Greater Cambridge Local Plan Preferred Options

Abrdn 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.

Abrdn 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 and would therefore be unlikely to be considered sound by a Planning Inspector during examination.

Abrdn understands and supports the ambition to protect existing business space. Abrdn notes that
the proposed policy J/PB is intended to state that where loss is proposed, it will need to be justified by evidence that it is no longer needed. Abrdn 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.

Abrdn 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.

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

Abrdn 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.

Abrdn submitted the attached topic paper to the Council in July 2021 which provided evidence on the key retail trends, including the shift to online shopping and the resultant lower footfall in retail areas. These trends have been accelerated by the COVID-19 pandemic and whilst footfall is expected to increase again post-pandemic, it is unlikely to recover to pre-pandemic levels as the online shopping trend has been accelerated. There needs to be a recognition of this in planning policy, by allowing for more flexible uses.

As recently discussed with the Council’s policy team, Abrdn is actively managing Lion Yard to encourage new occupiers. Abrdn’s has adopted an approach to proactive asset management for ensuring the continuing role of Lion Yard in maintaining the vitality and viability of the city centre. Abrdn’s approach to its assets is based around ensuring that it can adapt to changing circumstances that affect the performance of its assets. It is essential that the planning system is sufficiently flexible to allow that adaptability to take place.

To ensure this strategy is successful in retaining the vibrancy of Lion Yard, it is vital planning policy
supports flexible uses. 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 threaten the role of places like Lion Yard.

City centres are evolving from just offering retail to becoming experiential destinations, with a plethora of different uses such as gyms, health centres, offices and food & beverage quarters and consolidating complementary uses into a successful and sustainable places. In recent years, the changing dynamics and economics of the high street has placed significant pressure on the ability of investors to curate the places that they want to provide. This has been recognised by the Government in changes that it has introduced, such as the new Class E.

Abrdn is therefore supportive of its ability to change uses within Class E and to introduce 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. The city centre is a destination and Lion Yard could help draw in more visitors if it had a greater variety of uses. Residents and visitors want a consolidated experience which includes leisure, offices, the night-time economy and food and beverage options, rather than just retail and the need to keep people coming to the city centre, to stay longer and keep the centre alive, should be reflected in the emerging Local Plan policy.

Abrdn recognises that different retail areas across Greater Cambridge operate in different contexts. Abrdn therefore supports the proposed approach of developing a specific approach to retail policy for Cambridge city centre, including its shopping centres. Abrdn 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, Abrdn 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. Abrdn has previously provided the Council with a topic paper to inform the development of the retail policies and is encouraged that the Council is taking a more flexible approach to retail in Greater Cambridge.

Abrdn 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.

Abrdn 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.

Abrdn welcomes the Councils’ offer to engage with investors about their future ambitions for the city centre, and would be pleased to continue the engagement process as the plan’s preparation continues.

Abrdn 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. Abrdn therefore requests that the proposed policy J/VA sets out that these uses will be appropriate in existing retail uses.

Abrdn 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.

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