Greater Cambridge Local Plan: Proposed Submission

Replace the opening of paragraph 4 with:

"4. Development proposals will contribute, in proportion to their scale and impact, to coordinated streetscape and public realm improvements within the Mitcham's Corner area, and must not prejudice their delivery. Proposals should have regard to the Mitcham's Corner Development Framework SPD (2018) or any successor document adopted by the Councils following consultation with landowners and the community. These improvements will:" [criteria a to e unchanged]

If the Councils intend a new framework, the policy should say who will prepare it and by when. It should also say that, until it is adopted, applications will be determined on their merits against paragraphs 1 to 3 and criteria 4a to 4e.

1. Solemn Investments Ltd owns a site within the policy area. It is preparing proposals for a mixed-use redevelopment of this brownfield site, with active ground-floor uses and homes above. It supports the policy's objectives: a less traffic-dominated environment, active frontages and a stronger sense of place. This objection is confined to the second sentence of paragraph 4.
2. Not effective, because the policy is ambiguous: The policy does not say whether the "development framework document" is the Mitcham's Corner Development Framework SPD adopted in December 2018, a replacement to be prepared by the Councils, or a document that landowners must produce. It gives no timetable and no approval process. A decision-maker cannot tell whether the precondition is already met. National policy requires policies to be clearly written and unambiguous, so that it is evident how a decision-maker should react to a development proposal.
3. Not justified: The same wording appeared in Policy 21 of the Cambridge Local Plan 2014 Proposed Submission. At examination, the Inspectors asked whether the "moratorium on the submission of planning applications" was consistent with national policy (Matter CC2D, question ii). The Council replied that the document was the Development Framework SPD then in preparation. It also accepted that applications could come forward if they did not conflict with the SPD's aims, and proposed a modification. The SPD was adopted in 2018. Nothing in the evidence explains why wording written before the framework existed is being repeated now that it does.
4. Not effective, because the policy cannot be delivered or enforced: If a new document is intended, it depends on decisions about the gyratory by the highway authority and the Greater Cambridge Partnership. Those decisions are outside the control of landowners, and the Plan sets out no programme or funding for them. Separately, a Local Plan policy cannot stop an application being submitted, because the planning authority must determine any valid application. The only practical effect is to create a policy conflict, and therefore uncertainty, for schemes that are otherwise acceptable.
5. Not positively prepared, and inconsistent with national policy. "Major" development starts at 10 homes or 1,000 sq m of floorspace. That captures almost any worthwhile redevelopment in a district centre of small plots. The Plan's strategy relies on brownfield and windfall sites within Cambridge, and national policy gives substantial weight to using suitable brownfield land for homes. An open-ended embargo in one of the city's most sustainable locations undermines both. The policy area also contains the Plan's own housing allocation S/C/HGH, Henry Giles House. Read literally, paragraph 4 would stall that allocation too.
6. The first sentence of paragraph 4 requires development proposals to "deliver" improvements to streets and junctions. A single-plot scheme cannot deliver changes to the gyratory. Contributions must be necessary, directly related to the development, and fair in scale.