ‘Sites are capable of providing an appropriate environment for residents in terms of health, safety and living conditions.’ Similar to our comments to Policy H/GT above, Annex C ‘Flood risk vulnerability classification’ of the NPPF classifies ‘caravans, mobile homes and park homes intended for permanent residential use’ as highly vulnerable. Sites used for holiday or short let caravans and camping (subject to a specific warning and evacuation plan) are classified as more vulnerable. We recommend given the higher vulnerability of this type of accommodation that flood risk is a key consideration within the policy criteria.

Page 298 states that a joint accommodation needs assessment is currently being developed. The Sequential Test (paragraph 161 of the NPPF) should also be applied to the accommodation needs assessment to avoid where possible locating accommodation sites in areas at risk of flooding. This should be informed by the Level 1 and where necessary a Level 2 SFRA.

The existing site at Fen Road continues to be a source of ongoing local water quality and environmental health problems due to inadequate foul drainage provision. There have been a number of reports of foul sewage from the site discharging into the River Cam, causing chronic on-going pollution. Water quality and ensuring appropriate drainage infrastructure is also an important consideration for these sites, both in terms of protecting the environment and safeguarding the health of the site occupiers. Policy H/23 ‘Design of Gypsy and Traveller Sites and Travelling Showpeople Sites’ in the South Cambridgeshire Local Plan 2018 provides an example of this, with the following wording: d. All necessary utilities can be provided on the site including mains water, electricity supply, drainage, sanitation and provision for the screened storage and collection of refuse, including recyclable materials;” Policy H/GT should include provision for mains foul drainage and protection of water quality as part of the policy criteria.

Infrastructure – general comments
Infrastructure and connectivity improvements, must be achieved in balance with the need to protect natural spaces, providing both accessibility and retaining restricted access refuges for wildlife. There is the opportunity to achieve both if, for example, cycle and pedestrian networks are considered strategically and systematically alongside green infrastructure and natural capital networks. A holistic approach to connectivity and infrastructure should be adopted, considering the multifunctional possibilities that provision of new transport and utilities infrastructure provide. For example, by integrating new road or rail schemes with flood resilience measures, energy generation, and green infrastructure enhancements.

I/SI: Safeguarding important infrastructure
We welcome the intention to work with infrastructure providers to consider whether planned strategic infrastructure or future land should be safeguarded. This should also include land for flood storage and flood risk infrastructure which is likely to include river corridors. Managing flood risk both now and in the future will require the plan taking a pro-active approach taking into account climate change. Your SFRA evidence base can inform this identification for safeguarding. The functional floodplain (Flood Zone 3b) is a zone comprising land where water has to flow or be stored in times of flood, identified in SFRAs and deemed to be the most at risk of flooding from rivers or sea. The SFRA should also gather information on flood risk management projects. The GOSIS (formerly Great Ouse Storage and Conveyance study) will assess how flood risk within the catchment can be managed now and into the future, giving a high-level evaluation of the costs of benefits of providing large storage volumes in the catchment. The GOSIS project will look for areas for flood risk management and draft outputs from this likely to be available towards the end of GC Local Plan process. There is also the Girton Flood Alleviation Scheme (Washpit Brook catchment) and flood risk management options at Oakington Brook (the latter referenced in our comments to Policy

As mentioned for Policy CC/FM, although a sequential approach has been considered there many sites proposed on the fringes of Flood Zones 2 and 3. This reduces and potentially eliminates future flood storage options for adapting to climate change. It’s important the L2 SFRA assesses these sites for their deliverability but also a broad perspective is taken to planning for flood risk both now and in the future. Creating extra flood storage to allow space for flood waters will be a vital component of that plan. We’d also expect safeguarding to include what is required for water infrastructure more broadly (water supply and waste) and green infrastructure/biodiversity.

I/ID: Infrastructure and delivery
We support the policy direction to propose to only permit development if there is, or will be, sufficient infrastructure capacity to support and meet all the requirements arising from the new development. The developer certainly has a role in this, beneath a robust and deliverable strategic framework led by the Council and other strategic infrastructure providers (informed by evidence).

As noted for Policy S/DS, we support the idea of development limited to levels that can be supported by a sustainable water supply (phased delivery) until the time the strategic infrastructure is in place. It is important that development is sustainable and the environment is protected throughout the process of infrastructure planning.

In terms of residential and employment commitments, the new Local Plan should seek to meet the full, unconstrained objectively assessed needs for market and affordable housing, as well as the assessed needs for jobs.
Paragraph’s 60 – 62 of the National Planning Policy Framework (NPPF) outline that Local Plans should support the Government’s objective to significantly boost the supply of homes and at a minimum should be informed by a local housing need assessment using the standard method included in National Policy Guidance. The NPPF also notes that it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed.
The Plan has identified an objectively assessed need for 58,500 jobs and 44,400 homes across the Plan period from 2020-2041.
The total number of homes to be provided through the plan is 48,840 which includes a 10% buffer for flexibility and results in a requirement of 11,640 homes to be identified in this Plan.
Whilst an uplift has been applied to the Standard Method, in response to the Council’s evidence which considers the preferred forecasted employment levels, it is noted that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041.
The Councils have instead opted to pursue a ‘Medium’ growth option (2,111 dwellings per annum), but this falls short of maximising the economic potential of the ‘Plan Area’ and the provision of housing in accordance with higher forecasts for jobs growth (2,549 to 2,690 dwellings per annum). This is projected to continue existing trends, where levels of housing delivery have been out-paced by jobs growth, resulting in sustained affordability pressure, and increased in-commuting. This has addressed in more detail by the representations submitted by Barton Willmore in respect of our client’s wider interests in Greater Cambridgeshire.
The Council’s Housing Needs for Specific Groups Addendum (2021) models the demographic implications of various growth scenarios. This recognises that whilst needs increase as the housing numbers go up, the proportionate increases are fairly small due to uplifts primarily affecting younger working populations (Paragraphs 6.7-6.8). The material point, however, is that the higher growth scenarios provide a true reflection of the actual demand for housing. Even using the Council’s ‘medium’ scenario, without prejudice to the reservations in these representations, the Council’s Preferred Approach represents a significant increase in the requirements for development.
To address this, the Council is only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites as provided for in the existing strategy. In practice, the risks to delivery mean that the Council’s stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period utilising very limited additional sources of flexibility.
Whilst this policy recognises the overall number of homes to be provided for within the plan period, the First Proposals as a whole fail to set a figure or a range for the number of specialist housing for older people needed across the plan area. The issues identified mean that, together with considering full housing needs, and the requirement for an increased supply buffer, consideration must therefore be given to specifying the amount of homes to be provided for to meet the demand for Extra Care and other types of specialist accommodation, and then how these will be delivered.
While an increase to the overall buffer may be appropriate (to say 20%) the practical implications are that any risks to delivery of the strategy mean operators within the specialist older persons housing sector will face the most extreme pressures of competition in securing development opportunities.
This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
In these circumstances, greater certainty and flexibility would be achieved through the allocation of specific sites to meet the needs for specialist housing for older people alongside provisions for the overall buffer, including that relating to general housing needs. Addressing this issue is central to satisfying NPPF Paragraph 60 in terms of providing an appropriate strategy that will enable the needs of specific groups to be addressed without being entirely dependent on the wider identified risks.

In terms of residential and employment commitments, the new Local Plan should seek to meet the full, unconstrained objectively assessed needs for market and affordable housing, as well as the assessed needs for jobs.
Paragraph’s 60 – 62 of the National Planning Policy Framework (NPPF) outline that Local Plans should support the Government’s objective to significantly boost the supply of homes and at a minimum should be informed by a local housing need assessment using the standard method included in National Policy Guidance. The NPPF also notes that it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed.
The Plan has identified an objectively assessed need for 58,500 jobs and 44,400 homes across the Plan period from 2020-2041.
The total number of homes to be provided through the plan is 48,840 which includes a 10% buffer for flexibility and results in a requirement of 11,640 homes to be identified in this Plan.
Whilst an uplift has been applied to the Standard Method, in response to the Council’s evidence which considers the preferred forecasted employment levels, it is noted that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041.
The Councils have instead opted to pursue a ‘Medium’ growth option (2,111 dwellings per annum), but this falls short of maximising the economic potential of the ‘Plan Area’ and the provision of housing in accordance with higher forecasts for jobs growth (2,549 to 2,690 dwellings per annum). This is projected to continue existing trends, where levels of housing delivery have been out-paced by jobs growth, resulting in sustained affordability pressure, and increased in-commuting. This has addressed in more detail by the representations submitted by Barton Willmore in respect of our client’s wider interests in Greater Cambridgeshire.
The Council’s Housing Needs for Specific Groups Addendum (2021) models the demographic implications of various growth scenarios. This recognises that whilst needs increase as the housing numbers go up, the proportionate increases are fairly small due to uplifts primarily affecting younger working populations (Paragraphs 6.7-6.8). The material point, however, is that the higher growth scenarios provide a true reflection of the actual demand for housing. Even using the Council’s ‘medium’ scenario, without prejudice to the reservations in these representations, the Council’s Preferred Approach represents a significant increase in the requirements for development.
To address this, the Council is only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites as provided for in the existing strategy. In practice, the risks to delivery mean that the Council’s stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period utilising very limited additional sources of flexibility.
Whilst this policy recognises the overall number of homes to be provided for within the plan period, the First Proposals as a whole fail to set a figure or a range for the number of specialist housing for older people needed across the plan area. The issues identified mean that, together with considering full housing needs, and the requirement for an increased supply buffer, consideration must therefore be given to specifying the amount of homes to be provided for to meet the demand for Extra Care and other types of specialist accommodation, and then how these will be delivered.
While an increase to the overall buffer may be appropriate (to say 20%) the practical implications are that any risks to delivery of the strategy mean operators within the specialist older persons housing sector will face the most extreme pressures of competition in securing development opportunities.
This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
In these circumstances, greater certainty and flexibility would be achieved through the allocation of specific sites to meet the needs for specialist housing for older people alongside provisions for the overall buffer, including that relating to general housing needs. Addressing this issue is central to satisfying NPPF Paragraph 60 in terms of providing an appropriate strategy that will enable the needs of specific groups to be addressed without being entirely dependent on the wider identified risks.

Representations to the Greater Cambridge Local Plan - The First Proposals Regulation 18 Consultation
West Cambourne,

On Behalf of MCA Developments Ltd November 2021

Contents
1. Introduction 3
2. Vision and Development Strategy 4
3. New Settlements – Cambourne 8

Nichola Traverse-Healy nichola.traverse-healy@turley.co.uk
Client
MCA Developments Ltd

1. Introduction

1.1 These representations are submitted by Turley on behalf of Taylor Wimpey UK Ltd and the Vistry Group (the applicants) who together comprise the consortium MCA Developments Ltd (MCA (herein referred to as MCA), in response to the Greater Cambridge Local Plan – First Proposals Regulation 18 Consultation (January 2020). MCA are the developers behind Cambourne, a maturing new settlement, located within the administrative area of South Cambridgeshire (SCDC) approximately 7 miles to the west of Cambridge. The aim of this document is to assist the Council in formulating their Local Plan.

1.2 We have set out below responses to the questions raised in the Draft Consultation Document in the order in which they appear.

1.3 The remaining part of this document is structured as follows:

• Chapter 2 – Vision and Development Strategy
• Chapter 3 – New Settlements: Cambourne
• Chapter 4 – Conclusion

1.7 MCA would be pleased to discuss any aspect of these representations in more detail if this would be of assistance to the Council and we look forward to engaging positively with the Council and other stakeholders in the ongoing preparation of the emerging Local Plan

2. Vision and Development Strategy

Vision

2.1 The proposed Vision for Greater Cambridge is set out at page 20 of the Draft Local Plan and states that:

“We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

2.2 Whilst MCA supports the Council’s objectives with regards to climate changes and protecting the environment, it is disappointing that the Vision as currently drafted makes no reference to the Oxford-Cambridge Arc.

2.3 The Oxford-Cambridge Arc is an area covering Oxford, Milton Keynes and Cambridge, identified by the Government as a unique opportunity to become an economic asset of international standing. In July the Government held a 12 week consultation which closed on 12 October 2021 seeking views on the vision for the Arc. The consultation document ‘Creating a vision for the Oxford-Cambridge Arc’ (July 2021) confirmed that it is still the Government’s intention to prepare a ‘Spatial Framework’, which will provide a national planning policy framework for the Arc.

2.4 As set out at paragraph 1.1 of the Government’s consultation document the Oxford- Cambridge Arc ‘is a national economic priority area’. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. As advised by the National Infrastructure Commission, without urgent action, a chronic under-supply of homes could jeopardise growth, limit access to labour and put prosperity at risk.

2.5 If the Arc to reach its full potential local authorities will need to plan positively in their areas to deliver the transformational growth required. On this basis we would suggest that the Vision is revised as follows:

“Greater Cambridge is a leading UK and global hub of innovation, which plays a key role in the internally recognised Oxford-Cambridge Arc. We want Greater Cambridge to be a place of great prosperity and innovation where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes.”

Policy S/JH: New Jobs and Homes

2.6 Policy S/JH of the Draft Local Plan proposes to meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year

2.7 For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.

2.8 For Greater Cambridge the housing need using the Standard Method would equate to 1743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario, the modelling predicted that 78,700 jobs would be required over the plan period.

2.9 Whilst MCA is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.

2.10 We would strongly advise the Council to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.

2.11 As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

Policy S/DS: Development Strategy

2.12 At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.

2.13 To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:

• North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.

• Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.

• Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.

• Expansion of Cambourne to around 2,000 new homes; and
• Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.

2.14 MCA strongly supports the proposed expansion of Cambourne for circa 2000 homes, which aligns with the Councils’ objective to provide jobs and homes in close proximity to major public transport routes. As stated page 44 of the Draft Local Plan locating growth at Cambourne takes advantage of the proposed new East West Rail station at Cambourne and the Cambourne to Cambridge Public Transport Scheme being brought forward by the Greater Cambridge Partnership.

2.15 Notwithstanding these proposed new transport links, Cambourne is an established and successful new settlement which benefits from a range of services and facilities, including three primary schools, secondary school, library, health centre, Morrison’s superstore, pub, leisure centre, numerous restaurants and takeaways together with a number of retail uses and professional services within two parades of shops.

2.16 The development of Cambourne West, a fourth linked village will further enhance the range of services and facilities at Cambourne. In 2017 South Cambridge District Council (SCDC) granted planning permission for the development of 2350 homes at Cambourne West including a new retail and community hub, two primary schools and an extension to the existing secondary school.

2.17 Cambourne is one of the largest and most sustainable settlements in Greater Cambridge, which since development commenced in 1998 has continued to make an invaluable contribution to Greater Cambridge’s housing land supply. The settlement is not only well placed in terms of access to major transport corridors and new infrastructure, including

the new rail station as part of East West Rail but benefits from an extensive range of shops, services, facilities and recreational opportunities. For the reasons set out above, Cambourne is considered a logical location to accommodate additional growth to meet the needs of South Cambridgeshire and Cambridge City. The proposed expansion of Cambourne is considered a soundly based strategy, which is justified by the Councils’ supporting evidence base and will deliver sustainable development in accordance with the policies of the NPPF.

Policy S/SH: Settlement Hierarchy

2.18 The purpose of Policy S/SH is group together similar settlements into categories that reflect their scale, characteristics and sustainability. In view of its sustainable credentials MCA strongly supports the Councils decision to reclassify Cambourne from a rural centre to a town.

2.19 As set out at page 49 of the Draft Local Plan:

“Cambourne is a growing centre, with a growing level of services, facilities and transport opportunities. This has been recognised by it now having a town council, and it is considered that this should be recognised in the local plan”

2.20 Cambourne performs far beyond the role of a rural centre and MCA agrees that this should be recognised in the new Local Plan. Given the excellent range of services and facilities in Cambourne and the wider catchment it serves, the Councils’ are considered completely justified in the new Local Plan to include Cambourne in the ‘Towns’ category of the settlement hierarchy.

3. New Settlements – Cambourne

3.1 Policy S/CB: Cambourne of the Draft Local Plan seeks ‘to identify Cambourne as a broad location for longer term strategic scale growth’ and carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’.

3.2 As stated previously in our response to Policy S/DS: Development Strategy, given Cambourne’s position in the settlement hierarchy and proximity to new major public transport schemes, MCA strongly supports the Councils’ decision to identify Cambourne as a broad location for longer term strategic scale growth. Cambourne has been identified as the location for a new railway station as part of the East West Rail scheme to connect Oxford with Cambridge and potentially beyond, along with the Cambourne to Cambridge public transport scheme being brought forward by the Greater Cambridge Partnership. The Draft Local Plan recognises that these schemes ‘provides an opportunity to consider how further development could make the most of these connections, but also make the overall Cambourne area a more sustainable place’.

3.3 MCA is also supportive of the Councils’ decision to carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’. Policy SS8: Cambourne West in the adopted South Cambridgeshire Local Plan (2018) currently requires at part 12 (g) ‘Vehicular access to be provided through an enhanced route through the Business Park, one or more access points from the Caxton Bypass, and via Sheepfold Lane’

3.4 The outline planning application for Cambourne West, approved in 2017, did not include an access through the Business Park, as this land was under the control of a third party. As set out in the Committee Report, relating to the West Cambourne outline planning application, dated 11th January 2017, Officers were satisfied to approve the application without the business park access but on the basis that the ‘opportunity would still exist with any future application for the development of the business park land’. To provide the Council with comfort that the business park access could be delivered in the future, the site wide masterplan submitted by MCA as part of the planning application was designed to facilitate an access. In addition plans were submitted as part of the application, demonstrating how the business park road could be brought up to adoptable standards.

3.5 In May 2021, it was announced that the South Cambridgeshire Investment Partnership (SCIP) a 50:50 partnership between South Cambridgeshire District Council and the Hill Group, would be purchasing the remaining undeveloped land at the Business Park. It is our understanding that it is the intention of SCIP to submit an application for the development of the site to provide 275 homes.

3.6 As set out at paragraph 260 of the Committee Report, relating to the West Cambourne outline planning application, Officers stated that:

“…the council would continue to encourage the delivery of an all vehicle access through the business park due to the benefits through greater connectivity that it would bring for early Cambourne West residents”

3.7 A top priority of the Draft Local Plan is to minimise vehicular movements. It has always been the Councils’ aspiration that walking and cycling links through the business park would be delivered as part of any vehicular connection. This would mean greater permeability between Cambourne and Cambourne West for pedestrians and cyclists. Given that the legal impediments to the delivery of the road no longer exist and for the benefit of Cambourne residents, it should be a requirement in Policy S/CB: Cambourne of the new Local Plan that future planning applications for the development of land at the Business Park should be required to provide an enhanced access through the Business Park to the development at Cambourne West.

3.8 As has been the approach at North West Cambridge, when drafting Policy S/CB: Cambourne for the next stage of the Local Plan, the Councils’ should be seeking to maximise the opportunities for intensifying development within the existing boundary of Cambourne West. The updated policy should enable the development of additional dwellings on the site beyond those identified in the current outline planning permission at Cambourne West, provided through changes to the dwelling mix and appropriate intensification of development areas that have yet to be built. MCA are currently undertaking a detailed review of the site wide masterplan, and will advise in due course the likely increase in dwellings that could be achieved.

3.9 Under Policy SS/8 of the adopted Local Plan any future planning application would need to provide an equivalent quantity of employment land to that lost on the Business Park (8.1ha), to be delivered in the northern part of the Cambourne West site rather than its current location. The outline planning application submitted by MCA and approved by SCDC made for provision 6.25ha of employment space for offices. At the time the outline planning application was being determined, SCDC provided limited justification with regards to the need for this level of employment land at Cambourne West. As set out at paragraphs 208 and 209 of the Officer’s Committee Report dealing with the application:

“The history of Cambourne has shown that the employment and retail units are rarely built on a speculative basis and have only come forward when an occupier has been identified…. the reality is that the majority of employment in Cambourne is outside the business park and can be found in the schools, hotel, retail units etc. There are also a large number of residents who run successful companies out of their homes.”

3.10 Current lettings data from CoStar, the commercial property database, provides a more up to date indication of the role of Cambourne in accommodating demand for office space that arises throughout South Cambridgeshire on an annual basis.

3.11 CoStar has recorded some 1,125 lettings of office space throughout South Cambridgeshire over the last ten years to November 2021, but only 34 – or little more than three lettings per annum, on average – have been in Cambourne1. It has therefore been the location for only 3% of all such lettings in South Cambridgeshire, which is

1 Lettings have been assigned to Cambourne based on postcodes

notable where the town accommodates more than twice as much (7%) of the district’s population2.

3.12 While around three lettings have been recorded annually in Cambourne over the whole decade, this had been slowing even prior to the pandemic as shown by Figure 1 below which tracks the annual average over rolling three year periods. This shows, for instance, that there were more than four transactions per annum on average in the three years to November 2016, which remained relatively stable over the subsequent two years. This was followed, however, by the recording of less than three office lettings per annum over the three years to November 2019, which has fallen even further to the point where there have been only 1.7 lettings per annum over the past three years – equivalent to one office letting every seven months.

Figure 1: Office lettings per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.13 The amount of office space taken up in Cambourne has also been falling, averaging nearly 4,900sqm per annum over the three years to November 2016 before reducing by almost a fifth to a little under 4,000sqm per annum over a similar period to November 2019, predating the pandemic. This has since more than halved to the point where only 1,700sqm of office space has been taken up annually in Cambourne over the last three years, the reduction being far starker than seen across South Cambridgeshire where the rolling average has fallen by only a quarter.

2 ONS (2021) Population estimates, mid-2020. This is the number of residents living in the officially defined Built-up Area (BUA) of Cambourne, divided by the number of people living in South Cambridgeshire (10,544/160,904)


Figure 2: Office space leased per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.14 The above analysis indicates that there has long been relatively limited demand for office space in Cambourne, which appears to have reduced even further during the pandemic. On this basis, we do not consider it justified and appropriate under proposed Policy S/CB to reserve the entire 6.25ha of employment space at Cambourne West for the provision of further office space.

3.15 For the reasons stated above and to be considered sound, MCA request that in drafting Policy S/CB the Council ensures the following:

• There is an requirement as set out under Policy SS/8 of the adopted Local Plan, to provide an enhanced access through Cambourne Business Park to link with the development at Cambourne West;

• The Policy is not overly prescriptive and allows for the intensification of development areas that have yet to be built at Cambourne West; and

• The Policy promotes and allows for the development of residential uses on land previously identified for employment on the Cambourne West Masterplan. This is on the basis of clear evidence demonstrating that the market for employment floorspace in this location is limited.


Turley Office 8 Quy Court Colliers Lane Stow-cum-Quy Cambridge CB25 9AU

T 01223 810990

Barrington Parish Council (BPC) is pleased to have the opportunity to respond to the Greater Cambridge (GCP) Local Plan First Proposals (FP).

1. Overall
1.1. BPC supports the FP development strategy in general terms and supports the principles of plan-led, sustainable development that underpin the FP. BP also supports the general themes of responding to climate change, biodiversity and green spaces, well-being and social inclusion, and great places.

1.2. The wording of many of the proposed policies is incomplete and as always, the devil is in the detail - especially regarding Jobs, Homes and Infrastructure which have the greatest potential impact on the quality of the local environment. BPC is of the view that while these issues are obviously central to any Development Plan, mitigating potentially detrimental effects on rural communities in South Cambridgeshire needs to be managed through effective, carefully worded policies in the Plan.

1.3. BPC particularly welcomes the recognition of and need for reinforcement of the distinctive character of South Cambridgeshire villages.

1.4. However, BPC wishes to make some general strategic and some specific comments as follows.

2. Strategic Issues
2.1. The 2018 Local Plan for South Cambridgeshire is to be succeeded by a Local Plan for a much wider constituency developed by a Partnership for “Greater Cambridge”. This inevitably creates tensions between the interests of the city and those of the surrounding, primarily rural areas. It has to be acknowledged that development pressures in and from the city of Cambridge have significant effects upon the surrounding areas and not all of these are positive and beneficial.

2.2. The First Proposals also seek to support both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail connection - both of which introduce additional development pressures and significant environmental impacts upon South Cambridgeshire.

2.3. The First Proposals are therefore in a key sense no longer for a “Local” Development Plan but in effect have been transformed into a Regional Development Plan where the local interests and concerns of villages such as Barrington lie at the bottom of the hierarchy of interest and control.

2.4. Policy S/DS. BPC has already placed on record and wishes to re-state its fundamental opposition to both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail southern route into Cambridge. BPC has concerns that these may lead to central government-imposed rather than locally-agreed development in South Cambridgeshire which will be highly detrimental to the area.

3. Specific Matters
3.1. Policy S/DS BPC agrees that brownfield development should be prioritised and in locally - agreed not nationally targeted locations. Development “around” the villages is not considered sustainable.

3.2. Policy S/SH. BPC supports the retention of the settlement hierarchy, and the definition of Group Villages should be retained as proposed from the 2018 Local Plan, possibly reinforced with stronger wording to restrict exceptional development of up to 15 dwellings only on brownfield sites.

3.3. Policy S/ JH. BPC has concerns about the notion of “Windfall Development”. Either we have a Development Plan or not – the notion of “unplanned” “windfall” or “opportunistic” development – especially if it were to be determined by officers as opposed to councillors – is not compatible with “plan-led development”. The opening the door to opportunistic applications that run counter to the direction of the Development Plan.

3.4. Policy GP/GB. Similarly, BPC opposes development intrusion into the Green Belt. Development “creep” – even for “nationally significant” development should be resisted.

3.5. Policy S/SRC. BPC is concerned about the definition and implications of the “Rural Southern Cluster” and this requires much more detailed elucidation, explanation and justification.

3.6. Policy WS/CF. BPC believes that Community Healthcare facilities should be prioritised as they have been poorly provided for under the current Plan. Much stronger policy definition is required.

3.7. Policy CC/WE. The FP recognise that availability of water resources is a major issue in Greater Cambridge and that the level of growth has significant constraints with regards to water supply. BPC shares these concerns. Policy should address this issue more comprehensively.

4. The Consultation Process
4.1. BPC is pleased to have the opportunity to engage to the extent that it is able with the FP consultation.

4.2. However, GCP’s consultation on the Local Plan is a convoluted process. The material is voluminous, there are 60 policies and the maps are often difficult to interpret electronically, and this militates against inclusion of the diverse age and socio-economic groups in a rural population. It comes across as an IT driven process designed for an urban sophisticated readership. Further thought needs to be put into reducing the complexity but increasing the inclusion, accessibility, and meaningfulness of this consultation.

Barrington Parish Council (BPC) is pleased to have the opportunity to respond to the Greater Cambridge (GCP) Local Plan First Proposals (FP).

1. Overall
1.1. BPC supports the FP development strategy in general terms and supports the principles of plan-led, sustainable development that underpin the FP. BP also supports the general themes of responding to climate change, biodiversity and green spaces, well-being and social inclusion, and great places.

1.2. The wording of many of the proposed policies is incomplete and as always, the devil is in the detail - especially regarding Jobs, Homes and Infrastructure which have the greatest potential impact on the quality of the local environment. BPC is of the view that while these issues are obviously central to any Development Plan, mitigating potentially detrimental effects on rural communities in South Cambridgeshire needs to be managed through effective, carefully worded policies in the Plan.

1.3. BPC particularly welcomes the recognition of and need for reinforcement of the distinctive character of South Cambridgeshire villages.

1.4. However, BPC wishes to make some general strategic and some specific comments as follows.

2. Strategic Issues
2.1. The 2018 Local Plan for South Cambridgeshire is to be succeeded by a Local Plan for a much wider constituency developed by a Partnership for “Greater Cambridge”. This inevitably creates tensions between the interests of the city and those of the surrounding, primarily rural areas. It has to be acknowledged that development pressures in and from the city of Cambridge have significant effects upon the surrounding areas and not all of these are positive and beneficial.

2.2. The First Proposals also seek to support both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail connection - both of which introduce additional development pressures and significant environmental impacts upon South Cambridgeshire.

2.3. The First Proposals are therefore in a key sense no longer for a “Local” Development Plan but in effect have been transformed into a Regional Development Plan where the local interests and concerns of villages such as Barrington lie at the bottom of the hierarchy of interest and control.

2.4. Policy S/DS. BPC has already placed on record and wishes to re-state its fundamental opposition to both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail southern route into Cambridge. BPC has concerns that these may lead to central government-imposed rather than locally-agreed development in South Cambridgeshire which will be highly detrimental to the area.

3. Specific Matters
3.1. Policy S/DS BPC agrees that brownfield development should be prioritised and in locally - agreed not nationally targeted locations. Development “around” the villages is not considered sustainable.

3.2. Policy S/SH. BPC supports the retention of the settlement hierarchy, and the definition of Group Villages should be retained as proposed from the 2018 Local Plan, possibly reinforced with stronger wording to restrict exceptional development of up to 15 dwellings only on brownfield sites.

3.3. Policy S/ JH. BPC has concerns about the notion of “Windfall Development”. Either we have a Development Plan or not – the notion of “unplanned” “windfall” or “opportunistic” development – especially if it were to be determined by officers as opposed to councillors – is not compatible with “plan-led development”. The opening the door to opportunistic applications that run counter to the direction of the Development Plan.

3.4. Policy GP/GB. Similarly, BPC opposes development intrusion into the Green Belt. Development “creep” – even for “nationally significant” development should be resisted.

3.5. Policy S/SRC. BPC is concerned about the definition and implications of the “Rural Southern Cluster” and this requires much more detailed elucidation, explanation and justification.

3.6. Policy WS/CF. BPC believes that Community Healthcare facilities should be prioritised as they have been poorly provided for under the current Plan. Much stronger policy definition is required.

3.7. Policy CC/WE. The FP recognise that availability of water resources is a major issue in Greater Cambridge and that the level of growth has significant constraints with regards to water supply. BPC shares these concerns. Policy should address this issue more comprehensively.

4. The Consultation Process
4.1. BPC is pleased to have the opportunity to engage to the extent that it is able with the FP consultation.

4.2. However, GCP’s consultation on the Local Plan is a convoluted process. The material is voluminous, there are 60 policies and the maps are often difficult to interpret electronically, and this militates against inclusion of the diverse age and socio-economic groups in a rural population. It comes across as an IT driven process designed for an urban sophisticated readership. Further thought needs to be put into reducing the complexity but increasing the inclusion, accessibility, and meaningfulness of this consultation.

On behalf of ECDC, and as an officer-level representation only, I have undertaken a high level review of your emerging Local Plan. I also had the benefit of the virtual meeting on 30 November, where you kindly outlined some of the key issues of your emerging Plan.

Overall, ECDC has no objections to raise at this stage.

In particular, ECDC notes that there are no additional (i.e. ‘new’) major development proposals close to the border with East Cambridgeshire; and where major new allocations are proposed within your plan area, there appears no immediate or obvious significant ‘cross-border’ implications of relevance to East Cambridgeshire arising from them.

Our only area of comment relates to the scale of job growth and housing requirement proposed (the latter being dependent on the former, rather than being dependent on using the national standard method minimum derived figure). As the Plan progresses, and through on-going duty to cooperate conversations (and associated Statement of Common Ground), ECDC will want to be satisfied that the evidence behind the balance between jobs and homes growth is sufficiently robust, and that (and of more importance to ECDC) appropriate mechanisms are in place in the Plan to ensure that the Plan can react positively should the growth in jobs and/or homes not occur as forecast (whether faster or slower than forecast).

To put it another way, ECDC may have concerns if, over the coming years, new homes considerably exceeded job growth, or job growth considerably exceeded new homes. Under such scenarios, there could be ‘spill over’ effects on East Cambridgeshire, hence the need for the plan to have mechanisms in place to actively ‘plan, monitor and manage’ for these potential eventualities.

Over the coming months, I would encourage continued conversations on this issue in particular, prior to your final ‘reg 19’ consultation stage.

Finally, on wider matters, ECDC is particularly interested in continuing to work closely with you on the aspects in your Plan relating to climate change and the natural environment, recognising that these matters are clearly ones that will require cooperation and shared learning across all organisations and administrative areas. In principle, the proposals you outline in your Plan on these matters are welcomed, and we would be happy to assist with your evidence base on these matters should you find that helpful.

Regards

Richard Kay
Strategic Planning Manager

Figure of 2,111 new homes per annum mentioned here. Using pre-covid data and rejecting the Government standard models for development.

Comments from Cottenham Parish Council:

Policy S/DC - Welcome the Councils’ strategy for development.

Policy S/DC - Support the allocation of 10% more housing than required by the standard test to avoid unplanned development as happened in Cottenham (an extra 500 houses now being built in unplanned locations as a result of speculative development) while waiting for the adoption of the 2018 South Cambridge District Plan.

Policy S/RRA - Support the allocation of the Old Highways Depot site for economic development, subject to protection of view of the church.

Policy I/ST - Look forward to an integrated approach between SCDC and CCC Highways for the development and delivery of integrated sustainable transportation for pedestrian, cyclists and vehicle users.

Policy I/ST and Policy S/RRA - Look forward to more consideration of the sustainable transport in the rest of the rural area, including bus and cycle links to rail hubs such as Waterbeach and Cambridge North, improved direct bus access to Cambridge from existing centres and generally better cycling connectivity. Including reinstatement of the Citi8 bus continuing to the northern end (Church) of the village and incorporating a bus turning area in the Voland Ind Est development area. Resolution That the proposed comments are submitted to the Greater Cambridge Partnership as Cottenham Parish Council’s response to the First Proposals. Passed at CPC Full Council meeting on 7th December 2021.

Policy CC/FM - Look forward to co-operation between SCDC and CCC on sustainable drainage solutions so that developments along the East West Rail arc do not impact on the Independent Drainage Board areas and Cottenham Lode in particular and consideration to take varying infiltration rates to accommodate the impact of climate change.

GENERAL – SUMMARY
The objections to the currently proposed Local Plan (the Plan) for Greater Cambridge (GC) are in summary:
No recognition of the existing importance of inward commuting under existing conditions, the likelihood this will increase in future and the opportunity this presents for levelling up by sharing housing growth with nearby areas.
Overestimation of the likely jobs growth given the changes in employment, the likely loss of growth and changes in the economy that have occurred in the first 10% of the plan period.
Overestimation of the housing growth needed in the GC area due to the in-combination effect of the above factors
The adverse consequences of the avoidable, extra planned housing growth in GC namely:
a) Requiring an unsustainable inward migration to the area.
b) Further negating the desirable objectives of preserving the unique character of Cambridge as a compact, dynamic city with a thriving historic centre and maintaining and enhancing the quality of its setting
c) Concluding that NE Cambridge is required to include some redevelopment of the existing sewage works area for high density housing within the Plan period which now translates to proposals to destroy part of the Green Belt
d) Excessive strain on the transport systems in Cambridge
e) Excessive concentration of load on the infrastructure, particularly water supply where the Plan states an exceptional intervention would be needed to maintain supplies at the planned rate and concentration of growth in addition to an assumed reduction in household demand. There is an unaddressed threat that supply failures will be overcome by either excessive pumping of Chalk aquifers or supply restrictions, ie drought orders, to prohibit nonessential uses. Sewage treatment is also a major issue with many minor work in GC s causing intermittent pollution as a result of recent increases in population.

ECONOMIC GROWTH AND HOUSING NUMBERS
a. SCDC use 2020 as the base with requirements for housing numbers being additive since the 2011 census. It is not clear how the base number accounts for actual completions in 2020 and 2021. If so, a buffer of 10% should not be added to what has already been built.
b. The 2021 census will give a more accurate base for the actual numbers of houses needed to meet the total need in 2041. The process for inclusion of the true 2021 figure needs to be described if it is not available before the formal consultation.
c. Employment patterns appear to be changing rapidly with a drop off in retail (and, anecdotally, low value day trip tourism) for example. If numbers of persons employed have dropped in addition to the noted drop or low growth in economic output, the overall employment target for 2041 may be too optimistic. For example if employment and output are still at 2019/2020 levels, that would equate to around 10% of the Local Plan period to 2041. The impact should be assessed and announced before the formal consultation on the Local Plan commences.
d. Changes to the planning regulations governing change of use have been announced recently. The application of the new rules should be assessed and the amount of qualifying space should be estimated if is not already known. If the change is between retail/commercial uses then the impact on the high value jobs underpinning the growth aspiration should be assessed prior to the formal consultation. Any potential for conversion of such spaces to housing should also be assessed.
e. Overall, if the jobs growth has been set back by the events of the last two years, noting the recent ONS announcement that the Uk economy is 2.1 % smaller than in Q4 2019. it is necessary to either change the forecast housing need or remove/reduce the 10% buffer.
f. 2021 Census data should also be interrogated to quantify if population growth in GC and surrounding areas has stalled or even gone negative in parallel with the economic slowdown of the last two years. A degree of ex-migration may have occurred compared to the expected inward migration to the areas.
g. The proposed medium growth +10-% strategy is objectionable as it stands because they are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan . Indeed, the impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, a 37% increase beyond existing homes in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further. The Aims of the Local Plan: “Wellbeing & Social inclusion” and ˜Great Places” are of particular relevance and at risk.
h. The quoted planned average of 2,111 homes produced per year is not going to have a major impact on Cambridge high house prices or the provision of social and affordable housing for the lower paid of the 58,500 jobs. The City already has one of the highest relative levels of deprivation in England and Wales with 3 LSOA’s in bottom 20% ( CN-Oct 2020).

I am writing in regard to the Greater Cambridge Local Plan. I would be grateful if this letter could be accepted as a response to the ongoing consultation, due to close on December 13th.

As MP for South East Cambridgeshire, I support growth and development in our region. Of course, we need more homes to be built in the right places, and unfortunately there are parts of our region where the cost of buying or renting a home is many multiples of local household income. It is therefore right that the local authorities investigate ways to provide sustainable growth during the period of the Local Plan (up to 2041). However, I believe that this growth needs to be delivered in a sustainable fashion which does not diminish the rural character of Cambridgeshire and my constituency of South East Cambridgeshire.

According to figures released by the National House Building Council, South East Cambridgeshire has already seen more than double the UK constituency average for new homes built, with 467 new registrations in 2021 so far compared to an average of
180. I am therefore keen to ensure that further growth plans do not negatively impact on a number of villages and residents in my constituency, many of whom, have already faced significant developments in recent years.

As I understand it, Cambridge City and South Cambridgeshire District Councils through their Greater Cambridge Local Plan are proposing to build close to 49,000 new homes (including a 10% buffer) up to 2041. This is beyond the medium growth outlined in the initial evidence base findings and development strategy options assessments,rublished in November 2020, and beyond the Government's minimum assessment o what is required locally.

I am supportive of sustainable growth, which is matched with the transport, power, broadband and water requirements of our region. Whilst I welcome the focus on new settlements within the Local Plan as opposed to dispersing homes amongst small villages in my constituency, I am concerned about the level of growth that has been outlined. I also believe it is imperative that local leaders identify and support the infrastructure requirements that our regions' already higher than average housing growth demands.

As part of this consultation, I therefore encourage the local authorities, especially South Cambridgeshire District Council not to seek to increase housebuilding levels beyond the government minimum target

I'm writing in a personal capacity to express my opposition to the Draft Local Plan as it currently stands. I feel very strongly that local government should not be planning more economic and population growth in this area or more housing than current government targets require, but prioritising social housing and new water infrastructure to reduce stress on our rivers and wildlife.

The plan should be supporting the national ‘levelling up’ policy. It should be consistent with the government’s ‘brownfield first’ objective which will deliver badly needed homes faster. It should take into account the growing flood risk to large parts of the county and the consequences for national food supply. It needs to take into account the as yet, unknown, long-term effects on employment and travel behaviours of the COVID pandemic.

Cambridge City Council has declared a climate emergency, which this plan simply doesn't reflect. I respectfully request that it be rejected, rewritten and re-submitted for full public consultation.

I am writing to object to the Draft Local Plan and the over-development in and around Cambridge.

Over abstraction of water and inadequate waste water infrastructure.
Already Cambridge Water and Anglian Water are damaging our precious and world famous chalk streams by over abstraction of water from the aquifers. Some of these rare chalk streams have already dried up completely.
More houses and businesses create a bigger demand on these water resources. A proposal to pump water from Lincolnshire, another water stressed area, to Cambridgeshire is not a viable solution, not an environmentally sound solution.

This continual building in excess of local requirement and more than the Government's target, results in concreting over large areas of ground leading to more rain water running straight into the sewage system. More houses means more sewage. The WWTW at Milton has been recently upgraded to cope with "normal" sewage volumes, but as soon as there is heavy rain, the sewage system is overloaded and untreated sewage is released into our rivers. In 2020 spills from various companies' pumps and overflows resulted in overt 12000 hours worth of sewage being discharged into Cambridgeshire's rivers. What a disgrace!
All this taking place when the Local Authority and Central Government profess to be caring for the Environment.

Green Spaces and Recreation.
The provision of green spaces is woefully inadequate.
The recent pandemic has shown how much people value open green spaces for their physical and mental well-being. Wicken Fen and the surrounding countryside has provided a much appreciated "Green Space" during the last 20 months or so. Resiting the WWTW from Milton ( a Brown Field site) is not necessary on operational grounds. This proposed incursion into the Green Belt is completely out of character with the surrounding country-side and destroys the Wicken Fen Vision, a proposal which is valuable on both recreational and environmental grounds, helping to absorb carbon dioxide and so helping to reduce global warming. Concreting over farm land does not make sense either financially or environmentally - cement manufacture contributes 8% of global carbon emissions.

These plans and proposals were being made before the pandemic. During this time work practices have changed. The Government's targets for housing etc. need to be revisited.

It is difficult to understand how this continual over-development in and around Cambridge is consistent with the "levelling up" policy and the professed care for the Environment of this Government and of our Councils.
There are many sites around the country registered as "Brown Field" sites, and empty houses suitable for upgrading in the former industrial towns and cities of the North, where this investment would be appreciated.

The infra-structure to support these proposed developments is not in place nor is it planned for. The water supply and sewage facilities are inadequate. Public transport is poor so private car usage is often the only viable means of transport. The roads are frequently congested with road traffic accidents occurring daily. Addenbrook's Hospital and the Rosie Maternity Unit are at near capacity.

Please think again! Think more of future generations.

Please confirm that you have received my objection.

The Cambridgeshire Development Forum brings together a diverse range of organisations with a shared commitment to the delivery of high-quality developments in the Cambridgeshire region. We include promoters, developers, housebuilders, housing associations, planners, advisers, law firms, design companies, transport planners and related professionals in our membership. We do not promote individual sites and are focused on achieving more effective delivery of plans in our region. We value the engagement we receive from local planning authorities, the Combined Authority and Central Government. We welcome this opportunity to respond to the consultation on the Local Plan.

These representations reflect shared views among our members but should not be interpreted as representing the views of any individual member organisation in membership of the Forum.

Responses:

Q1: the additional 550 homes a year should be regarded as a minimum figure, which should be reviewed regularly in relation to the growth in jobs within the travel-to-work areas

Q2: the spatial strategy for development should focus the larger development sites in locations which offer public transport options to reach major employment centres. Development in rural locations of an appropriate scale should not be deterred as and when more sustainable personal transport options are available, eg EVS using renewable energy.

Q3: The Cambridge East Development should be connected directly to the City centre and the inner urban ring of development at the Biomedical campus, North Cambridge and the Science Park, Eddington and West Cambridge. But it should not be a wholly residential development. It should be a mixed development including commercial, residential and leisure/ retail options. It should be envisaged as a distinct place, with its own character. It could include high-rise apartments suitable for the younger workers who comprise many Cambridge area workforces.

Q4: North-East Cambridge should offer a residential opportunity for those employed in the technology sectors around Cambridge, including a significant component of affordable housing for market sale, market rent, shared ownership, and social housing.

Q5: development in and close to the biomedical campus should be prioritised for the healthcare, research, and technology cluster; significant adjacent sites should not be developed for large-scale residential purposes.

Q6: Cambourne should provide jobs near the new homes and include more employment space potentially including a commercial hub based on any new railway station above the A428.
Outside this commercial and retail hub, Cambourne should be focused on the large-scale offering of homes for families of those working across the Cambridge area.

Q7: in the southern rural cluster, opportunities for development on brownfield sites and for rural diversification, with small business-related developments should not be excluded.
Related residential development on smaller sites should also be accommodated, taking account of the Neighbourhood Plans. A priority should be given to sites in villages on rail routes, at public transport nodes and within public transport corridors. Subject to the decisions to be made concerning the East-West Rail Link, the option for significant growth and/or new settlement in appropriate locations that maximises the use of all forms of public transport should be considered as additions to the sites proposed.

[Q8-13 omitted]


We have welcomed the engagement with the Greater Cambridge Shared Planning team, and look forward to this continuing through this process in future discussions.

Cambridgeshire Development Forum December 2021

I have read about the themes and the interactions between the themes.
Water supply for the City and its environs is not mentioned. With regard to the themes on Climate change, Biodiversity, Wellbeing, Great Places, Jobs, Homes and Infrastructure; it is almost as though the supply of drinking water to the city has either been forgotten or ignored. The only time, as far as I can see, that water is mentioned is in the section on Infrastructure where it notes water should be delivered in the right places at the right time. It is very unlikely that there will be enough water for all the homes and developments proposed. The last Cambridge local plan, and consultations by Cambridge and Anglian water companies were informed many years ago that Cambridge would run out of water by 2035 and this was confirmed in the Stantec report recently and by the Environmental Impact Assessment of the last Cambridge local plan. The flow of the River Cam and its rare chalk springs and streams is in jeopardy because of the over abstraction from the chalk aquifer, as shown in the Report on the Water Crisis published by the city council and a later report arising from the Water Crisis publication. Until water can be supplied for all the homes and developments at the time of their building the developments should not go ahead.

Firstly, the Form To Assist gives a comment column for Vision and Aims.
We have numerous comments to make under this heading but I have not been able to locate this on the online system.
Secondly, the online system asks "Did you raise the matter that is the subject of your representation with the LPA earlier in the process?"
Guilden Morden Parish Council have not been involved earlier in the process. I have therefore clicked "No" but the system will not allow me to proceed further.
The online system allows only 100 words for each comment and to summarise the comments to avoid exceeding 100 words. It would have been helpful if the Form To Assist had stated that.
Vision and development strategy
Section / Policy Your comments
Vision and aims 1.Guilden MordenParish Council has concerns that the increase in population resulting from the additional homes target of 44,000 will have a negative impact on an already struggling traffic, school and healthcare infrastructure.
Specifically on traffic and congestion:
Commuting into and out of Cambridge at peak times already attracts significant congestion and delay for commuters.
This not only effects commuting by car but also bus and the Park&Ride buses as these typically use the same roads as the other commuters and the bus lane network doesn’t extend to where it’s needed.
Links between the train stations and the city centre are also currently inadequate and equally effected by commuter congestion.
The guided busway is too infrequent to be a viable alternative and typically the Park& Ride parking is at capacity leaving commuters with little alternative other than to drive into the city centre.
All of the above describes the current situation which will clearly be significantly worsened by the addition of 44,000 homes by 2041.
2. Is the methodology used in arriving at the figure of 44,000 defendable?

How much development, and where – general comments Support that the proposed developments are to be in major clusters in areas with good public transport.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support. Guilden Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support. Tightly drawn development boundaries are important to reduce encroachment into the countryside.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity. Where might this be generated locally by solar and/or wind?
CC/NZ: Net zero carbon new buildings Support
CC/WE: Water efficiency in new developments Absolutely necessary
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedial action if required
BG/GI: Green infrastructure Support for recognition of pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support
BG/RC: River corridors Support
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Support
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.
Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff fromhard surfacesto minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but improvements required rural public transport and congestion into Cambridge (see comments under Vision and Aims)
I/EV: Parking and electric vehicles Support
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support
I/AD: Aviation development Support
I/EI: Energy infrastructure master planning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

NORTH-EAST CAMBRIDGE ‘CORE SITE’, COWLEY ROAD,
CAMBRIDGE


GREATER CAMBRIDGE LOCAL PLAN 'FIRST PROPOSALS' (REG 18)

Written Response on behalf of U&I PLC / TOWN

Monday, 13 December 2021


Classification L2 - Business Data



CONTENTS




0.0 INTRODUCTION 1
1.0 POLICY RESPONSE 2


0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I / TOWN, to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).
0.2 U+I and TOWN have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (to be referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document). For the avoidance of doubt, these representations are submitted on behalf of U+I and TOWN as master developers rather than the landowners themselves.

0.3 Regeneration of the Core Site will be facilitated by the relocation of the WWTW, which will be funded from the Homes England’s Housing Infrastructure Fund, and which is currently going through a Development Consent Order approval process. Anglian Water will be submitting separate representations to the First Proposals, on this specific element.

0.4 U+I/TOWN have been actively involved in the policy formation process of the NEC AAP and are therefore looking to ensure there is policy consistency between the NEC AAP Proposed Submission and First Proposals documents.

0.5 Consideration will need to be given to the prospect of policy inconsistencies between the Greater Cambridge Local Plan (‘GCLP’) and NEC AAP.

0.6 As a point of broad principle, we would request that relevant GCLP policy (particularly where performance standards are stated) provides appropriate wording that defers to more area/site-specific policy, where it is being formed in other Development Plan Documents, such as NEC AAP. In the event of any inconsistency, this will ensure that there is a clear understanding over which policy takes preference. For instance, if a 20% biodiversity net gain (‘BNG’) target is ultimately adopted in GCLP policy, and a minimum 10% BNG is sought in NEC AAP, then there would be a clear signal in the GCLP policy that the NEC AAP policy is the correct standard to apply.



1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing
OBJECT
1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.
1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.
1.3 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.
1.4 It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.


Policy S/DS: Development Strategy

SUPPORT

1.5 We broadly support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land, noting that it has already been identified for homes and jobs growth.
1.6 However, we are extremely concerned by the ‘Homes’ target for NEC that is stated in the table on page 32, which refers to 3,900 homes between 2020 and 2041. Fundamentally, this is at odds to the trajectory that has been agreed with Homes England as a pre-requisite for the substantial public funding that has been agreed in principle to relocate the WWTW.
1.7 We would therefore instead support a policy that recognises 5,600 homes will be provided on the Core Site by 2041. Consideration will also then need to be given to other housing that is expected to come forward within the NEC AAP.



Policy S/NEC: North-East Cambridge

SUPPORT

1.8 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process.
1.9 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC.
1.10 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP.


Policy BG/BG: Biodiversity and Geodiversity

OBJECT

1.11 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).
The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so:

- Post-development biodiversity value of the onsite habitat;

- the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development;

- the biodiversity value of any biodiversity credits purchased for the development;

1.12 Whilst U+I/TOWN recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).
1.13 In terms of implications for the Core Site in North-East Cambridge, the NEC Ecology Study (2020) recommended that a target for a net gain of 10% is applied for all developments within NEC. Where this is not achievable within the site boundary then offsite measures should be provisioned.
1.14 By way illustration, a 20% gain to the 36.76 biodiversity units that have been identified in the Ecology Study would result in the need to achieve 44.112 biodiversity credits, in order to satisfy policy requirements. This seems highly ambitious, given the level of density that will need to be achieved across the Core Site to meet NEC strategy objectives. We will continue to make representations on this point as the NEC AAP progresses. GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.



1.15 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/HD: Creating Healthy New Developments

SUPPORT

1.16 We broadly support the 10 principles for creating healthy places. The vision for North-East Cambridge is of a healthy, inclusive, walkable, low-carbon new city district with a vibrant mix of high quality homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods.
1.17 One of the five strategic objectives of the NEC AAP is for a healthy and safe neighbourhood and notes the principles of the Health New Towns programme.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments

SUPPORT

1.18 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy GP/LC: Protection and Enhancement of Landscape Character

COMMENT

1.19 The policy notes that ‘the edges of Cambridge and the villages are an important area of transition which require sensitive landscaping to protect the setting of the settlements and to provide a well- defined edge which respects townscape and the countryside beyond’.
1.20 The Core Site at North-East Cambridge will need to be planned to a high density in order to fully achieve the the strategic objectives of the NEC AAP, as well as to hit the quantum of development required under Homes England’s Housing & Infrastructure Fund. This will require a number of buildings that are taller than may otherwise be commonly found in the north of Cambridge (including surrounding villages, such as Milton). The masterplan for the Core Site will take great care in how its development edges interface with the landscape and setting of nearby settlements, as well as adjoining ‘bad neighbour’ uses currently in existence. The policy will need to recognise the strategic objectives of NEC AAP and avoid imposing conditions that could unreasonably restrict development.

Policy GP/QD: Achieving High Quality Development

SUPPORT



Policy GP/QP: Establishing High Quality Landscape and Public Realm

SUPPORT


Policy J/NE: New Employment Development Proposals

SUPPORT

1.21 We broadly support the intent of the policy but consider it essential that GCSP takes a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area. There is a need to provide sufficient supply in order to meet the balanced homes/jobs requirements and to reflect the high employment density and employment skills these uses engender.
1.22 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It
noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries

SUPPORT

Policy H/HD: Housing Density

SUPPORT

Policy H/CB: Self and Custom-build Homes

OBJECT

1.23 The concern we have with this policy is the ability for the Core Site scheme to comply with the amount of Self-build/custom build being sought, given the high-density development that is envisaged. We would seek reference in the policy to wording that reflects the relevant policy in the NEC AAP i.e. to support ‘custom-finish’ as well.


Policy I/ST: Sustainable Transport and Connectivity
SUPPORT

It is being proposed that the local plan include a housing requirement of 44,400 homes over the plan period 2020 to 2041, the equivalent of 2,111 dwellings per annum (dpa). This level of need is higher than the minimum housing need established using the standard method by some 40%. The HBF supports the Councils’ ambitions to go beyond minimum needs and considers its approach to be consistent with national policy and guidance. As the Council note in the consultation document and supporting evidence, paragraph 61 of the National Planning Policy Framework (NPPF) is clear that the local housing needs assessment is the minimum number of homes the Council should be planning to meet with Planning Practice Guidance (PPG) outlining that there will be circumstances where housing needs will be greater than that arrived at using the standard method. In this case it is clear that the level of jobs growth in the Greater Cambridge area and the need to reduce the level of in-commuting to the area (in line with paragraph 104 and 105 of the NPPF) is sufficient justification to support a housing requirement in excess of the standard method.