Greater Cambridge Local Plan Preferred Options

USS acknowledges the aims of proposed policy GP/PH but also recognises there are some circumstances where public houses are no longer viable and supports the caveats in the proposed policy that allow for their loss in some circumstances.

To ensure a wide range of jobs is available across Greater Cambridge, it will be important for the Local Plan to be flexible in its approach to commercial, retail and leisure uses. This is in accordance with paragraph 81 of the National Planning Policy Framework which requires Local Plans to support economic growth. It is also in line with the new Use Class E which encourages increased flexibility across use classes to allow for quick and effective reactions to changes in demand. Failure to provide sufficient flexibility across uses could stifle economic growth and risks the creation of derelict sites.

USS supports the ambitions for the Local Plan to encourage a flourishing and mixed economy in Greater Cambridge which includes a wide range of jobs. To ensure this aim is achievable, it is important that proposed policy J/NE allows flexibility for employment uses in Greater Cambridge. This would be in accordance with Paragraph 82 of the National Planning Policy Framework which identifies that planning policies should “be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances.”

Further, the Government recently introduced the new Use Class E to promote flexibility in town centres. It is crucial that the Local Plan does not seek to restrict sub-uses within the wider Use Class E. This would be in direct conflict with the aims of Use Class E.

USS understands and supports the ambition to protect existing business space. USS notes that the proposed policy J/Al is intended to state that where loss is proposed, it will need to be justified by evidence that it is no longer needed which USS supports. USS requests that the proposed policy recognises that it is becoming increasingly important for town centres to cater for flexible uses and that office uses are not always required.

USS notes that an effective way of better utilising land is to redevelop brownfield land and re-provide the existing uses alongside co-located residential uses. This is a proven way of addressing both the housing shortage and the need for other uses.

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

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

To enable asset managers to effectively respond to these changes, proposed policy J/RC should support all uses within Use Class E in retail areas. This is vital to ensure that an overly restrictive retail policy does not stifle economic growth and risk the creation of unoccupied and/or derelict sites. USS has previously submitted the attached topic paper (Greater Cambridge Local Plan and Retail Evidence Base Response on behalf of Universities Superannuation Scheme, dated July 2021) to the Council which sets out background to the current retail trends. USS requests that this evidence is considered in the development of a more flexible retail policy.

USS is also supportive of non-Class E uses within the city centre such as cinemas and leisure facilities which can complement retail uses and ensure retail areas in Cambridge continue to flourish. Consumer demand is pivoting towards experience-led shopping destinations and accessible convenience-oriented retail places and planning policy needs to reflect this.

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

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

USS notes that visitor accommodation, attractions and facilities can complement retail uses. The city centre would be an appropriate location for such uses due to its transport links and proximity to visitor attractions. USS therefore requests that the proposed policy J/VA sets out that these uses will be appropriate in existing retail uses.

USS notes the housing targets for the Local Plan and is supportive of appropriate brownfield sites being redeveloped to help contribute towards the housing need across Greater Cambridge.

USS supports the ambitions of proposed policy H/SA to support purpose-built student accommodation in Greater Cambridge. USS requests that proposed policy H/SA recognises that the city centre is an appropriate location for new student accommodation.

USS notes the ambitions of the infrastructure policies to deliver transport improvements and USS is supportive of an integrated transport solution and the benefits this will bring for the city centre. However, the Local Plan should recognise that such a solution will likely take many years to deliver and in the interim there should not be onerous restrictions on the existing modes of transport that are used to access the city centre.

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

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

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

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

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