Draft Greater Cambridge Local Plan for consultation

ARU has a long-established history and connection to Cambridge. ARU’s origins in Cambridge began with the opening of the Cambridge School of Art in 1858. This historic connection is still apparent today with the Ruskin Building, home of the Cambridge School of Art, remaining on the original East Road site. The University became Anglia Polytechnic University with the merging of Cambridgeshire College of Arts and Technology (CCAT), before more recently becoming Anglia Ruskin University in 2005. This heritage is crucial to understanding the University’s long-established role and status within the City.

ARU has provided a valued higher educational offering to the local community, the regions and beyond for over 150 years. The offering has been notably diverse, respecting the value of both academic and more vocational education to students from all walks of life, and from across the UK and internationally. This has ensured the City provides a broad offering and choice of education, complementing well the University of Cambridge’s research-intensive offer, with the two universities working closely together in many areas. Indeed, ARU has received many accolades, which should be celebrated. ARU was named Times Higher Education University of the Year 2023, as well as receiving numerous other recognitions such as a Gold award for the quality of their education in the Teaching Excellence Framework and The Queen’s Anniversary Prize for their world-leading music therapy work in 2021. Despite current challenges in the higher education sector, ARU continues to be financially strong.

The supporting text to draft policy J/FD identifies both University of Cambridge and ARU as ‘significant employers in Greater Cambridge’. However, the subsequent text is dominated by the role and status of the University of Cambridge and its associated Colleges. ARU feels strongly that this supporting text needs to be more balanced and clarify the role and value of their institution to Greater Cambridge.

As ARU has previously discussed with officers at Cambridge City Council, the evolution and growth of ARU in Cambridge has led to a broader ‘East Road Campus’, which includes multiple hubs of activity as opposed to relying on the original site of the Cambridge School of Art (i.e. the site fronted by the Helmore building). Whilst this site will naturally retain historic value to ARU, it has been apparent for well over a decade that this original site is far too constrained for the committed and aspirational growth of ARU. This has been reiterated through various Local Plan stages, planning applications (such as Young Street in 2012 and Compass House in 2013/2015) as well as the masterplan evolution and multiple iterations since the BDP version in 2009. The latest Development Framework produced for ARU reiterates this clear trend, clarifying the broader East Road campus as ‘East Road North’ and ‘East Road South’ (see extract Appended to these representations for a visual depiction).

The current wording of J/FD provides clear support for education within the City Centre. There is also support for education development on the edge of the City Centre, such as the Eastern Gate and Grafton Area of Major Change. ARU strongly supports this, though note that parts of the East Road campus may well deliver student accommodation, as well as faculty development. On this basis, ARU considers that the extent of the ARU ‘campus’ should be defined within this policy and associated proposals map so that it can suitably inter-relate with the reading of other policies such as draft H/AH. Such an approach provides greater clarity when interpreting the Development Plan as a whole.

As parts of these areas are also outside of the City Centre, it is considered that point 4. warrants its own subheading to ensure accuracy. This could be termed ‘University Development on the Edge of the City Centre’ to remain consistent with existing phrasing.

The draft policies map identities the City Centre designation as a ‘Policy Area’. However, it proves extremely difficult to review the boundaries using this tool, particularly given the number of designations in this central location.

It is considered that any final policies map should provide clear distinctions and colour coding for the various ‘Policy Areas’ so it is easier to read the map, including an ARU campus designation.

The selected Development Strategy makes clear that it seeks to avoid further release of Green Belt to deliver the needs in the plan period. This is further clarified in the supporting information supplied with Policy S/DS, specifically paragraphs 2.63-2.66 (the pdf version of the document). However, ARU considers the approach to the designation of Green Belt is fundamentally flawed.

The draft Plan relies on previous iterations of Local Plans to justify the existing Green Belt designation. Paragraph 2.63 states ‘Cambridge has had a Green Belt since the 1965 Development Plan, and Cambridge’s locally specific Green Belt purposes have been embedded in development plans over many years’. However, this fails to recognise that there are no such things as ‘locally specific Green Belt purposes’. National planning policy is clear there are five national aims of Green Belt, as set out in the NPPF. Local Councils should consider which of these national purposes apply to their designation. The Council’s Green Belt Assessments can then assess specific parcels of land against the relevant purposes. Crucially, this must remain within the categorisation of the five national purposes.

Greater Cambridge are relying on their own ‘local’ purposes which are effectively adaptations to those set at the national level. Whilst this may have been accepted by previous Inspectors as sound, this does not automatically lead to the assumption that it remains as such. Not only have national Green Belt purposes experienced subtle change over the decades (see response to S/GB), previous errors should be addressed rather than carried over. This error has become all the more apparent since the creation of Grey Belt. As part of this, the matter relating to ‘towns’, not ‘villages’ in national purpose 2 has become a source of contention.

By way of example, Appeal Ref: APP/V4630/W/24/3347424 – Land off Chapel Lane, Great Barr, Walsall addressed the point of villages vs towns. Paragraphs 21, 22 and 23 of the appeal decision set out the Inspector’s Green Belt analysis. It stated “Villages should not be considered large built-up areas. The appeal sites cannot therefore contribute to Green Belt purpose (a)”… and “Given that Daws Heath is a village, the appeal site cannot contribute strongly to Green Belt purpose (b) which is to prevent neighbouring towns merging into one another”. The Green Belt Planning Practice Guidance confirms that purpose (b) relates to the merging of towns, not villages (see Paragraph: 005 Reference ID: 64-005-20250225).

The Council’s Green Belt assessment (August 2021) specifically assesses the Green Belt purposes against the ‘Cambridge Purposes’. This is fundamentally flawed and conflicts with national policy. The greatest conflict is between Cambridge Purposes 3 ‘Prevent communities in the environs of Cambridge from merging into one another and with the city’ and national purpose 2. ‘To prevent neighbouring towns merging into one another’. These purposes are crucially and distinctly different. This is made apparent in the Council’s own 2021 Green Belt Assessment which states in Table 3.1 that ‘Cambridge Purpose 3 is closely related to NPPF Purpose 2. However, the focus here is not on gaps between ‘towns’ specifically, but on the gaps between Cambridge and the surrounding necklace of villages and on the gaps between individual villages themselves - both those within the inner necklace and those more distant’. This assessment directly conflicts with both the Planning Practice Guidance and the Inspector’s conclusion in the abovementioned appeal at Walsall. That Inspector made clear that national Green Belt Purpose 2 relates to merging of towns. It cannot apply to more modest settlements, such as the necklace villages approach which Cambridge Purpose 3 relies upon.

In this context, the reasons and value of particular parcels of land surrounding Cambridge being included within the Green Belt are fundamentally flawed and warrant review in the context of the 5 national purposes. This would ensure accordance with national policy. By way of example, land parcel AR4 of the 2021 Green Belt Assessment includes ARU sports pitches at Howes Close. This assessment concludes ‘relatively limited’ contribution to Cambridge Local Purpose 1 and 2 (arguably slightly better aligned with the national purposes, though still with some inconsistency). In contrast, the site is identified as having ‘Moderate’ contribution to Cambridge Local Purpose 3. However, as these representations elude, Cambridge Local Purpose 3 is fundamentally flawed and conflicts with the national purposes. As such, sub parcel AR4 has limited, if any contribution to the national Green Belt purposes. This is a significant material consideration and warrants further attention as one develops a development strategy for the Greater Cambridge area. The sustainability credentials of a site in such proximity to central Cambridge, cycle networks, employment opportunities and the public transport network is undeniable. Furthermore, this is simply a review of a single site given it is owned by ARU. Indeed there may well be multiple Green Belt sites that have limited if any value to the Green Belt when one correctly assesses the land against the relevant national Green Belt purposes.

Policy S/GB sets out 3 purposes for the Cambridge Green Belt. However, these do not align with the national purposes, instead adapting them to what the Council consider better reflects the Cambridge context. It is accepted that this approach is long standing with the principle of some form of Green Belt going back to when provisions were made in the Town and Country Planning Act 1947. However, it is reiterated that Green Belt was still new at this point and the purposes and way in which it was dealt with was not clear or consistent. By way of example, The Ministry of Housing and Local Government gave advice to local authorities on Green Belts in Circular (42/55). This stated the 3 main functions of Green Belt were:
-to check the growth of a large built-up area,
-to prevent neighbouring settlements from merging into another; or
-to preserve the special character of a town.

The current national purposes have evidently evolved since these 3 examples. Indeed there has been much advice and guidance published since the 1947 Act. Whilst the general approach remains comparable, it is crucial to recognise that the five national purposes (established in PPG2 in 1995) differ from the considerations that applied at the time Green Belt was first being formed at Cambridge. This particularly relates to the prevention of neighbouring settlements from merging into one another as opposed to neighbouring towns (current national purpose 2). Further information on this point is provided in response to Policy S/DS Development Strategy and so should be reviewed in tandem with these representations.

To resolve this issue, a Green Belt review is warranted to assess designated land against the national Green Belt purposes. This will ensure the Cambridge Green Belt and resulting Development Strategy reflects the latest policy position. Indeed, it is expected that various parcels of Green Belt land may not contribute to any relevant national purposes and as such, would be suitable for release.

It is also noted that there is an error in the supporting information that accompanies Policy S/GB. It states ‘The Cambridge Assessment (2021) assesses the contribution of different parcels of land to these purposes and to identify grey belt land to inform plan making in line with the NPPF and national guidance’. Grey Belt policy did not exist in 2021 and the Cambridge Green Belt Assessment (2021) did not identify grey belt land as claimed. A Grey Belt assessment has not been undertaken by Greater Cambridge to date. Whilst it is understood that Greater Cambridge intend to produce one, it is reiterated that sufficient time to fully comment on that report ahead of the Regulation 19 version should be provided.

ARU has significant concerns with the application of a requirement for student accommodation to provide a financial contribution the equivalent to 40% affordable housing provision. Viability ultimately plays a significant part in this and ARU is reviewing what evidence can be collated to demonstrate that this is not a viable or justified approach. Any such evidence will be made available at or prior to the Regulation 19 consultation.

At this stage, ARU is concerned that the financial burden of this policy will ultimately be felt by ARU students. Rents will inevitably have to rise to accommodate this requirement and further evidence to justify this concern is being considered. In the meantime, it is stressed that as ARU is a widening participation university, their students are from a varied and diverse background, many with limited resources. Affordability of student accommodation is therefore already extremely challenging for many of its students, and the need to make a significant contribution to affordable housing, however that is calculated, will add significantly to that financial burden. As many of ARU’s graduates work in the public sector – in health, policing and local government - where salaries are typically lower than the private sector, that financial burden will be felt for many years as they repay their student debt. This step would further impact already hard-pressed and financially challenged public servants.

Ultimately a combination of a cost of living crisis, as well as high costs for student accommodation within the City influence students’ decisions on whether they can afford to reside away from home and/or in the City for their studies. This isn’t necessarily a choice but a trend directly influenced by policy making.

ARU considers it crucial that the Local Plan makes sufficient commitment to facilitate the rooms and space required by students (see response to S/JH) but also policy commitment to ensure it is affordable. Affordability is crucial to diversity and inclusion priorities. Requiring student accommodation to align with 40% affordable housing requirements assumes it is akin to market housing. In essence, the resulting charge to rent said space would need to be at a sufficient level to sustain the financial burden of a 40% contribution. Without this, developers would be disincentivised from opting to deliver PBSA.

At no point does this policy requirement provide for or take account of lower income students or those with other challenging socio-economic backgrounds. This model assumes all students are comparable and opportunities for financial assistance such as student loans put all on par. However, this is not the case. There is a clear disparity between the possible student loan vs student housing costs in Cambridge. For the latest academic year, the maximum maintenance loan that can be obtained for a student studying outside of London from a low income household is £10,830. However, the average rent for year September 2025/Summer 26 in ARU owned accommodation is £7,513, and £9,134 in facilities partnered with ARU. These averages were calculated using the figures from the ‘Cambridge Accommodation Cost Comparison Chart’ available on ARU’s website. Necessities such as food, personal items, travel and study materials also need to be funded before any consideration of social activities. This illustrates how challenging the rental market is for students and the need for policy to assist rather than worsen the existing situation faced by students. The requirement for 40% affordable housing is not considered to assist in this fundamental disparity.

Indeed, if student housing is to be considered within the Objectively Assessed Need (ARU reserves their position on this, depending on the outcome of the next iteration of the Plan), it is considered Greater Cambridge should consider a more innovative approach to addressing affordability. Subject to viability, ARU would welcome further discussions with the Council to consider alternative options that may help affordability for a broad demographic range, including key worker and young professionals that are closely aligned with the institution.

It is also considered crucial that any final policy takes into account the very different accommodation models in place for the two principal higher education institutions in Cambridge. As the Iceni Report (Housing Needs of Specific Groups in Cambridge and South Cambridgeshire, 2025) states ‘The HESA data records that around 60% of ARU students either live in their own residence or with their parents, while the equivalent figure for UofC students is only 6%. Conversely, 80% of UofC students are in property provided to them by the University, while only 2% of ARU students do this’ (paragraph 10.31). This is for the year 2023/24 and caveats the self-reported nature of the survey. Nevertheless, these statistics are most telling. University of Cambridge ultimately has stock to serve its students and has greater control over these assets and resulting rents. In contrast, ARU does not have an equivalent offering with students having to rely on alternative means; often by necessity rather than choice.

ARU is committed to rectifying this issue, providing students with greater certainty and choice in PBSA. This will include the development of new PBSA owned by ARU and referenced within the latest Cambridge Development Framework (i.e. potential opportunities at East Road North). However, the 40% affordable housing contribution will have devastating consequences on the ability of ARU to fund such proposals to help address this shortfall. This may be alleviated through modification to the policy. For instance, providing commitment that this 40% requirement does not apply on land owned by an existing University, or to accommodation built by an existing university. This would provide far greater certainty than the current drafting which excludes the requirement from development ‘within an existing university or college campus site’.

With a lack of certainty over what may be considered part of the existing university campus, the application of the policy is fundamentally flawed. Not only that but if the Council’s interpretation of ‘campus’ is restrictive, it could lead to unintended consequences. For instance, universities feeling compelled to develop additional student accommodation on areas the authority considers the ‘campus’ to make said developments deliverable and so re-directing pressure for land for the more traditional education and research spaces off campus. This policy ultimately pressurises ARU to disband their more condensed campus offering; a key market USP for many prospective students. Ultimately, the policy as drafted could unintentionally manipulate the natural and optimal evolution of ARU to the determinant of not only its operations, but its desirability to students and its positioning within the City.

The alternative would be to ensure the ARU East Road campus is specifically defined as a policy area and reflects the extent identified within ARU’s latest Cambridge Development Framework (i.e. East Road North and East Road South). Whilst such designation has clear value in line with comments to J/FD, for the specific point of where the 40% requirement (if found sound) is applied, it is preferential to simply exclude ARU owned land. This approach avoids the abovementioned concern of inadvertently manipulating the uses within the campus limits.

ARU is concerned that the figure set out in point 4 of the draft policy is misleading and does not reflect latest projections. The draft policy states ‘Within the total number of homes required, development will provide 2,042 additional units to meet the accommodation needs of students over the period 2024-2033’. In the first instance, this does not fully cover the plan period and instead aligns with the data provided by the University of Cambridge. Furthermore, it fails to acknowledge that this 2,042 figure only accounts for the 800 additional bedspaces required by ARU by the year 2025/26. It is reiterated that circumstances have changed since that evidence was issued and ARU has sought to supply evidence that reflects the latest position, as well as aligning with the Council’s plan period.

Latest evidence suggests 70% of students live within a radius of 5km from the Cambridge East Road campus. This broadly covers the extent of the City. This percentage includes those within rented accommodation, ARU owned accommodation, own residence, parental/guardian home and private sector halls.

It is reiterated that a number of institutions across the country are noticing a trend in increased commuter students with the general consensus being cost of living as the cause and lack of PBSA also being experienced by a number of cities. ARU acknowledges this trend and seeks to embrace the right for students to choose the best learning and lifestyle model for them. ARU considers it is important to consider this trend in the longer term and it will remain relevant for future Local Plan reviews.

However, if the trend towards increased commuter students is indeed down to the predicted causes, this is considered a fundamental concern. This trend hinders diversity and inclusion goals for not just the institution but also the local authority. As the evidence base notes ‘Compared to ARU, a significantly larger proportion of undergraduate and postgraduate students at the University of Cambridge reside in University of College maintained accommodation’ (paragraph 3.50, Appendix 12 of the Development Strategy Topic Paper). The rents and room style are consequently within the direct control of the institution. Whilst independent operators will align themselves with an institution, this is ultimately in a competitive environment and so there is inevitably more compromise on rents and the quality of the offering i.e. independent operators will be seeking to maximise value as opposed to student affordability.

Having said that, ARU is also committed to ensuring choice for students and that includes adequate and crucially, affordable, student accommodation. The draft policy assumes 800 additional bed spaces for ARU up to 2033/34 (i.e. not even the full plan period) but fails to recognise this quantum was identified by ARU as required up to 2025/26. This figure consequently does not address their need over the plan period. Based on ARU’s latest evidence and student projections, a 19% increase in student numbers is calculated across the plan period 2024-2045. This applies annual predications up to year 2029/30 before then transitioning to a 5 year % assumption up to year 2044/45.

It is agreed that there may well be downturns within the plan period given the volatility of the market, competition and rapidly changing national and global policies that can impact on higher education. However, the figures supplied rely on medium term projections and thus seek to provide the most reasonable and sound approach in this volatile context. On that basis, if one takes 2024/25 as the base year, student figures could rise to 15,165 students by 2044/45. If one assumes the % living in Cambridge remains the same as the latest evidence (70%), it would mean 10,616 ARU students living in Cambridge. This is an uplift of 1,695 students compared to 2024/25. Therefore, if the plan is simply to address growth only, then the Plan must provide for a minimum of 1,695 additional bed spaces.

On this basis, it is crucial that the local authority reviews the additional bedspace figure they have utilised in this version of the draft Plan. The figure used does not reflect latest circumstances or evidence, which ARU now supply.

It is noted that the latest Cambridge Development Framework for the University shows the potential to deliver circa. 388 bed spaces at Severn Place and Mackays. This is consequently a beneficial opportunity (subject to policy H/AH and J/FD wording updates to support said growth) but is not sufficient in itself if the plan does seek to address projected growth.

ARU supports this policy and development opportunities at the Grafton Centre. This includes improvements to public realm and connectivity, which will ultimately improve the student experience along East Road.

ARU particularly supports the specific reference to the site being suitable for uses associated with ARU’s East Road campus. Such phrasing helps ensure that the Local Plan acknowledges that the campus of ARU has transitioned to an ‘East Road campus’ as opposed to simply focusing on the original site fronted by Helmore. This broader campus approach has become well established through planning consents over the past 15 years, as well as various iterations of the Cambridge masterplan/Development Framework. A plan marking the landholdings of ARU along East Road is attached to these representations for the sake of clarity and to illustrate this point. In light of this ownership and the proximity to the Grafton Centre, it is evident that it would be an opportune area for further ARU based development, reinforcing this perception of an East Road campus and interconnectivity across the multiple hubs.

The benefits of redevelopment and opportunities to enhance the Eastern Gate are well established and ARU does not contest such points. ARU agrees that the locality is an opportunity for visual improvement and remains dominated by vehicular traffic. The general principles to rectify this point are supported with improved public realm and connectivity among others.

However, there is one point of concern within this policy, specifically ‘Studies will also be required to justify proposed land uses floorspaces and their redevelopment on a proposal-by-proposal basis’. This is a somewhat ‘anti-development’ approach, albeit likely inadvertent. It would be constructive if the policy cross referenced that such justification is not required where there is separate policy support for stated uses (such as draft policy J/FD).

As supporting text to draft policy J/FD states, ‘ARU’s East Road campus and the wider area along East Road both remain the most sustainable locations for ARU during the next plan period and the policy supports this approach’.

It is also reiterated that the benefits of development opportunities should be acknowledged within the policy. As the policy identifies, the area would benefit from notable improvements to movement and public realm. New development is a primary facilitator for delivering such aspirations for place making. In such a context, it is considered the policy should be rephrased to be more positive towards development.

It is considered that the boundary of the Mill Road Conservation Area warrants review. As the Conservation Area Appraisal (2011) notes ‘Anglia Ruskin University provides a variety of modern buildings, mostly of no special merit, which butt up to the western boundary of the cemetery’. ARU considers this is a fair assessment and do not consider the inclusion of the southernmost buildings on their original East Road site within the Conservation Area designation are warranted.

The Conservation Area includes notable buildings of no special value, such as the Coslett and Swinhoe Buildings. It is noted that the Ruskin Building is deemed a Building of Local Interest. However, the wider perception and context of this building surrounded by Swinhoe and Coslett mean the overall broader site context is not worthy of designation. The Ruskin Building should instead be considered as a Building of Local Interest in the context of the adjacent Conservation Area. Revising the boundary would provide a more proportionate and accurate depiction of the heritage status at this locality. Ultimately, the University should be considered an institution adjacent to a Conservation Area as opposed to warranting inclusion within it. It is therefore suggested that review of this Conservation Area boundary as part of this new Local Plan production would appear rational.

The intent behind this policy is acknowledged and the benefits associated with additional tree cover are not disputed. However, this must be considered in the context of Cambridge City as a highly competitive environment, constrained by Green Belt and multiple other features such as valued heritage and the river. These can equally be considered as assets but naturally create a planning environment filled with notable restrictions, compounded by the competing uses and development pressures facing the City.

In that context, it seems inevitable that multiple sites would need to rely on criteria 2 within the draft policy. It therefore appears somewhat counterintuitive and unduly onerous to expect applicants to have to supply evidence with each major application as to why the 30% requirement cannot be achieved within the City. It places undue burden both in terms of cost and risk. Furthermore, there is already a separate BNG requirement which will lead to increased ecological enhancements with tree planting forming a component of that uplift.

Given that ‘Valuing the Urban Forest of Cambridge’ technical report (2020-2021) found that Cambridge tree canopy covers about 20.1% of the city, this in itself should be considered a positive attribute aided by the proportion of open space serving the City. This aligns with the Urban Forestry & Woodland Advisory Committee recommendation that a target of at least 20% overall tree canopy cover for a local authority area should be accommodated. Whilst this is a minimum target, to increase this target by a further 50% fails to reflect the Cambridge specific context. It is instead considered the policy should identify support for protection (or where appropriate) replacement of existing trees to ensure the existing percentages are not adversely impacted. Future tree canopy increases can then become apparent through the more recent BNG criteria. This approach is considered more proportionate, realistic and to create a more sustainable balance between the competing pressures on sites within Cambridge. This also avoids the burden of producing unnecessary evidence or justification as part of planning applications. These representations focus specifically on Cambridge City and it is possible a policy distinction between the City and area beyond is appropriate in this instance.

It is also suggested that greater clarity is required in the wording on ancient woodland buffers. Point 7 of the draft policy suggests a buffer of at least 15m but then states ‘the size and type of buffer zone will vary…’ and that a buffer should apply to all tree groups. It is unclear why a minimum of 15m from the development boundary is required. This is unclear as it would be illogical to apply to the red line development boundary should no development take place in proximity to the trees. It is suggested that the policy could be simplified so that suitable buffer zones from built development are secured for all retained trees, proportionate to their status.