Draft Greater Cambridge Local Plan for consultation

The University supports this policy. For domestic proposals should be able to use UK New Construction Residential (formally Home Quality Mark) and for non-residential BREEAM.

The University welcomes much of the proposed development plan which seeks to balance the challenges of growth for an internationally significant part of the country, with the need to protect and enhance the quality of life for existing residents, students and University staff.

The University particularly supports the use of local data to best inform the modelling of jobs and housing growth. The inclusion of additional headroom in both jobs and housing projections appropriately reflects Cambridge’s growth potential and aligns with wider ambitions across the sub-region. This approach is vital for long-term viability and enhances the overall robustness of the draft Plan.

The current policy approach relies on the NMS Site SPD, elements of which are now outdated and no longer fully appropriate. While some aspects of the SPD remain relevant, particularly in relation to access arrangements, public realm and the re-use of buildings, it is based on a 2018 masterplan that no longer reflects the current or future aspirations for the site.

Notably, the SPD identifies certain buildings for demolition which are now intended to be retained, including the Shell Building. In addition, the sustainability objectives set out in the SPD are out of date when compared with the more ambitious and up-to-date sustainability targets proposed elsewhere in the Local Plan. Planning policy, best practice and expectations for development have evolved significantly since the SPD was prepared.

Many of the core design principles set out in the SPD, such as access, active frontages and public realm, are already adequately addressed through Policy J/FD. As such, the continued reliance on a prescriptive, site-specific masterplan is not required and risks constraining appropriate development.

If the site continues to be allocated within the Local Plan, the policy should be amended to allow for a more flexible approach. In place of a fixed masterplan, a Development Framework should be required to be submitted alongside the first planning application. This would ensure that key principles are established while allowing sufficient flexibility to respond to updated policy requirements, evolving site circumstances and changing aspirations over the plan period.

The University supports many of the key principles of the proposed development strategy to direct development to the order of preference set out in the policy: where it has the least climate impact; where active and public transport is the natural choice; where green infrastructure can be delivered alongside new development; and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.

The University also agrees that sites should be developed at appropriate densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places.
In particular, we support the principles of:

• The continued development of the nationally important Cambridge Biomedical Campus, including through a release of land from the Green Belt;
• Using land more effectively at Eddington through intensifying development;
• Supporting the on-going development of an Innovation District at Cambridge West;
• Evolving and expanding Cambourne into a vibrant town alongside the development of a new East West Rail station and links to Cambridge West;

However, we object to the omission of the land at South West Cambridge and support the joint response from the University of Cambridge, Corpus Christi, Downing, Jesus and St Johns Colleges which offers an opportunity for greater strategic transport connections between Cambridge West and the Cambridge Biomedical Campus, as part of a new sustainable mixed-use development at South West Cambridge which will be highly accessible by walking, cycling and public transport to help meet the housing need within the plan.

See attached file with plans

The University supports the principle of a Development Framework for Madingley but considers that its current extent is overly restrictive and should be amended to include a limited number of small sites that have previously been developed on the edge of the village. This would better reflect national policy, support the vitality of the village, and enable sustainable development without undermining its character.

The University requests that the site allocation boundary (red line) is amended to remove the University Centre and other smaller properties.

The inclusion of the University Centre adds unnecessary complexity to the allocation. Its removal would allow the policy to focus on providing greater clarity and deliverability for a site that is now in separate ownership.

This policy needs to be clear on the l/h/d domestic figure when non-potable sources are unavailable. 80l/h/d is far tighter than govt target of 100l/h/d for water stressed targets. Not clear this ties in with 9% reduction target in non-household consumption by 2038. The initial premise is that development should only occur if there is adequate water supply for the development. The evidence there is, is provided in the main by the Cambridge Water Water Resources Management Plan. Will this be accepted in determinations?

The University supports the principle of this policy requiring a full 5 credits under the Wat01 heading within the BREEAM assessment for non-residential development. However the wording within the policy must include ‘unless demonstrated not practicable’ as many projects are refurbishments on tight urban sites often involving heritage constraints. There must be flexibility in the policy where justified.

The policy is generally supported but there is concern that the interpretation of attenuation may obstruct innovative solutions for water harvesting.

The University considers that there is a need for further supporting guidance regarding what qualifies as 'unacceptable impacts' as the exception to the presumption to support. The policy is open ended which may cause delays in determination of applications. Of particular significance in Cambridge is the assessment of impact of renewables on heritage buildings, where there is significant opposition to rooftop solar for example on older buildings. The principles of heat network connection are valid but only seem to apply to new build, shouldn't this also apply to major refurbishment? The links between this section and the infrastructure sections need to be aligned, as the infrastructure section refers to connection to gas networks and doesn't seem to require any statement on connecting to 'heat' sources/ networks.

Whilst generally supportive in principle, it is necessary to see the technical consultant analysis of the evidence base to justify the increase from 10% to 20% BNG as a blanket across the plan. The draft NPPF states “Development plans should only set local standards for biodiversity net gain which are in excess of the statutory net gain requirement where this is for specific site allocations, and is fully justified and deliverable”. Therefore justification should be provided for specific sites where 20% is feasible and viable. There should be some qualification that off-site provision is acceptable as there will be fewer and fewer instances where on-site can be achieved at the higher level.