Draft Greater Cambridge Local Plan for consultation

We believe this policy is weak from an environmental sustainability and climate mitigation point of view and do not support it. The policy focuses on noise and amenities and does not directly reference greenhouse gas emission associated with aviation and associated infrastructure. We strongly suggest that this policy be amended to explicitly consider greenhouse gas emissions, include conditions based on climate impact of any developments, distinguish between different purposes of aviation, and future proof by specifying that any development will align with national aviation decarbonisation pathways.

In addition to the requirements included we think children’s play should be considered more broadly than just ‘play area’ there is a lack of integrated play and playable landscapes in Cambridge and we would like to see policies similar The London Plan S4 including:
“incorporate accessible routes for children and young people to existing play provision, schools and youth centres, within the local area, that enable them to play and move around their local neighbourhood safely and independently.
for large-scale public realm developments, incorporate incidental play space to make the space more playable”
We would like to see public realm incorporate more elements for engaging children. Evidenced through the success Dinky Doors https://www.dinkydoors.co.uk/ has had on engaging children while walking and making space for them in the public realm.

Support this policy
Point d regarding food growing should be strengthened to actively encourage integration of food bearing landscapes for urban foraging. This will become increasingly important with respect to future climate and food security impacts recently cited in the government paper: Nature security assessment on global biodiversity loss, ecosystem collapse and national security
https://www.gov.uk/government/publications/nature-security-assessment-on-global-biodiversity-loss-ecosystem-collapse-and-national-security
This policy should also include opportunities for playable landscapes

This policy should include a requirement to limit the light spill from shop fronts which has become an issue in the high street in the last few years with new shops using excessive LED lighting that is disproportionate to the streetscape at night and consumes more energy than is necessary.

We support this policy, but believe that it should be made stronger by tightening the specificity of the language used and including accountability mechanisms, making the car-reduction intent harder to dilute at the application stage. We would also suggest that the policy should make explicit that development proposals should be designed in accordance with the sustainable travel hierarchy. Additionally, we would recommend that public transport should be frequent and reliable as well as ‘high quality’, and should be operational from first occupation in new developments.
Additionally Introduce mandatory permeability standards based on site size
Walking and cycling connections should be required, not optional

We support the parts of this policy relating to cycle parking but believe it could be made stronger in the following ways: firstly by strengthening the cycle parking provision to require that this be future proofed to allow for future growth in cycling without the need for additional planning application, and to specify that ‘non standard cycles’ includes cargo bicycles, tricycles, longtail bicycles, bicycles with trailers and handcycles, reflecting inclusive and family friendly travel provision. Secondly, for major developments, we suggest that parking provision and usage should be monitored post-occupation, with mechanisms secured through condition or legal agreement to enable reallocation of space to sustainable modes if car parking demand is lower than anticipated.
Point 4 - it is not clear if this relates to car parking or cycle parking - we have assumed car parking. Greater clarity is needed to be clear on the number of car parking and cycle parking spaces.
The policy should require cycle parking to have equivalence with car parking in both location and journey quality, including step-free access and minimal barriers
We are aware that there are developments within Cambridge built for residents who would like to not use cars and to be able to enjoy more amenity space in place of car parking, and be forced to put in higher levels of car parking than desired. If developers can demonstrate that residents are willing to be car free or very low car use through a mechanism such as a sustainability or travel charter - car free or much lower levels of car parking should be allowed. We would like to see city centre residential developments be car free as they would be in London. For example the Parkside allocation site.
We would also like to see car club space requirements specifically included.

We support this policy but believe that the Delivery and Service plan required for proposals should explicitly require that climate targets are considered, and a sustainable servicing hierarchy should be used.

We strongly support this policy and would like to see a greater reference to applying weight to climate considerations in the valance of affecting heritage, for example the use of PVs on heritage roofs, or adapting windows

Housing growth is becoming more dispersed while employment remains concentrated around Cambridge.
Dispersed growth will increase pressure on transport corridors and make sustainable travel harder

Theme 3: Density, car ownership and sustainable travel
Higher-density development can support sustainable travel, but only when it is paired with low car ownership and strong alternatives to driving. In Greater Cambridge, dense schemes are too often delivered alongside high levels of private parking, which consumes land, dominates streets and undermines walking and cycling. This also pushes up housing costs, forcing households without cars to subsidise parking through higher prices.

The Local Plan should explicitly link higher density development to lower car ownership, avoid assuming one car per home, and require parking to be optional, generally separated from housing, and transparently priced. Without this, density will continue to be experienced as a problem rather than an opportunity.

We support this policy but believe it could be made stronger in the following areas. Firstly we suggest that the policy should explicitly state that 10% BNG is a minimum expectation, not the desired outcome, and require higher BNG in defined circumstances (large sites, strategic allocations, sensitive locations). Secondly we suggest a requirement for BNG to contribute toward ecological connectivity i.e. creation and enhancement of ecological networks including river corridors and habitat stepping stones as set out in the Cambridgeshire Nature Recovery Strategy. And finally we suggest that biodiversity enhancement should also contribute to climate change adaptation, nature-based solutions, flood resilience, and improved health and wellbeing.