Draft Greater Cambridge Local Plan for consultation

1.a should be amended to read: “there is a local need or demand for the facility […]”, as there may be, e.g., no health need for a football pitch if there are already tennis courts, but there may well be high demand for both.
In 1.f, “where appropriate” should be amended to “where possible.” This makes clear that developments including spaces open to the wider community are to be prioritised in planning. It also brings 1.f in line with the same “where possible” language in 2.d.

We welcome this policy’s recognition of the value of cultural infrastructure and its promotion of affordable creative workspaces. We recommend amending 2.a to read “the proposed cultural/creative hub will provide and support most or all of the criteria listed in paragraph 1 above […]”.
With reference to S/PRIA/EG and the Elizabeth Way bridge and Underpass(es) Community-led cultural hub project: we support proposals that seek out new uses for the as-found spaces within and surrounding the bridge and underpasses, including adjacent public realm leftover spaces. We support implementing new uses including affordable community and youth facilities, arts and cultural provisions, indoors and outdoors sports and recreational provisions, and commercial, business and services including food and beverage provisions and outdoors markets. It is expected that cultural activities will encourage Learning and Networking as well as Employment.

We welcome this policy’s encouragement of the efficient use of existing buildings and land. To further strengthen this encouragement, we recommend amending “where appropriate” in point 2 to “where possible.” This more clearly prioritises the accommodation of meanwhile uses.
Point 3 contains a typo: “meanwhiles” should be “meanwhile”.
In the supporting information, we recommend adding a sentence immediately after the first paragraph to state “Meanwhile uses can be applied to any temporarily vacant property, whether commercial or residential, as well as to vacant land.” This encourages the efficient use of all types of buildings and land.

We applaud this policy’s intention to address the poverty and skills gap in Greater Cambridge and to support community wealth building. To better support these aims, we recommend amending 3.c to read: “How these opportunities will be made available and actively communicated to local residents […]” so that the onus is on the developer to make residents aware of new business, employment and training opportunities. This will help to ensure that jobs and training created by development genuinely benefit the local community.

In this policy’s stated aim, “odour, and/or light pollution” should be amended to “odour, soil, air, water, and/or light pollution” and “suitable for the end use” should be amended to “suitable for both the construction process and the end use.” These make the aim more comprehensive.
We recommend adding a new criterion 4.e to state “proposed development will not lead to excessive noise and/or vibration pollution during the development process” to address the risk of pollution during the construction process.
The section “contaminated land” should be re-titled “contaminated land and water,” as 10b discusses impacts on controlled waters.

We welcome this policy’s recognition of public houses as community infrastructure rather than just commercial assets. However, in point 1, “need for the public house” should be amended to “need or significant demand for the public house.” In cases where one public house is available but of a character unsuitable for some residents’ usage, there is no community-wide need for an additional public house, but there may be significant demand from those residents who are under- or un-served by the existing provision.

The ‘Great Places’ theme should include more concrete references to involving local people and communities in decision-making, as people are central to creating great places. References to building materials should specifically require that the materials be sustainable. Provisions for enhancing and protecting biodiversity must be strengthened, as set out in our comments on the specific policies in this theme and the ‘Biodiversity and Green Spaces’ theme. Research shows that to fully benefit from biodiversity, at least 20% of land area (including urban spaces) must be maintained as semi-natural habitat. (https://doi.org/10.1016/j.oneear.2023.12.008 ) Furthermore, urban green spaces are crucial for cooling local temperatures. (https://theconversation.com/climate-change-is-making-cities-hotter-heres-how-planting-trees-can-help-26782)
Finally, we recommend adding a new policy ‘GP/TS Tree-lined streets’. A suggested text for this policy is below:
“1. New streets or new sections of streets must be tree-lined on both sides unless it can be demonstrated that site-specific constraints make this impracticable. This applies to new streets or sections of streets within an application site (whether intended for adoption or private management) and to streets delivered through associated off-site highway works required to serve the development.
2. Street tree provision should be considered from the earliest design stage, taking into account spatial constraints, both above ground and below surface level, including SuDS design and surface water management, street cross-sections, building set-backs, utilities, and drainage layout together with the need to minimise unacceptable impacts on accessibility, services, and highway safety.
3. Applications within scope must include a street tree plan that demonstrates that trees will have sufficient space and appropriate growing conditions to reach healthy maturity, so that their amenity, biodiversity, and climate benefits increase over time. In assessing required growing conditions, consideration should be given to climate change and the provision of adequate water, soil or growing media volume, and protection of the rooting environment from compaction.
4. Development proposals that remodel, realign, or substantially reconfigure existing streets must retain and protect existing street trees and, where possible, ensure that remodelled streets are tree-lined on both sides.
5. Long-term management, maintenance, and replacement of street trees must be secured through appropriate planning obligations, including clear responsibilities and funding where trees are not adopted by the highway authority.
Supporting information:
Street trees are an important part of creating high quality streets and public realm. They help to define the character of streets, provide enclosure and human scale, and contribute to attractive views along routes. Tree-lined streets can make walking, wheeling, and cycling more pleasant and comfortable, help to calm traffic, and support social interaction by providing shading, shelter, and enjoyable places to pause.
Street trees also play a significant role in responding to the climate emergency. Over time, a well-managed street tree population can make a meaningful contribution to carbon sequestration and mitigating climate change. Tree canopies provide shade and cooling through evapotranspiration, reducing the urban heat island effect and helping to maintain comfortable conditions in streets and public spaces during hotter summers. To ensure that these benefits are sustained over the lifetime of the development, species and cultivar choices, planting design and soil provision need to reflect projected changes in climate, including hotter, drier summers and more intense rainfall events.
Integrating street trees with sustainable drainage forms part of a wider move towards more nature-based approaches to managing water. Tree pits, verges, and rain gardens can collect, store, and treat surface water while also improving water quality. When designed together with SuDS and surface-water drainage, street trees can be integrated into a multi-functional network of green and blue spaces that manages runoff close to source and contributes to biodiversity, visual amenity, and climate resilience.
The long-term value of street trees depends on trees being able to reach healthy maturity and on appropriate arrangements for their care. This policy therefore expects proposals to demonstrate that trees will have adequate soil or growing-media volumes, adequate to water, and protection from compaction and other damage. The policy also requires that responsibilities and funding for management, maintenance, and replacement over time are provided for through planning obligations. Taken together, these requirements are intended to ensure that street trees are planned, delivered, and maintained as durable green infrastructure assets that support local character, climate adaptation and mitigation, biodiversity, and health and wellbeing.”

In 1.a.iv, “inform design decisions” should be amended to “inform and shape design decisions,” so that community engagement genuinely empowers local people and has a clear influence on outcomes. Without this, engagement risks being tokenistic.
In 1.c, we recommend adding a second subclause 1.c.ii, “being designed to be adapted and resilient to the impacts of climate change, including extreme weather events.” This change is necessary to reflect scientific forecasts and ensure development responds effectively to the climate emergency. An effective response needs to go beyond mitigation and extend to adaptation and resilience.

The introductory overview paragraph should replace “designed with communities in mind” with “designed to reflect the needs and priorities of communities, as determined through robust consultation processes,” to ensure that engagement genuinely shapes outcomes.
In 2.c, “high-quality building materials” should be amended to “high-quality, sustainable building materials” to reduce environmental impacts.
2.d is too car-centric and should be amended to read “create safe open spaces and active streets, by providing highway layouts that prioritise safe spaces for people to interact and for children to play, and safe and convenient pedestrian and cycle movement. Proposals should minimise the need for car transport and any car parking should be well-integrated.”
2.i should be amended to read “Ensure the layout and design of development successfully incorporates functional needs such as: (i) waste storage and recycling facilities, designed to be secure, hygienic, and conveniently accessible without negatively impacting neighbouring amenity; and (ii) car and bicycle parking, designed to be safe, convenient, covered where appropriate and integrated into the overall layout of the site without impeding pedestrian movement.” This separates the different functional requirements of waste and recycling on the one hand from parking on the other and also explicitly addresses the potential negative impacts of car parking.
2.k should be moved to appear earlier in the design principles section (e.g., immediately after 2.a or 2.b) and “Introduce mixed-use proposals where appropriate” should be amended to “Prioritise mixed-use proposals where appropriate.” This will more strongly encourage mixed-use developments, which have significant social and economic advantages over wholly residential neighbourhoods or business parks.
In the supporting information, “bringing benefits in terms of the health and wellbeing of residents” should be amended to “bringing benefits in terms of the health and wellbeing of residents, and mitigating and adapting to climate change and supporting nature and biodiversity.”
Finally, “clear circulation routes and secure boundaries will be considered appropriate” should also be amended to “clear circulation routes and no cul-de-sac roadways will be considered appropriate.” This promotes safer and more connected neighbourhoods by reducing dead-end streets that limit circulation and passive surveillance.

In the introductory overview, “used effectively” should be revised to “used effectively and appropriately, taking into account the needs and priorities of existing local communities,” to ensure that local context is explicitly considered alongside density uplift.
In the criteria for determining appropriate density, an additional requirement should be added that proposals must demonstrate “that water can be adequately and sustainably sourced.” Given the region’s water scarcity, this wording change is essential to ensure that higher-density development remains environmentally sustainable and does not place unacceptable pressure on limited water resources.