Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

H/DC: Dwellings in the countryside

Representation ID: 60805

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Broadly support policy.

Full text:

We broadly support this policy.

Comment

Greater Cambridge Local Plan Preferred Options

H/RM: Residential moorings

Representation ID: 60806

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Requests review policy successes and failures to inform any necessary updates. Issues with existing provision:
● New moorings should come with appropriate pumpout facilities.
● Pontoons, to be designed with shape of a narrowboat in mind and ensure they fit.
● Moorings fixtures need cautious design and awareness of flood danger to boats and occupants.

Full text:

Again, rather than simply carrying forward the policy, it is important to review its successes and failures to
inform any necessary updates. Cambridge City Council’s 2017 consultation, which proposed among other things a potential doubling of houseboat residents’ fees and plans to clear the Riverside section of Abbey of houseboats entirely, met with fierce local opposition and lessons must be learned from this.
We are aware of some particular issues with existing provision:
● New moorings should come with appropriate pumpout facilities - the one on Jesus Green is inadequate and needs replacing.
● Pontoons, if supplied, need to be designed with someone involved who knows the shape of a narrowboat, and can ensure that boats will fit.
● Fixtures for moorings need to be designed with caution, and awareness that flooding can endanger boats and their occupants if they are moored with inappropriate fixtures.

Comment

Greater Cambridge Local Plan Preferred Options

H/RC: Residential caravan sites

Representation ID: 60807

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Refers to policy H/GT

Full text:

See comments under H/GT

Comment

Greater Cambridge Local Plan Preferred Options

H/GT: Gypsy and traveller and travelling showpeople sites

Representation ID: 60808

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Essential the policy is based on good evidence and genuine consultation with the communities.
This has not been the case in the past and resulted in gross under-estimate of accommodation need.
Concerned the company carrying out the assessment will have been unable to establish much contact with the communities.
Welcome “the needs assessment will seek to identify the needs of Gypsies and Travellers that no longer travel” as this was a serious emission previously.
The Plan should prioritise delivery of sites for Gypsy, Roma and Traveller communities and ensure they meet their needs, are sufficiently spacious, affordable, and are in locations that are desirable to this community.

Full text:

It is essential that this policy is based on good evidence and on genuine consultation with the communities
affected. This has often not been the case in the past. The 2011 Cambridge Sub-Region Gypsy and
Traveller Accommodation Needs Assessment was a desk-based exercise, dependent on existing data but
with a number of dubious assumptions applied. This resulted in a gross under-estimate of accommodation
need.
We are aware that the updated Accommodation Needs Assessment has been delayed by the impacts of the
pandemic and will reserve detailed comment on this policy until the results are available. We are however
very concerned that the private company carrying out the assessment will have been unable to establish
much contact with the communities in question. We also hear that there is uncertainty over the exact terms
of reference and area being covered by the assessment.
We welcome the statement that “the needs assessment will seek to identify the needs of Gypsies and
Travellers that no longer travel” as this was a serious emission in previous assessments.
The national context for this policy is a shortage of pitches on Traveller sites [1]. Gypsy and Traveller people
are estimated to have life expectancies of between ten and 25 years shorter than the general population.
Pupils from the Gypsy, Roma and Traveller ethnic groups have the lowest average score in GCSEs of any
ethnic group. Gypsies and Travellers are more likely to experience housing deprivation than any other ethnic
group [2].
Many current sites are in areas of high air pollution or and/or poorly connected. The chronic shortage and
poor quality of sites provided nationally can be corrected at the local level by local authorities. The Local
Plan should therefore prioritise delivery of sites for Gypsy, Roma and Traveller communities and ensure that
they meet their needs, are sufficiently spacious, affordable, and are in locations that are desirable to this
community.
[1] Research by Friends Families and Travellers - https://www.gypsy-traveller.org/wpcontent/
uploads/2021/01/Availability-of-pitches-on-Traveller-sites-in-England FINAL.pdf).
[2] https://www.gypsy-traveller.org/wp-content/uploads/2020/12/Friends-Families-and-Travellers-submissionto-
the-Commission-on-Race-and-Ethnic-Disparities-Call-for-Evidence-on-Ethnic-Disparities-and-Inequalityin-
the-UK-FINAL.pdf

Comment

Greater Cambridge Local Plan Preferred Options

H/CH: Community led housing

Representation ID: 60809

Received: 06/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Broadly support policy. Generally, the Green Party supports a large increase in council owned and managed secure rented property backed up by community ownership cooperatives, housing associations and co-housing projects.
It will important to be clear which policies in the Local Plan will apply to community led housing developments.

Full text:

We broadly support this policy. As a general principle, the Green Party supports a large increase in council owned and managed secure rented property backed up by community ownership cooperatives, housing associations and co-housing projects. It will important to be clear which policies in the Local Plan (e.g. net zero buildings, affordable housing provision) will apply to community led housing developments.

Comment

Greater Cambridge Local Plan Preferred Options

I/ST: Sustainable transport and connectivity

Representation ID: 60810

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Development around Cambridge over the
coming years will significantly affect travel links to the City. The position of the Cambridge Green Party that the scale of development puts insupportable pressure on both the ecology and the infrastructure of the Cambridge area. Discussion includes various standards for damage limitation.
Settings higher and more appropriate travel standard for developers.
All developments must have a net positive impact on congestion and pollution.
Welcome initiatives to reduce movements within settlements, and to enhance the use of either active or electric transport.

Full text:

The very significant development of communities, from proposals in the Plan, around Cambridge over the coming years will significantly affect not only the immediate area of the settlements, but the travel links to the City. It is the position of the Cambridge Green Party that the scale of this development puts insupportable
pressure on both the ecology and the infrastructure of the Cambridge area. What we are discussing below is damage limitation.
As a mitigating axiom there must be a ‘Green Line’ standard by which these developments are evaluated,
that is they should be net reducers of greenhouse gases by dint of their design delivering both very low emissions within the development but facilitating emission reduction in neighbouring
villages/settlements. Inclusion of such a ‘Green Line’ for planning consent is consistent with best practice, as set out in the strategy document of Taunton and Somerset council. Such criteria should be formally evaluated as part of the planning consent process.[1]
This ‘Green Line’ sets a higher and more appropriate travel standard for developers. Developers must therefore show that they will not provide simply convenient routes to ‘Park ’n’ Rides’ for getting people to the City centre or to their places of work. The significant increase in population must be accommodated so that it does not turn outlying villages into car parks, and/or overwhelm an already stretched transport infrastructure.
It must therefore take responsibility for both the consumer demand and the ecological impact of end-to-end change in travel load of anticipated journeys.
This would include the council ensuring, as part of the consent process, undertaking of an ongoing responsibility for underwriting of bus or other transport methods for completing habitual journeys [2].Examples of this exist and should be expanded as a matter of urgency.
An essential criterion against which all developments and their respective transport plans should be evaluated must be whether they reduce the total number of car movements into the city. This is to say they must have a net positive impact on congestion and pollution. Without a net reduction in car movements any hope of achieving a net zero city by 2030 will be lost.
Policy discussion of larger scale infrastructure projects must recognise that they will be subject to long delay
before delivery and will therefore have no immediate effect on the impact of either traffic or pollution.
Infrastructure initiatives should be swift to implement and implicit in planning permissions.
We broadly welcome initiatives to reduce movements within settlements, and to enhance the use of either
active or electric transport.
We specifically support attributes that can be incorporated into the design of the settlements themselves such as:
I. Cycle greenways
II. A parking permit cost that is a deterrent, with exemptions for special needs. Significant costs for second car permits .
III. Ensure ‘advance green phases’ for bicycles at lights
IV. European style provision for cycles and pedestrians and disabled
Bus transport should be enabled such that regular services reach travel hubs, or their nearest equivalent,
serving the main demanded destinations. Convenient and economical end-to-end journeys will be essential.
It must be recognised that public transport is a lifeline for many people. A lack of adequate provision
disproportionately affects people in lower income brackets who cannot afford to either own a car or live close to centres of employment.
Arrangements where possible for simplified and good value single ticketing would be an advantage and should be explored as is currently the case in the Mega-rider pilot in Cambridge.[3].
Travel hubs have been much spoken however they have been increasingly and incorrectly equated to Park and Rides. Unlike Park and Rides, they embody a fundamental infrastructure strategy to reduce the
incentive to own and use a car, and to provide safe and efficient transport for everybody. As references to Travel Hubs are common to many proposals, we strongly suggest that that pilots of the Smarter Cambridge Travel specification[4] be set up in at least two suitable areas, perhaps serving existing new developments.
As Travel Hubs are not as simple as park and rides they will need work to refine the integration of the various modes of transport involved, and the stakeholders.
[1] Somerset West and Taunton Local Planning Authority, ‘Climate Positive Planning Draft Interim Policy
Statement on Planning for the Climate Emergency’.
[2] https://www.stagecoachbus.com/promos-and-offers/east/single-bus-tickets-cambridge,
https://www.environment.admin.cam.ac.uk/travel/travel-bus
[3] https://www.stagecoachbus.com/promos-and-offers/east/new-flexible-bus-tickets
[4] https://www.smartertransport.uk/travelhubs/?
utm source=General+contacts&utm campaign=953b6ad41a-
Weekly+Mailchimp+Mailout&utm medium=email&utm term=0 df1204f23f-953b6ad41a-253543989

Comment

Greater Cambridge Local Plan Preferred Options

I/EV: Parking and electric vehicles

Representation ID: 60811

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Support policy, particularly that developers should be required to provide extensive and inclusive cycle parking at homes, destinations, and travel hubs.
Would strongly support a Workplace Parking Levy to be introduced across Greater Cambridge.
Car parking to be designed on a ‘need to have’ rather than a ‘want to have’ basis, a disincentive to car ownership. Possible alternative pricing for electric vehicles could be explored.
Policies must be fair to all sections of society, including meeting the needs of individuals with a genuine need for access to a car.
Car Clubs are a positive innovation.
Welcome the proposal for electrical charging points but call for greater ambition.
If Cambridge truly aspires to being a world-leading city it should be matching the Netherlands in the provision of this infrastructure.

Full text:

We support this proposed policy, particularly that developers should be required to provide extensive and
inclusive cycle parking at homes, destinations, and travel hubs. This provision should meet the Green Line criterion of contributing a demonstrable reduction in both traffic and emissions. We would strongly support a Workplace Parking Levy to be introduced across Greater Cambridge. This would act as a further disincentive to all but essential car ownership and vehicle movements and provide a source of funding to support eco-travel infrastructure.
Car parking, while necessary, should be designed on a ‘need to have’ rather than a ‘want to have’ basis. As
mentioned above, residents’ parking permit costs should be a disincentive to car ownership. Possible alternative pricing for electric vehicles could be explored. Policies must be fair to all sections of society, including meeting the needs of individuals with a genuine need for access to a car.
Car Clubs are a positive innovation. Lift sharing should be enabled on a Greater Cambridge-wide basis possibly using a car sharing system such as Liftshare. Developers can and should be responsible for making sure that Liftshare or similar apps are available to new residents.
We welcome the proposal for electrical charging points but call for greater ambition. We note that according
to Department of Transport Statistics [1], the number of charging points per 100,000 population is 44.8 in
Cambridge and only 28.0 in South Cambridgeshire. By contrast, the rate in Oxford is 69.3, in Bedford 58.4,
and North Devon 52: clearly there is room for improvement.
Rapid charging is essential to the rapid uptake of EV’s. The minimum specification for EV charging points as set out in the First Proposals is unambitious and will quickly become insufficient. New developments should
be specified to have a minimum of 11kW with smart loading and easy access to 3 phase charging. This will
meet the expected rise in the consumption of electricity by households (approx. 50%) in the near future and mean the increased capacity of inverters will not act as an infrastructure deficit, which would be very costly to
redress. This level of provision will require an increase in the capacity of local substations by about 50%. In 2017 the Netherlands 50% of public charging was rapid charging, compared to about 5% in the UK.
If Cambridge truly aspires to being a world-leading city it should be matching the Netherlands in the provision
of this infrastructure, in which investment in local EV charging points is fundamentally different to the UK.
The Netherlands had in 2017 a highly effective EV on request policy, under the ‘Green Deal’. the spending of
£2.2m in the UK is compared to approx. £28m in the Netherlands. The majority of UK spending is directed at
inter-city infra-structure. The GP Cambridge feel that if Cambridge is to meet best practice this difference
should be redressed both through policy and through planning criteria.
[1] Electric vehicle charging device statistics: October 2021
https://www.gov.uk/government/statistics/electric-vehicle-charging-device-statistics-october-2021

Comment

Greater Cambridge Local Plan Preferred Options

I/FD: Freight and delivery consolidation

Representation ID: 60812

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Support the need to reduce the number of road freight and servicing vehicles, and are concerned stronger wording is needed to move to a system of rail freight and other sustainable delivery mechanisms.
Support policy proposal concerning local travel hubs.
Require that road freight transport will not increase as a result of developments, planning will be made to account for end-to-end journeys and to provide infrastructure broad enough to lower net carbon emissions.

Full text:

We support the need to reduce the number of road freight and servicing vehicles, but would like to see strong wording concerning the need to move to a system of rail freight and other sustainable delivery mechanisms. We support the policy proposal concerning local travel hubs, and urge the Planning Authority to take note of the specification for Travel Hubs set out by Smarter Cambridge Transport [1].
A further ‘Green Line’ should be established such that existing levels of road freight transport will not increase as a result of developments and that, just as in the case of human transport, planning will be made to account for end-to-end journeys and to provide infrastructure broad enough to lower net carbon emissions. This would include for example enabling neighbouring villages or other settlements to have convenient access to freight travel hubs, while avoiding consequential environmental degradation.
[1] https://www.smartertransport.uk/travel-hubs/

Comment

Greater Cambridge Local Plan Preferred Options

I/SI: Safeguarding important infrastructure

Representation ID: 60813

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Support policy direction

Full text:

We support this policy direction

Comment

Greater Cambridge Local Plan Preferred Options

I/AD: Aviation development

Representation ID: 60814

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Aviation is an energy intensive and polluting form of transport, with both global and local impacts.
Airport infrastructure also has negative impacts on residents.
Core policy should support no development of the airport except under exceptional circumstances.
Policy should include additional explicit objective based on the criterion of ‘whole project’ emissions reduction and positive ecological impacts.

Full text:

Aviation is one of the most energy intensive and polluting forms of transport, with both global and local
impacts. Airport infrastructure also has negative impacts on residents, as exemplified by recent community
opposition to the proposed new radar at Marshalls Airfield [1] . The core policy should be that there should
be no development of the airport except under exceptional circumstances (for example replacing outdated
infrastructure with safer or lower-impact alternatives).
The Cambridge Green Party would therefore add to this policy direction an additional explicit objective to
apply planning permission in future based on the criterion of ‘whole project’ emissions reduction and positive
ecological impact.
[1] https://cambridge.greenparty.org.uk/news/green-abbey-councillor-objects-to-new-airport-radar.html

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