Greater Cambridge Local Plan Issues & Options 2020

Dear Sir or Madam Consultation response to Greater Cambridge Local Plan, Issues and Options 2020 Consultation I write on behalf of Cambridge University Hospitals NHS Foundation Trust to provide our response to the Local Plan, Issues & Options 2020 Consultation. We welcome the opportunity to contribute a response to the Greater Cambridge Local Plan in order to support the inclusive growth and development for Cambridge, in particular when considering the future of Addenbrooke’s Hospital and the Rosie, and the role of the wider Cambridge Biomedical Campus (CBC). About Cambridge University Hospitals NHS Foundation Trust Cambridge University Hospitals NHS Foundation Trust (CUH), incorporating Addenbrooke’s Hospital and the Rosie Maternity Hospital has over 1,000 beds and 11,000 members of staff. We are one of the largest and best known acute hospital trusts in the country. The ‘local’ hospital for our community, CUH is also a leading regional and national centre for specialist treatment; a government designated comprehensive biomedical research centre; a partner in one of six academic health science centres in the UK – Cambridge University Health Partners (CUHP); and a university teaching hospital with a worldwide reputation. We have worked closely with CUHP in preparing this response. CUHP have responded separately to this consultation on behalf of the wider CBC partners. Why are we interested in this consultation? Hospital projects The next phase of development requires the upgrade of the aging NHS facilities at the core of the Cambridge Biomedical Campus's vision. It is the Trust's view that this upgrade provides a further opportunity for the NHS (beyond the vision of the CBC) - a once in a generation chance to use capital investment to integrate our care models, strengthen regional ties, and improve the health care experience of patients locally and across the East of England. We summarise in this response our proposals for major investment in the hospital during the lifespan of the new Local Plan – with the Cambridge Children’s Hospital, the Cambridge Cancer Research Hospital and the rebuild of the core of Addenbrooke’s Hospital (known as Addenbrooke’s 3) all in our capital pipeline during the timeline of this Local Plan. Other projects may include other specialist facilities such as a neurosciences facility and a movement centre. Policies of the plan should ensure the future plans for CUH and the wider Biomedical campus can be accommodated and to improve the local hospital for the residents of Cambridgeshire and South Cambridgeshire, but to ensure the campus as a whole continues to drive nationally significant progress in health outcomes. Housing In addition to hospital projects, a key priority for the Trust is the issue of housing affordability. The lack of affordable housing for our staff, in the right locations, is a key barrier to CUH in recruiting and retaining key staff and skills and has implications for travel patterns, congestion and quality of life for our staff. We enclose evidence with our submission, as follows: 1) “Assessing the Housing Need of Hospital Workers” report prepared by Savills in January 2020. This is research undertaken on our behalf which highlights the real affordability challenges facing our staff, and some of the less desirable outcomes arising as a result. See our comments on questions 31 to 33. 2) We have prepared a summary report entitled “Delivering Affordable Housing for our Hospital Workers: The Case for Change”. This is a simple, accessible document, which draws out the key findings of the Savills research, and sets out CUH’s corporate priorities in terms of housing, highlighting the critical importance of delivering of genuinely affordable housing in accessible locations, to ensure the growth and prosperity of the area can be supported by the NHS. The research highlights housing as one of the key barriers to CUH in recruiting and retaining key staff and skills. Officers will be aware that we are hosting a briefing on this research on 2nd March, to which officers and Councillors have been invited. We very much consider that this research should inform the Greater Cambridge Planning Service’s evidence base on housing need and affordability, to shape policies in the new plan to help meet this need. I trust the content of our representations is clear, but should you have any questions, please do not hesitate to contact me.

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Cambridge University Hospitals NHS Foundation Trust (CUH), incorporating Addenbrooke’s Hospital and the Rosie Maternity Hospital has over 1,000 beds and 11,000 members of staff. We are one of the largest and best known acute hospital trusts in the country. The ‘local’ hospital for our community, CUH is also a leading regional and national centre for specialist treatment; a government designated comprehensive biomedical research centre; a partner in one of six academic health science centres in the UK – Cambridge University Health Partners (CUHP); and a university teaching hospital with a worldwide reputation. The next phase of development requires the upgrade of the aging NHS facilities at the core of the Cambridge Biomedical Campus's vision. It is the Trust's view that this upgrade provides a further opportunity for the NHS (beyond the vision of the CBC) - a once in a generation chance to use capital investment to integrate our care models, strengthen regional ties, and improve the health care experience of patients locally and across the East of England. There are three key NHS builds proposed to facilitate this: 1) Cambridge Children's - a paediatric hospital that integrates acute and mental health care, improving the pathways and support to patients and staff across the East of England. This project has been successfully granted £100m of funding. 2) The Cambridge Cancer Research Hospital - a hospital that brings together world class research (University of Cambridge) on methods to improve the early detection and diagnosis of cancer with the clinical (CUH) and commercial facilities to deliver that care. This project has yet to identify a funding source, however discussions are ongoing with industry partners and government departments; and 3) The rebuild of the core of Addenbrooke's Hospital - replacing aging NHS building with a new fit for purpose facility (Addenbrooke's 3) designed to maximise local integration with primary care and community service, working closely with GPs, community nursing, therapy teams, social workers and charities to transform the workforce and co-ordinate services more effectively, ensuring patients get quick and easy access to the care they need closer to home; alongside improving pathways and support to patients and staff across the East of England. In the timeline of this Local Plan, other projects may include other specialist facilities such as a neurosciences facility and a movement centre. Given the significance of the Cambridge Biomedical Campus and Addenbrooke’s Hospital to the area, in addition to the statutory consultation periods, Cambridge University Hospitals NHS Foundation Trust (CUH) strongly encourages the Local Planning Authorities to engage with key delivery partners in the area, including CUH. CUH wishes to engage proactively with the plan making process, to ensure that the growth envisaged is closely aligned with and supported by the expansion of key elements of infrastructure such as the Addenbrooke’s Hospital Campus (see our response to question 2). Policies of the plan should ensure the future plans for CUH and the wider Biomedical campus can be accommodated and to improve the local hospital for the residents of Cambridgeshire and South Cambridgeshire, but to ensure the campus as a whole continues to drive nationally significant progress in health outcomes. Cambridge University Hospitals NHS Foundation Trust would welcome the opportunity to engage directly at all levels to help the Local Planning Authorities to understand the opportunities, challenges and vision for the Addenbrooke’s site, its staff and patients. Good planning both on and off-site is essential to the Trust’s ability to attract and retain staff and deliver the World-class treatment, teaching and research for which it is renowned

Addenbrookes Hospital Extension

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Question 2. Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible Enclosed at Annex A, is a plan showing, Addenbrooke’s Hospital, the Rosie Maternity Hospital, expansion land for the hospital and the adjacent Cambridge Biomedical Campus. The land edged yellow represents the existing Addenbrooke’s Hospital and Rosie Maternity Hospital. The land shaded yellow represents land which CUH has options to draw down form the landowner, in order to facilitate the replacement and/or expansion of hospital buildings and facilities. Land edged blue represents the wider Cambridge Biomedical Campus. (application ref 16/0176/OUT) with the deadline for submission of reserved matters of September 2026. There are three key NHS builds proposed in the next 3-10 years. 1) Cambridge Children's - a paediatric hospital that integrates acute and mental health care, improving the pathways and support to patients and staff across the East of England. This project has been successfully granted £100m of funding. 2) The Cambridge Cancer Research Hospital - a hospital that brings together world class research (University of Cambridge) on methods to improve the early detection and diagnosis of cancer with the clinical (CUH) and commercial facilities to deliver that care. This project has yet to identify a funding source, however discussions are ongoing with industry partners and government departments; and 3) The rebuild of the core of Addenbrooke's Hospital - replacing aging NHS building with a new fit for purpose facility (Addenbrooke's 3) designed to maximise local integration with primary care and community service, working closely with GPs, community nursing, therapy teams, social workers and charities to transform the workforce and co-ordinate services more effectively, ensuring patients get quick and easy access to the care they need closer to home; alongside improving pathways and support to patients and staff across the East of England • The Addenbrooke’s 3 project has successfully obtained c. £5m of seed funding from Government to begin early stage feasibility studies. At this stage, CUH is not in a position to articulate the detail of this project, but it is likely to entail significant clinical development on the CBC Phase 1 and Phase 2 land, moving the centre of gravity of the Hospital to the south and west • Complex construction sequencing will be required to ensure we maintain the highest standards of care throughout the construction and commissioning periods. • We recognise the need to consider the end use of residual land which may be freed up from the demolition of life expired buildings and facilities. We have not put a formal submission into the Call for Sites as the Council are aware of the site and our intentions, and given it is consented for clinical uses. We intend to work with policy and development management officers over the coming months and years to develop a suitable policy framework to support our plans, and to ensure planning permissions are secured in a timely fashion. The working assumption is that construction of the new hospital would commence by 2025. The shaded yellow land has long been identified for the provision of clinical accommodation to support the (re)development of Addenbrooke’s Hospital. This includes:

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While the aspiration to plan for a twenty-year period is welcomed, CUH advocates considering developing a plan with a longer term time horizon, to ensure the co-ordinated planning of the area for the long term. Given the significant level of growth envisaged in Cambridge City and South Cambridgeshire, CUH considers that the plan should seek to guide development up to 2050 and so align with the anticipated delivery of our long term vision, the 2050 vision for the Cambridge Biomedical Campus (CBC) due in Summer 2020 and to align with potential delivery of major strategic sites that may come forward during the plan period. It would also allow planning on a longer time horizon having regard to planned infrastructure projects, including those promoted by the Cambridgeshire & Peterborough Combined Authority (such as the Cambridgeshire Autonomous Metro) and the Greater Cambridge Partnership (e.g. Cambourne to Cambridge, South East Transport Corridor). It is recognised that communities are concerned about such matters as green belt release, and by setting a longer term growth horizon, would allow the Greater Cambridge Planning Service to make longer term decisions about the future role of Cambridge, to help inform decisions on such matters as Green Belt, the special qualities of Cambridge and South Cambridgeshire, how they should be protected, whilst also stimulating growth through infrastructure, housing and the economy. Clear long term growth plans will also ensure other infrastructure (including health) can be developed as part of a long term strategy for the area .An end date of 2050 would also align the Plan with the UK government’s commitment to be net zero carbon by 2050

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CUH supports the ‘Big Themes’ as identified in the consultation document. These are very important and the aim to ensure the Local Plan delivers housing, employment and infrastructure to support the needs of the population in a sustainable, economically, socially and environmentally. However, as drafted, the document risks separating the themes from the role of the Plan. In order to make a “sound” Plan the Big Themes must include housing, employment and infrastructure as these are inextricably linked to the issues of climate change, bio-diversity, wellbeing and great places already identified. The purpose of the Plan is to deliver growth in the most sustainable, socially, economically and environmentally responsible manner, consistent with the NPPF (see for instance NPPF paragraph 5). The Plan as drafted fails to give due weight to issues such as housing, employment and infrastructure, including healthcare provision, all of which are fundamental to peoples’ wellbeing. On the issue of housing, which we feel is not given enough status in the document, CUH is committed to working directly with the Local Planning Authorities and other key stakeholders to deliver positive outcomes and housing that our workers can afford. The location of housing close to places of work and investment in infrastructure to provide sustainable means of getting from home to work is critical to the impact any development will have on climate change, by driving a shift away from car borne journeys to more sustainable long term travel choices (walking, cycling and high quality public transport). We submit as an appendix to these representations, two documents. 3) “Assessing the Housing Need of Hospital Workers” report prepared by Savills in January 2020. This is research undertaken on our behalf which highlights the real affordability challenges facing our staff, and some of the less desirable outcomes arising as a result. See our comments on questions 31 to 33. 4) We have prepared a summary report entitled “Delivering Affordable Housing for our Hospital Workers: The Case for Change”. This is a simple, accessible document, which draws out the key findings of the Savills research, and sets out CUH’s corporate priorities in terms of housing, highlighting the critical importance of delivering of genuinely affordable housing in accessible locations, to ensure the growth and prosperity of the area can be supported by the NHS. The research highlights housing as one of the key barriers to CUH in recruiting and retaining key staff and skills.

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Our view is that it is inappropriate to seek to prioritise or rank the Big Themes, which should also include economic growth, housing, employment and infrastructure, as they are inextricably linked to the delivery of development in a sustainable, economically, socially and environmentally responsible way and cannot be prioritised one above the other. This is fundamental to the principles of sustainable development as defined in the National Planning Policy Framework (NPPF, 2019). See for instance paragraph 5 which talks about economic, social (including housing) and environmental objectives for sustainable development.

Cambridge University Hospitals NHS Foundation Trust is aware of Government’s commitment to achieving a net zero carbon society by 2050. We are also aware that a number of organisations are campaigning for this date to be brought forward. CUH is supportive of this agenda and wishes to highlight some of the practical and wider considerations in achieving this, which should be taken into account when drafting any policies for the new Local Plan. It is important that a new Local Plan embracing net zero-carbon is agreed and delivered on an accelerated timeline. The IPCC model pathways with no, or limited, overshoot of 1.5 deg.C require carbon emissions to decline by approximately 45% from 2010 levels by 2030. For land-use planning policies to effect this target they need to be introduced promptly. We would recommend that steps on how to achieve this should be brought forward, agreed and implemented as a matter of overriding urgency. Planning policy has an important role to play across the full range of carbon emission sources and sinks. The full scope of these elements should be carefully established and linked to the relevant aspects of planning policy and control. For example, the core circular economy and carbon saving tenets of reuse and recycling can be facilitated by policies that ensure the infrastructure and space to realise these actions to the full is thoughtfully established. We are aware that decarbonising the economy has a number of potential health benefits: including integration of more active travel (walking, cycling), improved air quality, more engagement with nature, reduced congestion and reductions in travel time and consequential improvements to quality of life, to name just a few examples. These objectives are all supported by CUH and our health partners. As an operator of essential hospital infrastructure, CUH is keen to work with the Local Planning Authorities to explore how the policies and objectives set by planning policy will work towards this goal. Policies and criteria will necessarily be wide ranging, considering everything from travel choices (modal share), travel to work areas and home location of staff and visitors, through to the design and performance of our buildings, green infrastructure and biodiversity. We have identified in our response to this Issues & Options consultation some major projects - including a dedicated children’s hospital, the UK’s first cancer hospital, and potential comprehensive redevelopment of the Addenbrooke’s Hospital site, through development of Addenbrooke’s 3 on the CBC Phase 1 and Phase 2 land. All of these projects are subject to business case approval from Government, and funding may be limited. The real world cost implications of policies require careful early consideration. Should project costs render important NHS schemes unaffordable, this would be a very unfortunate and embarrassing unintended consequence of any policies that may be formulated, especially where those projects are clearly in the public interest. This suggests that for health delivery there is an especially poignant balance to be struck: on the one hand there is an urgent and extensive need for carbon reduction, to mitigate the increasingly damaging effects of climate change on our health, and, on the other hand, the potential impacts on existing healthcare delivery of the costs of taking these mitigating actions now. Policies should identify clearly the basis on which schemes should be developed and assessed, following appropriate industry best practice as it evolves, from bodies such as RIBA, CIBSE and the UK Green Building Council. These should be consulted on early, to allow industry to consider the implications. CUH would be pleased to engage with the Joint Councils and its appointed advisor(s) as the emerging thinking develops in this area, to help shape any policies, but also to ensure we build the emerging requirements into our project pipeline. At this early stage, we consider that any policies should also define circumstances in which departures from standards may be permissible, for instance where it can be demonstrated that it is not practical to achieve the objectives. For instance, Addenbrooke’s Hospital and the Rosie requires an energy loading far in excess of any normal commercial operation running 24 hours, seven days a week, 365 days of the year, with significant heat and power requirements in an aging building stock. To maintain critical care for our patients, we also need to build in redundancy to the system (back up supplies etc). The same is likely to be true of laboratories and other specialist users. Achieving net zero carbon is likely to be challenging for all buildings, but as the sector embraces the challenge, the cost of technology will reduce as it becomes increasingly ‘normal’. Given our development horizons, with major projects to be brought forward through planning in the next 3-5 years, and constructed over the next 5-20+ years, we would be keen to understand early the likely policy expectations in this field. Consideration also needs to be given to refurbishment projects, or extensions to the existing hospital, which rely on, for example, existing energy infrastructure. For these, achieving net zero carbon may not be practical or viable. Any policy should reflect very carefully on how it includes any reference to the off-setting of carbon emissions through off-site contributions. It is essential the Plan recognises that net zero carbon is a shared goal according to a fair and transparent allocation of responsibility. Within reason, we would recommend that emissions are measured and offset as and when they occur, thereby encouraging their reduction at source before any consideration of off-setting is brought into play. A very valuable way of introducing additional practical meaning to carbon reduction is through establishing transparently calculated energy use intensity (EUI) criteria for new buildings – these make sound measures of performance, can be readily monitored and are not skewed by variations in the carbon intensity of grid supplies. We also consider that it should be possible, in carefully defined circumstances, to explore the practicality and viability of achieving targets, set against any overriding public interest to ensure that the world-class care and research undertaken at Addenbrooke’s continues

The Local Plan’s role is to promote sustainable development. In order to ensure that such development promotes wellbeing and social inclusion, it will need to create better integration between existing and new developments, delivering the homes and jobs people need, whilst balancing these against social and environmental objectives, including relating to carbon, biodiversity and the affordability of housing. We set out below some of the priorities for CUH through the next Local Plan. Great Places Aligned to the objective of creating Great Places, new development should encourage open green spaces, well maintained, overlooked and lit pedestrian and cycle links and make provision for outdoor recreation. Opportunities to cycle or walk from home to work should be encouraged, as should opportunities to take exercise during the working day through the provision of ancillary uses, such as gymnasiums, washing and changing facilities on employment sites. This applies equally to residential development, as it does to our own Hospital projects. CUH has prepared a masterplan framework (with Allies & Morrison) to set clear expectations of how any projects that come forward contribute to a coherent place over time. Health provision in Planning Health provision should be integrated with the needs of the population. As part of the Cambridgeshire & Peterborough Sustainability and Transformation Partnership (STP), we wish to be closely involved with the development of the new Greater Cambridge Local Plan to ensure the best possible health outcomes are a key part of the plan and that health infrastructure is given appropriate priority in planning decision making. The identified priorities of the STP are as follows: • Integrated out of hospital care. Focusing on population needs, we will join up out-of-hospital services more effectively, building on the foundations of strong primary care and providing additional support where necessary. • Outpatient transformation. We will change the way we deliver our outpatient services to ensure that our patients are seen by the right professionals in the right places. • Redesigning care pathways to improve efficiency and reduce unwarranted variation. We will improve the quality of the care we provide by reducing variations in the way services are delivered, adopting best practice. • Making the most of our assets. We will identify opportunities to make the best use of our high fixed cost assets, including estates and digital infrastructure. The STP is developing its strategy in this area and is looking to appoint a single point of contact to engage on policy development, Local Plans, planning applications and CIL/S106. We will contact the Greater Cambridge Planning Service in due course. As part of this, the NHS system is working towards the development of some model Local Plan policies which we would wish to see incorporated in all Local Plans, to promote health, wellbeing and social inclusion and to contribute to Great Places. We would be pleased to engage further with the Greater Cambridge Planning Service to support preparation of policies for the new Local Plan. Housing in the right place that our staff can afford The Local Plan will also need to deliver a mix of housing sizes and styles at an affordable price. A key strategic priority for CUH is to support the delivery of more affordable housing in the right place, for our staff. We have submitted two documents in support of our representations: 1) “Assessing the Housing Need of Hospital Workers” report prepared by Savills in January 2020. This is research undertaken on our behalf which highlights the real affordability challenges facing our staff, and some of the less desirable outcomes arising as a result. See our comments on questions 31 to 33. 2) We have prepared a summary report entitled “Delivering Affordable Housing for our Hospital Workers: The Case for Change”. This is a simple, accessible document, which draws out the key findings of the Savills research, and sets out CUH’s corporate priorities in terms of housing, highlighting the critical importance of delivering of genuinely affordable housing in accessible locations, to ensure the growth and prosperity of the area can be supported by the NHS, including through recruitment and retention of staff. The research highlights housing as one of the key barriers to CUH in recruiting and retaining key staff and skills. To build on some of the recommendations of the report, CUH is seeking to work in partnership with a range of stakeholders to delivery significant discounts on market rents, and discounts on purchase, on high quality housing located within no more than 40-50 minutes of the Hospital.

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Continued economic growth is extremely important in the next Local Plan period not least because it is inextricably linked to quality of life social, physical and mental wellbeing. We note in particular the findings of the Cambridgeshire & Peterborough Independent Economic Review (CPIER), published in September 2018. This sets out a compelling case for the international importance of the Cambridge economy, a target to double the economic output of Cambridgeshire, and notes the real risk of decline if policies do not support the investment in infrastructure, housing (including affordable housing) and the economy, with a blended development strategy proposed. We note that all of the Local Authorities have signed up to recommendations of the CPIER report (November 2018), which is welcomed. In the spirit of CPIER, CUH believes that economic, housing and infrastructure growth must be given comparable weight to the other Big Themes at the very heart of the Local Plan; in line with the Government’s Objectives for Sustainable Development as set out in the NPPF. Environmental protection and economic growth, housing and infrastructure delivery are not mutually exclusive. The challenge is to deliver growth in an environmentally and socially responsible manner. The Cambridge University Hospitals Partners (of which CUH is a key stakeholder) are currently in the process of developing the 2050 Vision for the Addenbrooke’s Campus, the details of which will be shared with the Local Authorities at the appropriate time. As part of a bold future for Addenbrooke’s and the CBC, CUH plans to bring forward a new children’s hospital, the UK’s first specialist cancer hospital and a comprehensive redevelopment of Addenbrooke’s Hospital (Addenbrooke’s 3). The wider partners have their own aspirations which are going to be set out in the 2050 Vision for the Cambridge Biomedical Campus, due for publication by summer 2020. The policies of the Local Plan should provide a supportive framework for delivery of a world class NHS service at CUH, but also for the complementary research and development activities at the Biomedical Campus, that allow us to be a world leading campus, with pioneering scientific research, and leading patient care benefitting the residents who use Addenbrooke’s as their local hospital. But of course it does not stop there. For the continued success of CBC to be realised, this can only be achieved if the planning process provides a framework for delivery, if housing is delivered in the right places to provide affordable homes to the workforce, if transport improvements are delivered to reduce dependency on the car and if a joined up strategy considers all of the pillars of sustainable development. CUHP is committed to working with the Greater Cambridge Planning Service to develop an appropriate policy framework to guide the future development of Cambridge Biomedical Campus, including Addenbrooke’s Hospital.