Draft Greater Cambridge Local Plan for consultation

In 1.a, an opening sentence should be added to state that “Taller buildings can make more efficient use of natural resources, reduce energy consumption and minimise land use and construction waste. Proposals for taller buildings will be supported where…” This wording shows appropriate recognition of the environmental benefits of taller buildings.
In 1.b, “remains dominant from relevant viewpoints” should be amended to “remains dominant from all viewpoints”. The term “relevant” is undefined and risks inconsistent interpretation, creating a potential weakness in the policy. Requiring the established character of Cambridge as a city of spires and towers rising above the tree line to be preserved from all viewpoints would provide greater clarity, certainty and protection for the city centre’s distinctive skyline and historic character.
In the supporting information, we recommend amending “When submitting planning proposals for tall buildings” to “When submitting planning proposals for all buildings, including tall buildings.” In the final sentence, we recommend deleting the words “in tall buildings.” We also recommend inserting a sentence immediately before the final sentence to state “Proposals should consider suicide prevention across all building typologies, including residential dwellings as well as public spaces, recognising that most suicides occur at or near a person’s residence.” This ensures that due consideration is given to suicide prevention mechanisms across all building types.

In 1.a.ii, “provide drinking water fountains, shade and shelter” should be amended to “provide drinking water fountains, space for biodiversity and nature, shade and shelter,” to reflect the importance of biodiversity and nature for wellbeing.
In 1.b.ii, “respond to their levels of use while not allowing vehicular traffic to dominate” should be revised to “respond to their levels of use and are designed to encourage active travel and discourage car use while not allowing vehicular traffic to dominate.”
Under climate change responses, 1.c.1 should remove the reference to “historic street furniture,” which is unrelated to climate resilience.
In 1.c.ii, “enhance biodiversity using native planting” should be amended to “enhance biodiversity by ensuring at least 20% of land area is allocated to nature, and using native planting,” since evidence shows that at least a fifth of land area needs to be allocated to nature to maintain its social benefits (https://doi.org/10.1016/j.oneear.2023.12.008).
References to “high-quality and well detailed materials” in 1.d.i should specify “high-quality, sustainable and well detailed materials” to reflect the fact (already acknowledged in the supporting information) that “materials that are adaptable and sustainable will play a key role in delivering distinctive and resilient places.”
In the supporting information itself, the sentence beginning “To support well designed public realm” should be revised to read “To support well designed public realm, and in particular, to reduce the risk of surface flooding and support biodiversity, the Local Planning Authority promotes the removal of paving in front gardens.” “Permeable paving” should be amended to “permeable and natural paving” and “If you use porous materials” should be revised to “If you use natural, porous materials,” to encourage the use of natural porous materials such as gravel rather than synthetic porous materials whose production is dependent on fossil fuels and creates pollution. The text reading “or provision is made to direct run off water from the hard surface to a permeable or porous area or surface within the curtilage of the dwellinghouse” should be deleted. Given the predicted increased risk of flooding in Cambridgeshire, stronger measures are needed to improve permeability of the urban landscape.

This policy should be revised to clarify the benefits of conserving heritage assets. In 2.a, the wording should be amended to state that proposals consider the positive contribution of conserving heritage assets to “the cultural identity, wellbeing and sustainability of communities,” not just “the sustainability of communities.” This ensures the policy recognises that heritage conservation primarily supports cultural identity and community wellbeing, not just sustainability, providing a more accurate and balanced justification for protecting historic assets.
In 2.c, a final sentence should be added to state “This could include a broad range of uses, both residential and commercial, consistent with historical mixed-use patterns.” This wording recognises that many heritage assets were designed for mixed use and promotes higher-density, mixed-use development making better use of existing buildings.

We welcome this policy’s emphasis on adaptive use and regeneration of heritage buildings, which can deliver significant carbon savings. However, in 2.c, “Use high-quality materials” should be revised to “Use high-quality, sustainable materials,” encouraging more environmentally sustainable building practices.

It is crucial that sustainability is embedded into all aspects of the local plan in the light of ongoing climate breakdown. Therefore, the key strategic priority should be amended to read “Encourage a sustainable and successful mixed economy in Greater Cambridge within ecological limits which includes a wide range of jobs, while maintaining our area's global reputation for education, research and innovation.”

New employment sites being accessible by low carbon transport is essential. Where the policy currently reads “g. The site can be easily accessed on foot or cycle”, it should instead be amended to read “g. The site can be easily accessed by public transport and by foot and cycle”. This would enable employees to access the site and critically link the development to public transport networks to benefit decarbonisation of the transport network.
Under “Established employment areas in the countryside” a point should be added which states “Any further development must contribute positively to employees being able to access the site using low carbon methods of transport via planning conditions, for example to subsidise greenways or the development of improved public transport infrastructure along with the increase in employee numbers using the site.”

Replacement of buildings should be permitted if there will be an overall carbon saving, including the embodied carbon in the new development.
Instead of reading: “2. The replacement of suitably located, existing buildings for employment uses with new buildings of permanent design and construction in the countryside will be acceptable where it would bring about environmental improvement, and result in a more sustainable development”, this should read: “2. The replacement of suitably located, existing buildings for employment uses with new buildings of permanent design and construction in the countryside will be acceptable where it would bring about environmental improvement taking into account full lifespan of the prior and proposed buildings, including embodied emissions from construction and emissions during building lifespan, and result in a more sustainable development”.
Instead of reading [3c] “Developments resulting in significant numbers of employees or visitors must only be located near to larger settlements or accessible by public transport, cycling, or walking”, it should read “Developments resulting in significant numbers of employees or visitors must only be located near to larger settlements or accessible by public transport, cycling, and walking.”

Where the current policy reads “c. the loss of a small proportion of floorspace would facilitate the redevelopment and continuation of employment on the site and the proposed redevelopment will modernise buildings that are out of date and do not meet business needs,” we recommend adding at the end: “(in this scenario biodiversity net gain should be evidenced in any application)”
Instead of reading “6. Meanwhile uses that generate employment opportunities will be encouraged while the marketing of a vacant site takes place,” the policy should read “6. Meanwhile uses that generate employment opportunities, community benefit, increased biodiversity or food sustainability will be encouraged while the marketing of a vacant site takes place.”

We recommend adding a new policy point: “7. Affordable workspace within a development should not be inferior in terms of location, exposure to noise or other pollution, facilities, light availability, bicycle and vehicular parking, as compared to the non-affordable workspace.”

We recommend adding a new policy point: “3. Facilities will be particularly supported when they contribute to sustainability, for example through reuse schemes, recycling facilities, encourage active transport and reducing food waste.”