Draft Greater Cambridge Local Plan for consultation

CPPF supports the climate-led vision approach to the Local Plan. However, as well as recognising the internationally significant economy, the vision must also recognise the internationally valued heritage and landscapes of Greater Cambridge. The vision should also recognise that there are potential conflicts between economic growth and the climate, physical and environmental capacity of the area. The vision should be to explicitly manage and mitigate these conflicting aspirations.

The Local Plan must shift from a growth-led strategy to a resource-constrained model. This requires the plan to stop treating employment projections as inevitable targets and instead treat the region's environmental limits—specifically the depletion of the chalk aquifer—as the primary cap on development. By implementing "Grampian" conditions, the council could legally tie the commencement of new housing phases to the actual completion of the Fens Reservoir and the Grafham pipeline, ensuring that growth does not outpace the arrival of sustainable water supplies.

Furthermore, the plan needs to move beyond "siloed" planning by aligning more closely with neighbouring districts like West Suffolk and East Cambridgeshire. Instead of simply allocating more land within Greater Cambridge, the strategy should focus on a regional distribution of housing that matches where people can actually afford to live.

Object: The Plan mentions that, in deriving the employment projections and in translating these to housing requirements, there are multiple uncertainties. Some of these are inevitable and we recognise that significant margins of error are unavoidable. However, insufficient attention appears to have been given to the aspirations and plans of neighbouring Districts when estimating commuting flows despite their significant impact on housing need estimates.

One of the challenges for the Cambridge area is high house prices. Prospective buyers cannot afford the type of property they want, and they are choosing to live distant to Cambridge and commute (from places like Bury St Edmunds, Soham, etc). This results in a greater proportion of people commuting long distance and is one of the reasons that despite the current Local Plan allocating significant land for housing, that large sites are not being built out quickly, despite high latent demand. It is unclear how allocating even more land for development overcomes this problem. It also creates the risk that there is an over-allocation for Greater Cambridge and under allocations in neighbouring areas.

CPPF is extremely concerned regarding the scale of growth placing further unsustainable demands on water resources to the detriment of our already depleted chalk aquifer and degraded chalk streams, which are in a poor ecological condition. The proposed Fens Reservoir will not be completed until the late 2030s and the proposed pipeline from Grafham won’t be in place until 2032. In the meantime, our chalk streams will not be able to recover (in spite of proposed massive investment through water companies funding) without sufficient supplies of good quality water. It is likely that the Cambridge Water abstraction from the chalk aquifer would have to reduce by half to recover near natural flows. However, the scale of proposed housing and jobs included in the draft Local Plan will only exacerbate the problem without radical and faster solutions, none of which are in place or proposed to support this plan. Therefore, we believe, that the proposed growth will result in the continued poor condition of chalk streams, rather than enabling them to recover.

Comment: While CPPF generally support the focus on a small number of settlements beyond the Green Belt that are of a sufficient size to enable a significant level of self-sufficiency, we wish to highlight several strategic risks and requirements necessary to ensure this growth is sustainable and well-governed.

Governance and Strategic Risks
We strongly believe that local authorities must maintain democratic control over the planning process. The vision for Greater Cambridge should not be lost to or superseded by the Cambridge Growth Company.
The Local Plan development strategy is predicated on future development of a transport strategy by the combined authority CPCA. The CPCA is also now responsible for the production of a Sustainable Development Strategy for Greater Cambridge. Both of these components will have significant influence on content of the new Local Plan and on its delivery, and these implications need to be explicitly set out and accounted for. The absence of a clear transport strategy prepared at the same time as the emerging local plan is a major weakness of the development strategy. Policy S/DS must ensure that the scale of growth remains strictly tethered to the delivery of necessary infrastructure.
The complexity of the above as well as a designated Growth Company in the mix increases the risk of ambiguity and potential for flaws in the delivery of a coherent development strategy for Greater Cambridge.

This applies equally to Sustainable Development. The draft Plan assumes, with no evidence whatever, that the built form, streets, public realm and historic spaces of our historic market town / university city and its hinterland can accommodate the levels of growth, population and traffic being proposed.
These physical capacity issues apply across the whole city and its hinterland, in terms of transport links vs landscape, tall buildings etc.
Claims that proposed levels of “Sustainable economic growth” are truly sustainable are groundless, in the absence of serious analysis of Cambridge and its hinterland’s capacity to withstand / accommodate this growth.

Reliance on East West Rail (EWR) and Railway-Led Development
The current strategy exhibits an overdependence on Cambourne North, which is fundamentally reliant on the timely provision of East West Rail. Any delay in the EWR project will directly compromise the delivery of this housing and employment cluster.
Consequently, the strategy must take better account of the government’s presumption in favour of development at existing railway stations. It is inevitable that growth will gravitate toward these travel hubs; therefore, the Local Plan should provide proactive policies to shape this development now, rather than reacting to it later. Bringing forward appropriately scaled developments at some stations could reduce the risks associated with a delay for EWR (in other words, reduce the allocation at North Cambourne (for the plan period) and offset that with station developments). We note that there may be opportunities for station-based development (meeting the governments proposed criteria) at: Foxton, Shepreth Meldreth, and Ashwell & Morden. Such developments would align with the development strategy of directing development to transport corridors. They also have the benefit of existing transport infrastructure and are therefore not at risk of being delayed. Additionally, the developers would not be required to fund new public transport infrastructure, potentially freeing up funds to contribute towards improving community facilities in the villages or providing more affordable housing.

Strategic Infrastructure and orbital route.
A coherent development strategy for growth at the scale which is proposed, must address the long-term capacity of the strategic road network. We recommend that Policy S/DS explicitly references the need to create a functional ring road around Cambridge. This should include adding connections at the following interchanges to create all-ways junctions:
• Girton Interchange (Junction 31/14, A14/A428)
• A14/A11 Interchange
• Junction 9, M11
Collectively these junction improvements would enable traffic to better circulate around Cambridge. As well as increasing connectivity, it would reduce the amount of traffic that is currently using local roads and passing through villages, thereby significantly improving road safety and quality of life. It would also have the advantage of providing better diversions in the event of road closures on the strategic road network, meaning less delays and better productivity.

The Cambourne Cluster and New Settlements
CPPF supports the policy of locating large new settlements beyond the Green Belt to protect the Green Belt, the setting of the historic city, to avoid coalescence with villages and help ensure that Cambridge remains a compact, human-scale city with limited unused land. However, for new settlements to be successful, they must be of a scale and design that fosters a degree of self-sufficiency in employment, schools, retail, health, leisure and community facilities to avoid becoming ‘suburbs in the countryside’. There is also a requirement to ensure good public transport and active travel (ideally where such infrastructure is already in place, or where it can be provided without conflicting with other planning policies, such as those that seek to protect landscape, ecology and heritage).

The Cambourne cluster is a logical priority for expansion to achieve this self-sufficiency, based on the delivery of East West Rail. However, as noted in our representation on Policy S/CBN, an urgent and comprehensive masterplan is required to unify the existing piecemeal development into a coherent settlement with a defined centre, which include imaginative ways to link development north and south of the A428 so that the road does not become a barrier to close integration.

Regional Context and Employment-Led Growth
As an employment-led plan, the scale of growth is dictated by commercial demand. This strategy must, therefore, look beyond the immediate district boundaries and account for the aspirations and growth of surrounding market towns, such as Royston, Newmarket, Ely, Haverhill, and Saffron Walden.
Looking beyond the current plan period, the eastward progression of EWR toward Ipswich and Felixstowe presents significant future growth potential. We note, for instance, proposals such as "Forest City" between Haverhill and Newmarket, which demonstrate the need for a long-term, cross-boundary perspective on how employment and housing will shift across the region.

Small Sites
CPPF support the Plan’s approach to the requirement to deliver a proportion of housing on small sites. CPPF supports a strategy which will deliver sustainable development.

CPPF support the settlement hierarchy.

The policy would benefit from supporting information on how to interpret local character. Does it mean density, form, materials, open spaces? How is new development which would equally contribute to the local character dealt with?

CPPF strongly supports this policy and the Green Belt purposes a-c.

It is important for the Green Belt Assessment to be updated. An up-to-date Assessment is needed to provide a qualitative assessment of the purposes and functions of the Cambridge Green Belt, and given the current pressures and contexts, demonstrate its relevance to the setting of the historic city. The lack of an up-to-date Green Belt Assessment will undermine the plan.

A strategic plan is needed to accommodate increased commuting demand, especially with East West Rail focusing on the Biomedical Campus rather than North East Cambridge.

There is a practical need for a new road crossing into Chesterton Fen, proposing a bridge over the railway and replacing the Fen Road level crossing with an active travel underpass.

If the Hartree Development proceeds, a significant contribution to off-site strategic green infrastructure is essential, which the current policy does not adequately address.

The policy should specify a minimum area of Green Space and ensure development mitigates impacts on Milton Country Park and Ditton Meadows, which are at capacity. The policy must deliver Green spaces which are designed for year-round use, connected by green streets, and should not include green roofs or courtyards in the green space provision. The policy must deliver large-scale Natural spaces suitable for outdoor activities and resilient to climate change impacts and a meaningful landscape buffer is needed on the eastern boundary to soften the transition between urban areas and river/fenland.

The policy should promote diversity in building heights and orientations, considering the site's proximity to the countryside rather than urban London standards.

The policy is premised on the relocation of the Cambridge Waste Water Treatment Plant (CWWTP). Since the relocation is no longer funded, and unlikely to be viable on the basis of the quantum of housing and commercial space proposed (8,350 homes plus ~350,000 sq.m. of business and industrial space), it is unclear what purpose this policy serves. Most of the allocated housing would be within the “odour zone” of the CWWTP, which therefore requires either the relocation of the CWWTP or a new odour control system. If neither is viable, then it is likely that the landowners will seek to intensify commercial uses in place of housing. This would exacerbate the imbalance between jobs and housing in the city, increasing demand to commute into Cambridge. There is still not a sufficiently ambitious strategic plan to accommodate this, especially as East West Rail is being designed to take people to the Biomedical Campus (via Cambridge South station) and not directly to North East Cambridge

There is a practical and safety need for a new road crossing into Chesterton Fen to replace the level crossing on Fen Road. The Local Plan should include provision of a bridge over the railway line, connecting Cowley Road to Fen Road. The Fen Road level crossing should be replaced by an active travel underpass or more direct connections to the towpath either side of the railway line.

If the Hartree Development were to proceed then CPPF believes that due to the density of the proposed development it will be essential for there to be a significant contribution to off-site strategic green infrastructure north and east of Cambridge. The current policy wording fails to acknowledge the need for this or set out a policy mechanism for the NE Cambridge site to contribute to meeting the GI needs of the new population.

The policy should specify a minimum area of Green Space to be provided. The policy must ensure that development mitigates the impact of increased population on Milton Country Park (which is already at capacity) and Ditton Meadows.

Green space should be useable spaces designed for year-round use and connected across the development by green streets. Green roofs and courtyards must not count towards green space provision. Green spaces must include natural spaces which are large scale natural environments suitable for long walks, runs, escaping urban pressures. Greenspaces must be resilient to changing climate (Impact of hot dry summers on Green roofs and wet winters on SuDS).
The policy needs to require a meaningful landscape buffer on the eastern boundary to soften the transition between urban and river/fenland.
The policy should ensure a diversity of building heights and orientations, with varied roof forms and the elegant integration of rooftop plant, that take into consideration that the site is adjacent to the countryside (not London, which many of the developers seem to use as their basis for height and design).

Suggest amendment to Part 2a of the policy replacing "make the development acceptable" with "achieve an outstanding standard of development" . Supporting information to be similarly amended.

A proportion of the new housing should be identified as key worker (above and beyond the affordable housing requirements) and linked to North Cambridge Academy staff needs. This allocation is from former playing field land, and the academy should benefit more from the allocation. The new facilities and the community use agreement should be in place before occupation of the first dwelling.

This policy is tentative about an eastern access to the station (“any possible future new eastern entrance”). An eastern entrance is essential for the continued safe functioning of the station and to open up opportunities to reconfigure the main station forecourt.
Figure 39 is inaccurate and too schematic to be helpful in shaping future development. This policy should set out principle and parameters for the components required for an eastern entrance to the station, including detail on pedestrian routes, cycle parking, a taxi rank, bus stops, and traffic management on Clifton Road, Rustat Road, Davy Road and Fanshawe Road.