Draft Greater Cambridge Local Plan for consultation

strongly support the protection of non-designated heritage assets.

The policy lacks a clear sequential approach to retrofitting historic buildings. Without a requirement to prioritise less harmful measures first, such as improved insulation, there is a risk of unnecessary harm to heritage assets through more intrusive options like solar panel installations. The plan should explicitly reference standard BS EN 16883, which provides a structured sequential process for energy upgrades in heritage settings. This is seen as a necessary addition because the current reference to PAS 2035 is insufficient for protecting the unique significance of historic fabric.

Support the protection of historic shopfronts

The supporting information should state that Cambridge’s traditional market possesses a unique historical legacy, having served as a vital community hub since before the founding of the University. The daily and Sunday stalls providing fresh food and produce represent a living connection to the city's medieval heritage and its enduring relationship with the surrounding agricultural landscape, as well as a sustainable low carbon economy.

The Plan needs to evaluate the capacities of key areas within the city centre to accommodate visitors
The Plan should make provision for the soft and hard infrastructure to meet visitor’s needs and a strategy for guiding them to suitable (less conflictual) parts of the centre.
The Policy must ensure that visitor accommodation on science parks is not be at the expense of land needed for science based development.

We are concerned with the quantum of visitors and their impact on central areas of the City which are impacted both by the visitors and, particularly for day visitors, the vehicles by which many of them arrive.
Central areas of the city are already unpleasantly congested and the projected population growth in the study area will increase current pressures, even if the ambition to achieve high levels of containment in new settlements is, eventually, achieved. Unrestrained numbers of tourist visitors (we did not find a forecast of day visitor numbers in the documentation) will further exacerbate the problem.

The Plan needs to evaluate the capacities of key areas within the city centre to accommodate visitors, whether local residents or tourists, (a) safely and (b) pleasantly – as seen both for themselves and other users of the centre. A determination can then be made, based on relative costs and benefits associated with different users, as to the quantum of tourism for which the Plan should plan and make provision.

The Plan’s development strategy for Jobs is to: “Encourage a flourishing, dynamic and mixed economy in which includes a wide range of jobs, while maintaining our area's global reputation for education, research and innovation.” A crucial factor in maintaining this global reputation is ensuring it is an attractive place in which to live, from all its aspects, not least for internationally mobile workers and their families. Tourism should be viewed through that lens.

When estimates have been made of the desired numbers of both day visitors and those staying longer, the Plan should make provision for the soft and hard infrastructure to meet their needs and a strategy for guiding them to suitable (less conflictual) parts of the centre. The money to pay for this and for curating the city centre (information, signage, street cleaning, pavement maintenance etc.) might be sought from a form of tourist tax(es), which should include a modest charge on group tours if possible.

The policy supports visitor accommodation in mixed use development such as Cambridge Biomedical Campus, Science Park and West Cambridge. We support this policy because it has the benefit of discouraging the conversion of houses into short-term lets in surrounding neighbourhoods (some of which are negatively affecting the appearance and character of those neighbourhoods). However, it is important that visitor accommodation on science parks minimises the use of land for this purpose, to ensure adequate provision for science based development and we would like to see the policy or supporting text reflect this.

We find the wording surprising in that it indicates that Faculty Development, and the development of language schools and specialist colleges will be "supported" whereas University developments will be "permitted". What is the basis for this difference?
In respect of language schools, point (b) needs to be clear as to whether this also only applies to non-local students. Unlike University developments, nothing is mentioned about the location of language schools. We suggest that if a large language school were to be sited in or near to a residential area, there could be significant conflict from a large hostel with noisy youngsters. The policy needs to be worded so as anticipate that eventuality.

The policy must
Require developers to propose all interventions that can realistically shift a significant number of development-generated trips from solo-occupancy car trips to other modes (say, at least 1%) and that are proportionate in cost before proposing interventions to increase road or junction capacity for general motor traffic.

Expand the scope of this requirement where appropriate to include mode-shifting existing and background growth in trips on roads impacted by the development. The objective here is to free up road capacity to absorb some or all of the residual motor vehicle trips generated by the development after all sustainable transport interventions have been taken into account. This forms the basis of the trip budget mechanism, discussed in the next section.

Cite a specific framework governing street design principles, such as the Healthy Streets Indicators. (1)

Define or exemplify what constitutes an appropriate “vision”, “unacceptable” impacts, and “adequate” mitigation.

Define what “high quality” means in different contexts, either within the Local Plan or by reference to other policy documents. For instance, dwellings in an urban area should be within 400m walking distance of at least one bus stop served by an all-week service, operating at least hourly from 6am to 11pm on weekdays, and at least half-hourly at peak times.

Strengthen the “should” in the final sentence of §3 to “must”.

(1)https://www.healthystreets.com/what-is-healthy-streets

Policy Language
This policy largely restates NPPF policies and is generally sound. However, it relies heavily on statuses that are undefined, unquantified and ultimately subjective: “principles of walkable Neighbourhoods”, “high quality public transport”, “high-quality new cycle, wheeling, walking and, where appropriate, equestrian routes”, “improvement of existing walking, wheeling and cycle routes”, “unacceptable transport and highways safety impact”, “adequate provision to mitigate the likely impacts”, “a vision-led Transport Assessment and Travel Plan”

Delivery Timelines and Policy Strength
The final sentence of §3 gives developers unwarranted flexibility to avoid pre-occupation provision of transport infrastructure and services: “Such measures should be provided to meet the first or early occupation of a site in order to influence travel behaviour from the outset.” There is already wriggle room in the inclusion of “early occupation”, so it need NOT be further attenuated by using “should” rather than “must”.

Prioritising Sustainable Travel over Road Capacity
Although there is a direction to developers “to demonstrate they have maximised opportunities for sustainable travel,” it is not made explicit that these take precedence over interventions to increase road or junction capacity for general traffic, rather than being additional. It cannot be assumed that developers will interpret “vision-led” in the way intended.

Offsetting Impacts via Mode-Shifting and CIL Compliance
There is no acknowledgment that a development can offset its own transport impacts by mode-shifting some existing and background trips to free up road capacity. However, this may be difficult to justify in planning terms because any interventions to mode-shift trips not directly related to the development do not comply strictly with CIL Regulation 122 (b): “directly related to the development”. Nevertheless, it is accepted that developments must mitigate cumulative impacts, which are also not strictly compliant with that test. From the developer’s perspective, if an investment in mode-shifting existing trips reduces the investment required in road and junction capacity upgrades, it should see either as an acceptable route to mitigating the transport impact of development.

We recommend the policy is amended to
Set out a framework mechanism, in line with draft NPPF Policy HO3 §3(b), for calculating trip budgets, identifying mitigations that cover a reasonable range of scenarios, monitoring trip generation (excluding any through-traffic), and enforcing trip budgets through planning conditions and obligations.
Explain in what circumstances increasing road or junction capacity is an acceptable mitigation, rather than expanding or enhancing provision for sustainable transport modes.
Ensure that this mechanism is legally sound and capable of dealing with wide ranges of uncertainty over long build-out periods.
Is there a role for financial penalties in the event of trip budgets not being met, even once all S106 mitigations have been implemented?

Trip budgets (Policy I/ST and site-specific policies)
§10.13 of the supporting information for Policy I/ST states, “there will likely need to be a vehicular trip budget applied to mitigate the transport impacts of the strategic site allocations”, but this is not part of the policy.

Trip budgets are quantified in site-specific policies, or a mechanism for quantifying them is. However, an explanation of how trip budgets will be enforced is provided only for Policy S/NEC (North East Cambridge), and there the policy only asserts without any details, “Conditions or Planning Obligations will ensure any breaches are corrected or restricted to bring trips back in line with the applicable trip budget.”

The IDP refers to a “range of technological measures to allow access to and from the Campus to be monitored, managed and enforced” (Table 5-4, page 52) at each of the eight strategic development sites in the draft Local Plan.

There are no powers in the Traffic Management Act 2004 or Road Traffic Regulation Act 1984 that could be used to enforce trip budgets (directly), so enforcement would be entirely a planning matter. The role of technology would be to monitor traffic trip rates, but not to limit them or enforce exceedances.

A planning condition may prevent or delay later phases of development if the evidence of exceeding a trip budget is clear and, in the case of an appeal against the condition, the Planning Inspectorate agrees that the Trip Budget condition meets the prevailing tests. If this mechanism is to be relied upon, the Local Plan should set out how the mechanism will work and why it is legally sound.

Planning obligations may include in-reserve mitigations to be delivered only if a trip budget is, or is likely to be, exceeded. However, these mitigations must be identified and agreed with the applicant up-front. They must also comply with CIL Regulation 122. The statutory tests are assessed based on evidence available at the time of agreeing the obligations, and do not explicitly allow for the consideration of uncertainties that may arise in the future. This limits the range of mitigations that are likely to be considered compliant, in particular with respect to being “reasonably related in scale and kind to the development.” If, once all the agreed mitigations have been implemented, the trip budget is still exceeded, the Planning Authority has no powers to demand further mitigations.

We recommend the policy is amened to
Use the term Travel/Mobility Hub consistently.
Prescribe maximum and recommended numbers of parking spaces at Travel/Mobility Hubs, based on objectively determined need rather than forecast demand.
Acknowledge the need to charge for parking in locations where more sustainable and space-efficient travel options are available, ensuring that usage is matched to need rather than demand.
Define Sustainable Modes of Transport to include only modes that also make efficient use of public highway (i.e. not private electric cars).

There is inconsistent use of the terms “mobility hub” and “travel hub”: for instance, the policy is about travel hubs, but the definition is of “Mobility (travel) hubs”. Smarter Cambridge Transport coined the term “travel hub” to convey the sense that, from the perspective of a traveller, it is a node on a journey, rather than a destination. The term “mobility hub” is promoted by CoMoUK, and is more widely used, but to a lay audience it suggests that its purpose is connected to disability (think “mobility scooter”, “mobility aids” or “limited mobility”). For clarity and consistency, the preferred term is probably “Travel (mobility) hub”.

Paragraph 2(c) of Policy I/ST is a good definition of a mobility/travel hub. It should, however, be more explicit that it does not include traditional Park & Rides, which are designed and primarily used for interchanging between private car and another mode (bus, cycling or walking). Their contribution to modal shift is limited; they are an inefficient use of land, most in the green belt; they are carbon-intensive to construct and contribute little to decarbonising transport.

a) The number of ‘last-mile’ legs that can be mode-shifted is capped by the number of parking spaces. In the context, for instance, of 72,016 daily trips to the Cambridge Biomedical Campus in 2050 (CBC Transport Strategy Table 7), a 2,000-space car park at the A11, occupying 20 hectares, can accommodate only around 3.3% of all trips to the Campus (assuming an average of 1.2 people per car).
b) Many people drive out of their way to use a P&R, adding miles to the driven part of the journey, increasing total carbon emissions and localised congestion.

The quantity of parking provided at a Travel Hub should match an assessed need, rather than likely demand. The assessment would seek to identify which dwellings are within the catchment area, the quality of the active travel infrastructure and bus services between those dwellings and the Travel Hub.

Demand is likely to exceed a level of provision based on need, so an appropriate level of parking charges should be levied to manage demand and ensure those who need a parking space are able to get one.

The definition of a travel hub provided on page 718 confuses transport users with modes. A suggested definition is as follows:
Travel (Mobility) hub
“A dedicated space that facilitates interchange between Sustainable Modes of Transport. If the main inbound mode of travel is car it is a Park & Ride rather than a Travel Hub. Essential facilities include secure cycle parking, bus stops with shelters and seating, real-time information displays, and free Wi-Fi. Depending on the scale of the Travel Hub, other facilities may include a climate-controlled waiting room, public toilets, a Changing Places toilet, kiosk, café, parcel lockers, cycle/scooter hire station, club car bays, taxi rank, private car drop-off/pick-up bays, Blue Badge parking bays, general parking bays, and public EV charge points.”

The definition of Sustainable Modes of Transport is copied from the NPPF, which unhelpfully brackets electric cars, including hybrids, with cycles and buses. It also mentions car-sharing, though there is no definition of this or any clear justification why a car carrying two work colleagues is more sustainable than a car carrying four family members. It may therefore be sensible to redefine Sustainable Modes of Transport or create and define a new term. It may also be useful to have a definition that covers multi-occupancy vehicles, as some policies should prioritise provision or access to these.

Sustainable Modes of Transport or Sustainable and Efficient Modes of Transport
“Walking, wheeling, cycling, bus, tram and train.”

High Occupancy Vehicle
“A private vehicle carrying at least two people including the driver, or a taxi carrying at least two people excluding the driver.”

CPPF strongly supports the use of CiL to enable the delivery of the green and blue infrastructure policies in the Plan.

CPPF welcomes recognition in the supporting text (para 1) of the need to provide parks, open spaces and land for biodiversity. Whilst we note that the text makes clear the list is not exhaustive, we feel it would be advisable to explicitly include ‘strategic green infrastructure’ or ‘natural greenspaces’ to support the biodiversity and green infrastructure policies.

We note that work on Green Infrastructure and Public Open Spaces is ongoing, once that is finalised and changes in standards, etc must be copied across into the relevant section of the IDP. There are inconsistencies across the various Green Infrastructure documents (Green Infrastructure Emerging Strategy, Standards & Evidence Reports, the Infrastructure Delivery Plan and the Draft Planning Obligations SPD) regarding the costs of providing strategic green infrastructure. We share the concerns of the Wildlife Trust, that in some instances these are too low, e.g. the Planning Obligations SPD quotes a price for agricultural land as £20k per hectare, when our own experience is that this can be £25-30K/ Ha in the Cambridge area. Likewise, the quoted capital costs while appropriate for many types of habitat creation, do not cover provision of surfaced paths or other such facilities where these may be required. It is essential that the GI policies and Infrastructure policies, including the final Planning Obligations SPD are consistent and secure sufficient financial contributions from all new development to meet the strategic natural greenspace needs of the area.

The current iteration of the Infrastructure Development Plan (IDP) has used the Fields in Trust standards whilst a bespoke standard is being worked on. We share the concerns of the Wildlife Trust that the FiT standards may not be appropriate or adequate for our area.

The IDP Table 17.2 lists a suite of strategic green infrastructure projects, that if delivered would contribute towards sustainable development and nature recovery. CPPF strongly supports inclusion of the initiatives identified in table 17.2 within the IDP. These must be delivered which will require sufficient financial contributions secured from new developments.