Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

How much development and where?

Representation ID: 57767

Received: 11/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

The jobs are being imposed on the citizens of Cambridge, not needed by them. The inflow of jobs to the area is already causing significant infrastructural and social strain.
Endless growth is of course not theoretically possible in a physical world of limited resources. There are always factors which increasingly make further growth more unattractive, costly, and dangerous to the entities living in the growth system. What models does the Planning Service have to determine likely limits to growth of the Cambridge economy?

Full text:

The plan is based on job “needs” in the area, translated into housing “needs”. However, these are based mostly on projections of previous growth rates, with insufficient challenge as to whether similar continued growth is either “needed” by the citizens of Cambridge, or indeed feasible without very significant worsening of the following factors that are already acknowledged to be key problems for Cambridge:
* transport infrastructure
* housing affordability
* water scarcity
* social and economic inequality
* access to shared civic spaces
* access to green spaces
* ecosystem pollution and the generation of waste products
Endless growth is of course not theoretically possible in a physical world of limited resources. There are always factors which increasingly make further growth more unattractive, costly, and dangerous to the entities living in the growth system. What models does the Planning Service have to determine likely limits to growth of the Cambridge economy?

Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 57785

Received: 11/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

The additional jobs, to be supported by housing, is not necessary: unemployment here is very low. It is being forced on the area by external actors, including international investors. Cambridge is being exploited for financial gain. Building more homes in an overheated area will only make housing pressure and unaffordability worse: as it has done consistently.

Full text:

Cambridge city’s unemployment rate, at less than 3%, is significantly below the UK average. How does this mean that Cambridge “needs” jobs? Surely, objectively, most other regions in the UK need jobs more than Cambridge.

Under the plan, job growth is around 40%: so very clearly this job growth by far exceeds the current unemployment rate. Even accounting for Cambridge organic growth, it indicates that the jobs are predominantly for people who are not currently residents. This is not “Cambridge” jobs, it is jobs imported/relocated to Cambridge. The conclusion from this growth is that actually someone or something other than Cambridge needs these jobs and this growth.

To be clear, we believe this to be external parties: national (not local) government, external investors, and external developers. In fact, these parties are seeking to exploit the residents and the resources and positive reputation of Cambridge for their own financial or political benefit.

As residents we resent this, and we resent that the planning system forces the planning service to collude with these exploitative actors in the unhealthy continued growth of Cambridge.

Will the plan deliver housing for the residents of Cambridge that currently need housing? No. The current housing market in Cambridge is driven by investment factors, not by housing needs. This is well argued by London academic Deborah Potts in her 2020 book “Broken Cities”. The simplistic view that the solution is to “build more homes” is increasingly being recognised as wrong.

Will the plan make Cambridge homes more affordable? No. Despite significant recent home-building, the ratio of house prices to average income has increased from 7x in 2002 to 13x in 2017: clearly the current policies are making homes less affordable, as argued by Dr Potts.

Will the plan even make any affordable homes at all? No. The planning criterion of rent “affordability” is 80% of the market rate, and 60% for social rent. Based on the numbers given in the plan, 60% of the average Cambridge rent of £1250 is £750, which is above the average open-market rental price of the rest of England (£700)! Clearly the term “affordable” here is meaningless: the market rate is so high that NO homes are actually affordable. Once again this is a consequence of the market being driven by investment, not housing needs.

The Government’s Standard Method is normally used as a default. In going beyond this method we would suggest that the Plan should also:

include the total of existing unoccupied dwellings in the ‘already in the pipeline’ figure in calculating the number of dwellings required, and to explore all possible means, by incentive, penalty or otherwise, to ensure that such dwellings are occupied within a reasonable time.

adopt a policy that of all new dwellings constructed above the ‘Standard Method’ number, at least 25% should be housing for social rent

Comment

Greater Cambridge Local Plan Preferred Options

The edge of Cambridge

Representation ID: 57981

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

There is no limit in the plan on individual scheme sizes on the edge of town. The plan should set out more clearly the requirements on developers to provide better space access and community area.

Full text:

There is no limit in the plan on individual scheme sizes on the edge of town. The plan should set out more clearly the requirements on developers to provide better space access and community areas: lessons should be learned from developments like GB1 and GB2 where there will be over 400 properties with NO facilities for inhabitants and poor access routes for pedestrians and cyclists (ie low-carbon transit). As a result In GB1 and GB2 the Council is now in the invidious position of having to mildly request the developers to improve on this – a request so far ignored by the developers. This is not compatible with the stated aim of the plan to build houses which minimise transport and of building new communities.

Comment

Greater Cambridge Local Plan Preferred Options

Climate change

Representation ID: 57983

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

To achieve net zero and still grow the economy we would need to decouple emission quantities completely from growth, not just reduce or mitigate them. Several economic projections including one by the UN Environment Programme indicate that such “ absolute decoupling” cannot occur and “green growth” is simply not possible in practice. https://foreignpolicy.com/2018/09/12/why-growth-cant-be-green/

In order to “help”, the plan must demonstrate how it will reduce the emissions in Cambridge by more than 4% per capita per year. Otherwise the plan will simply “make it marginally less hard than it might otherwise be for Greater Cambridge to reach net zero”

Full text:

The objective is clearly stated: “Help Greater Cambridge transition to net zero carbon by 2050” . Net zero means reducing total net emissions to zero, not reducing the rate of growth of emissions to zero. To achieve net zero and still grow the economy we would need to decouple emission quantities completely from growth, not just reduce or mitigate them. Several economic projections including one by the UN Environment Programme indicate that such “ absolute decoupling” cannot occur and “green growth” is simply not possible in practice. https://foreignpolicy.com/2018/09/12/why-growth-cant-be-green/

This plan calls for an average growth of the machinery of the economy of around 1.2% per year. The UK economy is currently growing at around 3% per year per capita long-term average, so the plan will grow the local economy by over 4% per year.

If we are to believe the plan will “help”, then it needs to demonstrate how it will reduce the emissions in Cambridge by more than 4% per capita per year. Otherwise (as it seems) the plan will simply “make it marginally less hard than it might otherwise be for Greater Cambridge to reach net zero”

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 57986

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

It seems unlikely that the developments can generate enough renewable energy to meet their needs at the required standards. For residential buildings alone, at a conservative average of 50m2 per home, 49,000 homes using 35kWhr/year will need 85 Gigawatt hours per year of new generation capacity paid for within the homes price; far beyond developers construction capabilities, eg. wind turbine farms.
If via photovoltaics, this too seems unlikely. An average home of 50m2 would need 1750 kWhr/year. At typical solar efficiencies this would require 17m2 of solar panels, which is all of the South-facing roof capacity, for every single house.


Full text:

It seems hard to believe that the developments can generate enough renewable energy to meet their needs at the required standards. For residential buildings alone, at a conservative average of 50m2 per home, 49,000 homes using 35kWhr/year will need 85 Gigawatt hours per year of new generation capacity paid for within the homes price. This is well beyond the capabilities of developers to construct, for example. wind turbine farms.
If the assumption is that it will be via photovoltaics this too seems unlikely. An average home of 50m2 would need 1750 kWhr/year. At typical solar efficiencies this would require 17m2 of solar panels, which is all of the South-facing roof capacity, for every single house.
Does the plan have confidence that developers can design and afford net zero energy homes within the required standards, or does it expect that nearly every development will need “offsetting” measures? What absolute standard is the plan going to apply to for offsetting, or what are the “futureproofing” approaches?

Comment

Greater Cambridge Local Plan Preferred Options

CC/WE: Water efficiency in new developments

Representation ID: 57987

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

The policy only sets a water standard per home. This will limit the overall increase in water demand, but the Cambridge area is already in severe water stress. The policy should include a limit based on the absolute water stress of the Cambridge area. If this is intended to be set as a criterion for continued development, this criterion should be included explicitly within this part of the document. Otherwise a developer can claim they have met the standard per home, and that aggregate regional demand is “not their problem”.

Full text:

The policy only sets a water standard per home. This will limit the overall increase in water demand, but the Cambridge area is already in severe water stress. The policy should include a limit based on the absolute water stress of the Cambridge area. If this is intended to be set as a criterion for continued development, this criterion should be included explicitly within this part of the document. Otherwise a developer can claim they have met the standard per home, and that aggregate regional demand is “not their problem”.

Comment

Greater Cambridge Local Plan Preferred Options

CC/DC: Designing for a changing climate

Representation ID: 57989

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

The policy does not set any limits for how many homes need to be passively designed and built, just a priority ordering, which will be left up to the developer to choose from with no clear goals to reach.

Full text:

The policy does not set any limits for how many homes need to be passively designed and built, just a priority ordering, which will be left up to the developer to choose from with no clear goals to reach.

Comment

Greater Cambridge Local Plan Preferred Options

CC/FM: Flooding and integrated water management

Representation ID: 57991

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

The whole plan is proposed despite the knowledge that in the short-, medium-, and long-term ongoing growth will cause further disruption to the chalk aquifer and habitats on which we all depend. Until an approach to dealing with this is found, a massive development on this scale cannot take place without inevitable and irreversible damage to the water ecosystem.

Full text:

The whole plan is proposed despite the knowledge that in the short-, medium-, and long-term ongoing growth will cause further disruption to the chalk aquifer and habitats on which we all depend. Until an approach to dealing with this is found, a massive development on this scale cannot take place without inevitable and irreversible damage to the water ecosystem.

Comment

Greater Cambridge Local Plan Preferred Options

CC/RE: Renewable energy projects and infrastructure

Representation ID: 57992

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

As stated in the section on net zero carbon new buildings, the renewable infrastructure needed will need to be large to meet the housing demand, let alone for the infrastructure. A very clear and integrated plan will be needed, rather than leaving it up to individual developers.

Full text:

As stated in the section on net zero carbon new buildings, the renewable infrastructure needed will need to be large to meet the housing demand, let alone for the infrastructure. A very clear and integrated plan will be needed, rather than leaving it up to individual developers.

Comment

Greater Cambridge Local Plan Preferred Options

CC/CE: Reducing waste and supporting the circular economy

Representation ID: 57993

Received: 12/12/2021

Respondent: Cambridge Doughnut Economics Action Group

Representation Summary:

There is no absolute standard for achieved performance of the developments. Given that developers are prone to create credible-looking “plans” and then depart from them in practice, we would like to see absolute metrics of waste and circularity applied to new developments.

Full text:

There is no absolute standard for achieved performance of the developments. Given that developers are prone to create credible-looking “plans” and then depart from them in practice, we would like to see absolute metrics of waste and circularity applied to new developments.

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