Greater Cambridge Local Plan Preferred Options

Marshall fully endorses and embraces the vision and aims of the ‘First Proposals’ consultation and is committed to embedding these aims at the heart of the vision for Cambridge East. Marshall has prepared separate detailed representations in response to the individual sections and policies that relate to the Development Strategy and to Cambridge East. The key points outlined in Marshall’s representations and how these relate to the Local Plan’s vision and aims are summarised below:

- Marshall strongly supports the allocation of Cambridge East for a truly mixed-use development which will comprise a significant number of new jobs, homes, community services / facilities and infrastructure. Marshall is pleased that the importance of the Site to Greater Cambridge’s growth strategy is recognised through this significant allocation.

- Whilst the Greater Cambridge Local Plan has planned for more homes than required by the standard method, Marshall considers that the Development Strategy is currently understating growth and could go even further to maximise Greater Cambridge’s economic potential.

- The safeguarded land at Cambridge East is one of the largest brownfield sites located outside of the Green Belt on the edge of Cambridge. It is one of the most sustainably located sites and represents the best opportunity to meet the GCSP’s Local Plan aims through the creation of a new, but complementary quarter for Cambridge. The opportunity to optimise the capacity of Cambridge East and maximise the site’s social, economic and environmental credentials should be thoroughly explored. Marshall considers that the scale of growth potential that could be achieved together with the quality of the Site justify optimising the allocation at Cambridge East and would justify the allocation of additional land east of Airport Way.

- Cambridge East provides a significant opportunity to address inequalities that exist to the east of Cambridge. Cambridge is one of the most unequal cities in the UK and has some of the least affordable housing, with pockets of deprivation. Cambridge East has the scale to achieve transformational change in the east of the City that will significantly improve the lives of local residents through the provision of access to skills development, education and life-long learning, a range of job opportunities, affordable homes and a range of cultural, leisure and retail options.

- Cambridge East also provides an opportunity to address the current lack of cross-city connectivity through the provision of a transformational transport strategy.

- Cambridge East is being planned to achieve an exemplar sustainable development which can act as a flagship for the Councils’ objectives. By pioneering new technologies and considering the long term welfare of our planet and its people, Cambridge East can create a transformative green infrastructure connecting the City with the countryside that sets the new global standard for sustainability. The potential for the sustainability benefits of Cambridge East would be even greater if development also includes land east of Airport Way, enabling planning at a genuinely strategic scale.

- In any event, however, Marshall is keen to work collaboratively with the GCSP and local communities to establish the best policy approach to the Site identified in the Preferred Options, ahead of the publication of the draft Local Plan in Autumn 2022.

Marshall supports the GCSP’s recognition of the need for growth in Cambridge and supports its aims to plan for enough housing to meet the needs of Greater Cambridge and plan for a flourishing and mixed economy that provides for a wide range of jobs. Marshall recognises that the GCSP’s ambition and proposed approach to deliver more homes than are required by the standard method reflects the Government’s objective to boost the supply of housing.

The Greater Cambridge Local Plan provides an opportunity to significantly boost the supply of housing and employment floorspace to support the area’s economic prosperity and growth ambitions. There is further potential to do this and truly maximise Greater Cambridge’s economic potential than currently identified in the ‘First Proposals’ consultation document and Cambridge East represents the largest and most sustainable opportunity to realise this potential. Marshall are keen to work positively and proactively with the GCSP and wider stakeholders to develop policies for Cambridge East that best reflect the GCSP’s Local Plan ambitions and objectives. Marshall also proposes to undertaken public consultation on the scheme during the second quarter of 2022, to identify the important constraints and opportunities in consultation with local communities and other interested parties.

Marshall recognises the level of growth that has been put forward by the GCSP and the proposed delivery of a number of homes that exceeds the standard methodology calculations. This submission is therefore made without prejudice to that position; however, Marshall does consider that there is opportunity through Policy S/JH to plan for even more ambitious growth.

Page 28 of the Preferred Options Local Plan consultation document explains that one of the alternatives that the GCSP considered was planning for the higher jobs forecast and level of homes associated with it. The report confirms that this alternative was rejected as it was considered that the higher jobs forecast was “not the most likely future scenario” (Page 28). Marshall supports and endorses much of the narrative in the draft Local Plan, which acknowledges the significance of the knowledge-intensive clusters and their importance to the reputation and resilience of the Cambridge economy, as well as recent trends of high economic growth. The scale of Cambridge East means that it is capable of delivering inclusive employment opportunities through the provision of a wide range of jobs for local people. Marshall are committed to delivering a scheme that can generate employment across a variety of sectors and that covers a range of different levels, not just highly skilled jobs. Marshall encourages the GCSP to reflect on the alternatives put forward for this policy and reconsider the opportunity to aspire for greater employment growth that captures the true economic potential of Greater Cambridge. Marshall would be pleased to submit further evidence to the GCSP.

Cambridge East has been identified as one of the key sites that can contribute to the delivery of new employment floorspace, new homes and other community facilities / services that meets the needs of Greater Cambridge. Marshall is pleased that the significant contribution which its land can make to the future wellbeing of Cambridge has been recognised through its draft allocation. Marshall is committed to working positively and proactively with the Councils to ensure that Cambridge East comes forward to optimise its social, environmental and economic potential.

The options for the distribution of homes and employment were tested in the suite of evidence base documents that the GCSP published in November 2020 documents and through the latest Preferred Options documents.

Marshall considers that, in order for the GCSP to plan at a scale necessary to generate investment for significant infrastructure and to meet the housing and employment needs of the area, the GCSP are right to adopt a strategy that combines different locations for focusing growth. Densification of existing urban areas is a logical place for development in sustainability terms; however, this option alone will be insufficient in terms of land capacity to accommodate the housing and employment needs for the area.

Therefore, the GCSP has opted for a blended strategy which directs new development towards locations that generate the least climate impacts, in line with the aims and objectives of the Local Plan. In locational terms, this objective to direct development to the locations that generate the least climate impacts means that the majority of the proposed growth is directed toward the Cambridge urban area, edge of Cambridge sites and new settlements. Marshall strongly supports the GCSP’s blended approach and the selection of proposed sites based on their ability to contribute to climate change objectives.

Pages 41 and 42 of the ‘First Proposals’ document, in relation to Policy S/DS, identify that there is a need for new strategic water supply infrastructure in Greater Cambridge to provide for the longer term needs of the preferred growth trajectories. It is indicated that a suitable solution may not be forthcoming until the mid-2030s and that the Local Plan may look to limit development levels until such a time that the strategic infrastructure is operational and able to support full delivery rates.

An integrated approach is required from all the key stakeholders in order to have a positive effect on the potential impacts of growth on the water environment. In particular, the onus is on Water Resources East and the water companies, through their obligations in the Water Industries Act 1991, to plan for and provide water to meet the requirements. Developments, including Cambridge East, will also have an important role to play and will need to make a more meaningful contribution to a sustainable future through the implementation of integrated water management regimes. The legal obligation and responsibility is on the water companies to address the expected water supply shortage and ensure that a suitable solution is identified to maintain the delivery rates required to meet housing and employment needs in Greater Cambridge. This matter should not influence the approach that the GCSP take to meeting the area’s needs. Marshall are keen to work with the water companies and the local authorities to understand and explore this matter further.

Having regard for the transport strategy outlined a part of Policy S/DS (pages 43 – 46), Marshall are supportive of the committed infrastructure proposals that are being progressed by the transport bodies and the objective of seeking to achieve a modal shift away from the use of the private car. As set out in the NPPF, the supply of large numbers of new homes can often be best achieved through planning for large scale development, provided that this development is supported by the necessary infrastructure. In order to ensure there is a genuine switch from car use towards sustainable modes of transport, new development must be supported by convenient, regular and affordable public transport, as well as safe and accessible pedestrian / cycle links.

Cambridge East provides a significant opportunity to address the current lack of cross-city connectivity through the provision of a transformational transport strategy linking the eastern side of the City with Cambridge Station, the city centre, Cambridge North Station and Addenbrooke’s and other key locations to the south. The greater the scale of development at Cambridge East, the greater the footfall, capacity and opportunity to deliver a transformational transport system that is a step change in transport in Greater Cambridge. Cambridge East has the potential to unlock mobility solutions that will make living, working and travelling in Cambridge easy, affordable and better for the environment.

Marshall and its consultant team are continuing to work closely with the GCSP, Cambridgeshire County Council, the Greater Cambridge Partnership and the Cambridgeshire & Peterborough Combined Authority to test and develop the most suitable and sustainable transport solution to support Cambridge East and beyond, exploring schemes that can be funded through already existing funding streams (e.g. City Deal), as well as more ambitious proposals which could be delivered through funding that the scheme itself can help to leverage given the scale of housing and economic potential.

Marshall supports the need for defined settlement boundaries, which indicate the extent of existing and planned development and help to guard the countryside against incremental growth. In defining the settlement boundary on the eastern edge of Cambridge, consideration should be given to the safeguarding land east of Airport Way, in order to accommodate for the relocated Park & Ride and allow for any future expansion of Cambridge East. Given the sustainability of the site and the location, the expansion of Cambridge East would be the logical place to locate future growth, whether that is determined through this local plan or through subsequent plans.

Marshall recognises the approach that the GCSP are taking regarding the timescales for the Local Plan relative to the North East Cambridge allocation.

Whilst the approach to the Local Plan and North East Cambridge AAP / DCO is acknowledged, there is a risk that the relocation waste water treatment plant proposals could be delayed, which in turn will influence the remaining stages of the Local Plan process, should the Local Plan continue to be contingent on Anglian Water’s DCO. The GCSP should consider accelerating the Local Plan ahead of the DCO if this begins hold up the progress of the Local Plan.

Marshall is continuing to work proactively with Anglian Water to consider opportunities to interlink the new waste water treatment plant site with Cambridge East. This includes looking at opportunities to join-up connectivity through walking / cycling routes and opportunities to deliver green infrastructure and biodiversity net gain.

In order for the GCSP to plan at a scale necessary to generate investment for significant infrastructure and to meet the housing and employment needs of the area, it is necessary to adopt a strategy that combines different locations for focusing growth. Realistically, a growth strategy that directs new development to the edge of Cambridge is the only option likely to generate the quantity of land in sustainable locations that are suitable for development. This reinforces the importance and value of Cambridge East and the capacity that it is able to deliver through the growth strategy.

As identified through the CPIER (Page 42), Cambridge East is the only side of the city that is not constrained and could accommodate significant levels of housing and employment growth, whilst still having the advantage of being close to the principal centres of employment and the existing transport infrastructure. There are no other sites with this scale of opportunity, that are released from the Green Belt and sustainably located so close to the city centre.

The Preferred Options consultation document rightly recognises the importance of Cambridge East to the growth strategy of Greater Cambridge through the allocation of the site for a significant mixed-use development. Marshall strongly supports the principle that the Local Plan should allocate Cambridge East and optimise the potential of the land to meet housing, employment and cultural needs in the City. Cambridge East is a development opportunity of national potential and importance and its scale and location make it a unique opportunity to establish the next chapter in the remarkable story of the City of Cambridge and Greater Cambridge area. It is the largest brownfield site and is the most sustainable opportunity to deliver significant growth embedded within the Greater Cambridge area. Cambridge East represents one of the key sites in the development of the Local Plan strategy based on its scale and its inherent potential to add to and diversify the City. It presents the opportunity to plan for forms of development that cannot be accommodated within the historic core and it is capable of providing the key missing links in a comprehensive sustainable transport network for the City.

Marshall is committed to delivering a scheme that is truly sustainable and of exceptional design quality. Through the work that has been undertaken and shared with GCSP so far, it is clear that a development of the scale of Cambridge East can have significant sustainability benefits in comparison to locating development over a series of smaller sites. The benefit of scale at Cambridge East can provide:
- A single integrated public transport and active travel solution to reduce carbon emissions and ensure local air quality improves;
- A single strategy to meet both biodiversity net gain and carbon sequestration, providing significant large-scale opportunities for major local environmental gains; and
- An opportunity to invest in sustainable approaches to water management, energy and biodiversity.

Marshall will continue to work collaboratively with the GCSP to undertake further capacity testing and prepare evidence base documents that demonstrate that the site is capable of developing into a high quality urban quarter, which can enhance the social and economic objectives of the Local Plan.

Marshall would like to take forward close joint working with the councils by entering into a PPA with the GCSP, which will facilitate further discussions around scheme design, mix of uses, the supporting transport strategy and other technical evidence, ahead of the preparation of a draft policy in Autumn 2022.

In advance of the next version of the Local Plan being published, Marshall is committed to:
- Engaging and working with the local community to understand their views and how those views should influence the content and development of Cambridge East. As part of this, Marshall is currently developing a plan to launch public consultation during the second quarter of 2022 to understand the issues of importance to the adjoining communities and other key stakeholders;
- Developing a clear, shared vision for the development of the land;
- Identifying ways in which the development of Cambridge East can help deliver wider objectives for the City of Cambridge and Greater Cambridge area;
- Undertaking further capacity testing which maps out the scale of development that can be accommodated consistent with enhancing access to the countryside and green infrastructure, whilst protecting important views and environmental assets;
- Developing the technical evidence base to support the delivery of the development;
- Planning the phased delivery of infrastructure, including green infrastructure and social infrastructure;
- Optimising sustainable transport measures and planning for a net zero development;
- Developing a detailed draft policy for Cambridge East that can be embedded in the local plan; and
- Creating the confidence which allows the GCSP to rely on the high quality and delivery of Cambridge East in favour of development proposed in less sustainable locations.

The importance of the main sustainability and climate change objectives in the ‘First Proposals’ is such that the spatial strategy of the Plan must optimise sustainable choices adjacent to Cambridge rather than dispersing growth and encouraging increased travel. By optimising development at Cambridge East, this allows the plan to avoid the need to plan development in less sustainable locations.

Marshall agrees that planning to limit and mitigate the effects of climate change is of central importance. Cambridge East is being planned to achieve an exemplar development which can act as a flagship for the Councils’ objectives. By pioneering new technologies and considering the long term welfare of our planet and its people, we believe Cambridge East can create a transformative green infrastructure connecting the City with the countryside that sets the new global standard for sustainability.

The ambitions of Cambridge East include net zero embodied carbon and net zero operational carbon through careful design of infrastructure, carbon offsetting through local (if possible) sequestration via the creation of new or enhancement of existing areas of woodland and other habitats, sustainable water management for the wider area (not simply for the benefit of Cambridge East), and creating a ‘green link’ which will encompass many climate initiatives such as using green infrastructure to reduce the impacts of climate change (e.g. providing shade and reducing overheating). These commitments are set out in the Sustainability Vision that Marshall submitted in February 2020. These commitments will be developed further through Marshall’s joint working with the GCSP.

Marshall’s view is that there is the potential for the sustainability benefits of Cambridge East to be even greater if development also includes land east of Airport Way, enabling planning at an even higher strategic scale.

In line with the climate approach of the Local Plan, the ambitions of Cambridge East seek to provide a net zero operational development, and reduce embodied carbon to net zero through construction. Offsetting would ensure consideration at an on-site and local scale where feasible. In order to provide a holistic approach to carbon offsetting, it is recommended that consideration is given by GCSP to a holistic carbon offsetting strategy, and the demarcation of potential sites where the offsetting of the carbon impacts from allocated Local Plan development could bring additional local benefits. This will ensure that this intrinsically important, yet often difficult to apply, policy is targeted, local, and achievable. Marshall is happy to work in collaboration with GCSP in order to develop, agree and achieve a strategy which works for all. Through collaboration a truly balanced plan will be created, in which the 4 pillars of the Local Plan objectives are achieved by embracing growth rather than resisting it.

More detail is provided below when responding to specific proposed policies.