Greater Cambridge Local Plan Issues & Options 2020

The impression that a community can be ‘created’ is misleading. A safe and inclusive community will emerge only in the presence of the correct ingredients to enable it to evolve. We believe that these ingredients should include: - a high quality of design and house construction, - plenty of green space with attractive landscaping, - community rooms and meeting places, - play areas for children and kick-about/hang-out space for the young, - good public services and facilities. • Good design will encourage the growth of socially inclusive communities. The intention should be to create a place where people are proud to live rather than just a soulless housing estate. • The Cambridgeshire Quality Charter for Growth was revised by the Combined Authority in 2019 with a fifth theme, Community Cohesion, added. We believe that all developers wishing to build in Greater Cambridge should be required to sign up to the Charter. • All large new developments should have some form of Community Forum or Resident’s Association that can represent the interests of the community to the developer and Council. Sites like Eddington or Marmalade Lane provide a model that ought to be achieved by all, rather than being the exceptions.

This can be achieved by creating a well-designed network of green open space provision, both through a development and connecting to green spaces or countryside outside it. Depending on the scale of the development this ought to include a variety of types of open space to cater for different healthy lifestyle needs: play areas, sports areas, hang-about areas, cycle paths, footpaths, natural greenspace for quiet contemplation (de-stressing), allotments and public realm that encourages social interaction (seating, picnic tables, BBQ areas). Spaces should be well designed in order to ensure that they feel secure and discourage anti-social behaviour. • A growing population will put further pressure on limited existing green spaces (see our response to question 13). All developments, especially those for housing, should therefore set out how they will contribute to increasing the quantity and quality of green infrastructure in our area. This must include strategic green infrastructure beyond the development site because Cambridgeshire has a defecit of such space. New green infrastructure provision should be based on green infrastructure priorities, such as the Nature Recovery Network which we have suggested in our answer to question 12. This emphasises the need to create a joined-up network of green infrastructure, in particular expanding and linking existing green spaces. • We would like to see large new developments laid-out in ways which prioritise cycling, walking and public transport rather than private vehicles. There are examples from the Netherlands of housing estates laid out in this way, such as Houten (https://itdpdotorg.wpengine.com/wpcontent/uploads/2014/07/22.-092211_ITDP_NED_Desktop_Houten.pdf). Such developments are also usually much more community-oriented. Most developers do not want to include measures to reduce car use as they see easy car access as a selling-point for their properties, so how can the Local Plan bring about change in this regard? • To facilitate greater cycling, we would like the Local Plan to support the provision of appropriate cycle storage. A family of four could well need four cycles, including a cargo bike. It is therefore important that new developments are designed so that a large number of cycles, or large cycles can be stored securely. This might mean that there is sufficient space to install a shed in a garden and that it is easy to get to it (eg without having to take the cycle through the property). Ideally, we would like to see the secure storage provided by the developer to encourage cycle take-up (rather than the property owner being required to install their own). • We should be aiming for cleaner, greener, and safer communities where children can play in the street without fear of traffic or corrosion of their lungs. Car access in the immediate vicinity of sensitive areas like schools and play areas should be restricted. • Community facilities should include opportunities for indoor sports (this can be informally, for example badminton or basketball in a community centre). • Large developments should include buildings which are designed to accommodate gyms or exercise classes and developers should be encouraged to attract these uses. As part of their sales package perhaps a developer could include one-year membership of a local gym as part of the welcome pack to owners of new houses or business premises? Could the Local Plan support such initiatives? The issues of mental wellbeing, social isolation, and loneliness can all be tackled by designing new communities so as to encourage greater social interaction and mobility. A local church, community centre, café, pub, etc are all important facilities that promote community integration and should be operational when residents move in. • Gardening is a valuable means of improving personal fitness and wellbeing. For people living in apartments that have no gardens, space should be set aside in the development so residents can engage in communal gardening. New allotments should be provided in areas where there is a high proportion of apartments. • Ensuring that all new houses can be easily adapted for whole-life use can ensure that infirm or vulnerable people can live in their homes for longer. • Larger developments need to include houses designed for all demographics, so that people have the option to move locally and remain in their neighbourhood as they age and their needs change. In other words, more housing for older people.

The Local Plan is limited in the measures it can introduce to address this issue. For example, it does not cover transport nor can it propose congestion alleviating measures. The obvious means of tackling air pollution in the city is through some form of Pollution Charge, but this lies outside the remit of the Plan. We feel that this should be made clearer so that people are not misled about what the Plan can achieve or influence. • In areas of poor air quality, new development should not be permitted unless the developer can demonstrate that their development will not contribute to a worsening of air quality. • The design of new homes should limit the exposure of occupants to air pollution. For example, not locating windows close to queuing traffic or the inclusion of ventilation systems that allow clean air flows. • Reducing the amount of car parking in developments, especially those that have good local access to shops, services and employment.

[This is two separate questions. “Ensuring new development is well designed” is Q23: our response to Q21 focuses on the heritage issue and the impact of new development on the heritage] • an Historic Environment Strategy must be prepared before extensive additional development is approved. It should be a key document in Cambridge’s future. In our view, a major failing of the 2018 Cambridge Local Plan was the lack of an Historic Environmental Strategy, despite the fact that Paragraph 185 of the NPPF requires LPAs to prepare such a document. For a city like Cambridge, with a world-renowned historic core and at the same time one of the fastest growth rates in the UK, not to have an Historic Environmental Strategy would seem irresponsible. The strategy should also seize the unprecedented opportunity, in considering Cambridge and South Cambridgeshire together, of considering the historic city of Cambridge in conjunction with its wider historic and cultural landscape setting. The 2018 Local Plan’s collection of related planning documents that touch tangentially on the historic heritage is not an adequate substitute for a properly structured and comprehensive Strategy. based on a thorough understanding of significance and issues. First steps in preparing such a strategy include preparation of a baseline city-wide assessment of current issues, building on those identified in Conservation Area Appraisals and Management Plans. Conservation Area Appraisals should be explicitly and individually included in the evidence base for the Local Plan. • Fig 17 “Greater Cambridge’s heritage and design successes” is wrongly captioned and misleading in relation to the heritage. The numbers of Conservation Areas and Listed Buildings are the number of designations: as such, they are an indication of the quality of the historic environment, but NOT of “successes”. This diagram provides no meaningful indication of current issues affecting the heritage, of the successes or failures of current and past policies in managing it. We feel that the text is complacent in relation to the pressures on the existing heritage and its capacity to accommodate change on the scale being contemplated. • With its rapid growth, the old medieval city centre with its narrow streets and cramped buildings is poorly adapted to the demands of today with the massive footfall, international tourism, and congested traffic. The threats to the heritage need to be identified as soon as possible, as a key part of baseline evidence for the Plan, and assessing capacity for change. Adequate measures need to be developed to mitigate the cumulative effects of change, in conjunction with the Local Plan process, and implemented before further growth is approved. In this context, what has happened to the Historic Conservation Area Management Plan, included in the 2006 Historic Core Appraisal but omitted from the 2016 revision? We feel that this vital Management Plan should have been prepared and put into effect before the recent consultation on “Making Space for People”. NPPF Para 185 states that Local Plans should include ‘a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In Cambridge’s case, not only are individual buildings at risk (the former Mill Road Library) but the historic city, its skyline and its setting are seriously threatened by the quantum of growth being contemplated and the cumulative impacts of new development. • Greater protection should be given to Conservation Areas, Listed Buildings, Buildings of Local Interest, and other non-designated heritage assets. This is especially critical for nondesignated heritage assets – all too often planners have little idea of the impact on the historic environment of their planning decisions, greater consideration must be given to the advice from their own conservation officers. • In an historic city like Cambridge, Conservation Areas should be given greater respect in urban planning. Protection should be given not just to buildings Listed by English Heritage but also to buildings characteristic of the local vernacular and Buildings of Local Interest (BLIs). The priority for such buildings should be restoration rather than demolition, which should be allowed only when there is a clear and manifest gain to the public and not just the developer. Both Councils are at fault in not maintaining an up-to-date listing of their BLIs and not carrying out Conservation Area Appraisals. • CambridgePPF has been working with the City Council for several years using volunteers to assist the Council in carrying out some of this conservation work. We believe that there is scope for local communities to play more of a role in identifying the buildings and heritage assets that they would like to see protected in their community. These will not always be designated assets such as Conservation Areas or listed-buildings but rather buildings, streets, views or green spaces that provide character. We would like to see a policy within the new plan that enables communities to identify such heritage assets and for these “designated community heritage assets” to be a material consideration in the planning process. Local communities should be supported to identify such assets if they produce a Neighbourhood Plan. • The role and status pf the Design & Conservation Panel and Cambridgeshire Quality Panel should be strengthened. As a member of the Cambridge Design & Conservation Panel, we have seen how effective this can be at helping developers to significantly improve their schemes in relation to their impact on heritage. We would like to see this operating across both Council areas and more developments going before the Panels. Could it be made compulsory for all large developments that could have an impact on heritage to go before the Panel? • Through the preparation of Design Guides or Neighbourhood Plans – these should be the mechanism to minimise the negative impact of new developments on heritage assets. Such documents need to be given sufficient weight in the Local Plan so that applications can be refused if they are not compliant. • Both Councils should make a long-term commitment to support their conservation teams so they are adequately resourced to carry out their work, in particular to monitor the threats to heritage assets and to enforce what limited protection measures are already available. • We would like to see both Councils appoint Heritage Champions (refer to Historic England’s Heritage Champions Handbook, 2016 and updated HE Heritage Champions support and guidance dated 12-11-2019). SCDC appears not to have a list of ‘local heritage assets’. A list of these or Buildings of Local Interest (BLIs) should be set-up, and local communities should be encouraged to put forward their heritage assets or BLIs in accordance with Historic England Advice Note 7.

(We feel that this question is seriously flawed, it should refer to ‘historic places, buildings and landscapes’. It is also two separate questions, so we have split our response between to historic buildings (Question 22A) and historic landscapes (Question 22B) 22 A: How do you think we should protect, enhance and adapt our historic buildings? Cambridge meets 4 of the Outstanding Universal Value criteria for World Heritage Sites (i) “to represent a masterpiece of human creative genius” (King’s College Chapel); (ii) “to exhibit an important interchange of human values….on developments in architecture or technology…or landscape design” (the Colleges, University buildings, the best modern buildings, the Backs); (iv) “to be an outstanding example of a type of building, architectural or technological ensemble or landscape which illustrates significant stage(s) in human history (e.g. King’s College, the Old Schools, Senate House and Gonville and Caius as the living focus of one of the greatest universities in the world; the Backs; Downing as a ground breaking built representation of the early c19 neo-Classical ideal). • An Historic Environment Strategy that builds on the Conservation Area Appraisals, considers Cambridge in its landscape setting, identifies risks to the historic heritage and sets out full mitigation measures is of fundamental importance. This needs to consider the whole landscape associated with historic Cambridge, including the upper Cam as far as Byron’s Pool and the lower Cam along the length of the Lents and Mays course as far as Baits Bite. The lower Cam section, although fully covered by Conservation Area designations, has been threatened by growth-related transport proposal; so have the West Fields. The arguably more significant cultural landscape between Cambridge and Grantchester and beyond have no such protection, with the Grantchester Conservation Area boundary narrowly drawn and no Appraisal. While Grantchester Meadows are owned by Kings’ College, this ownership neither provides direct protection from developments beyond their boundary, nor has any force in planning terms. The need for such protection is highlighted by the impacts on the Meadows of the combined height and bulk of the CB1 development. Air pollution damages the fabric of old buildings and not just people’s lungs: the vibrations from heavy vehicles will over time weaken the structure of historic buildings. We must keep polluting buses/vehicles out of the historic core. • It is important for planners to appreciate that protection should extend to the setting and curtilage of an historic building and not just the physical structure: also views which may include distant views. • More Conservation Areas, active management of Conservation Areas and preparation of enhancement proposals, and up-to-date listing of Buildings of Local Importance. Buildings listed by English Heritage are generally well protected – the problem is with locally significant buildings that contribute to the local character but do not warrant listing. This produces a strong polarity between buildings considered important to protect and others that can be dismissed. • Adaptation, especially energy efficiency to minimise carbon emissions, is problematic in old heritage buildings. Heritage significance should be assessed, as required by BS 7913:2013, before proposing retrofit measures. As a general principle, and as required by PAS 2035, the heritage features, fabric, and significance of a building should not be impacted or reduced in a zealous drive to minimise emissions. This may mean offsetting measures elsewhere. • The introduction of safety and security measures, like barriers, cameras, and fencing to prevent entry, can all have a detrimental effect on the public enjoyment of our heritage. Planners must be alert to the possibility of over-reacting with invasive security measures to the perception of potential threat rather than to an actual threat. • Planners also need to be alert to the trend for the ‘Disneyfication’ of the heritage especially in areas of high tourism. • What can be done to promote the heritage outside the central core? Can tours be encouraged to less visited parts of the city – like along the Cam or the Leper Chapel/Museum of Technology/Abbey Church? In the mind of the planners, ‘heritage’ is becoming increasingly zoned as a concern just of the central core area. 22B: How do you think we should protect and enhance our landscapes? • A Landscape Character Assessment for Greater Cambridge should form part of the Local Plan. The historic and cultural significance of landscapes, where applicable, should be given full weight. • Local Plan policy should require developments to be in keeping with the landscape character assessments. • Local Plan site allocation should seek to discourage any development in those landscape character areas that are identified as being of highest value or at highest risk.

• There is a need to review successes and failures, and to learn lessons from them. CB1 is an example where historic environment considerations were given lower priority than claimed public benefits, which have not been delivered. Lessons need to be learned from past successes and failures. • One problem is that it is difficult for the local planning authority to refuse an application because of poor design – because it is all too likely they will lose on appeal. Developers know this and so, for some, there is very little incentive for them to invest heavily in quality architecture. If it is possible, we would like to see a policy in the Local Plan that makes it easier for the Councils to refuse schemes that are not well designed. The Plan should use the Building Better, Building Beautiful Commission’s report “Living with Beauty” as a basis for securing better quality design. The criterion – “does this scheme meet the standards set out in the Cambridgeshire Quality Charter for Growth?” – should be applied as the basis for assessments. • “Blandscape” is becoming the scourge of Cambridge. These are developments which are not necessarily ugly or badly designed but neither are they interesting or well-designed. Typically, they are block shaped with flat roofs and are almost identical to new developments in any other European city because they form part of the developer’s standard architectural portfolio. Outside of the historic core such developments, collectively, are eroding the character of the city into “anywhereville”. CB1 and the developments around Cambridge Central and Cambridge North station are examples of this. It seems that the planning authorities are powerless to stop it but we would welcome any policies within the new Local Plan which could support better architecture, especially in prominent locations such as major roads. • Applications should conform with Design Guides and plans which have been created by the local community, such as Village Design Guides and Neighbourhood Plans. Policy statements in the plan should afford sufficient weight to Design Guides or neighbourhood plans that have been created by the community (eg by considering them as SPDs), such that applications that do not conform can be turned down without risk of appeal. • We would like to see the Councils provide clear frameworks and guidance to enable and enthuse local communities and residents’ associations to become involved in preparing village design guides, neighbourhood plans and updated Conservation Area Appraisals. Once these are adopted, they should be material considerations in assessing planning applications. • Insist that any significant developments in very visible locations have to go before the Design & Conservation Panel or the Cambridgeshire Quality Panels.

Neither important nor unimportant

• This is a question of the greatest importance, and it is regrettable that this simplistic tick-thebox approach leaves it open to a variety of interpretations. In consequence the single answer format in the consultation document is unhelpful. Obviously continued economic growth is desirable but it cannot be at the expense of the environment or social cohesion. We need growth that is genuinely sustainable rather than an unbalanced rapid dash for growth just to meet a Government target. • CambridgePPF takes issue with the crude objective of doubling GVA of Greater Cambridge over 25 years. This could mean doubling the area’s population along with an unchanged GVA per capita. Equally it could mean doubling GVA per capita through gains in productivity along with an unchanged population. We can see little evidence that consideration is being given to increasing productivity per caput which could take some of the heat out of the development pressures. • Over recent years, national policies have given strong encouragement and support for economic growth in and around Cambridge, but the current emphasis on rebalancing the UK economy may lessen such support in future. Sustainable growth, taking into account economic, social, and environmental issues, will only be achievable if public investment in our green, grey and social infrastructure is commensurate with the dynamism of the knowledgebased sectors. If the necessary investment in green, grey and social infrastructure is not forthcoming, growth aspirations must be reduced. • The consultation refers to the many other sectors that provide job opportunities for local people and we agree that these need to be given full consideration in the Plan. However, we urge that a more sophisticated approach be developed towards the tourism sector to recognise that whilst longer-stay visitors may bring economic benefit to restaurants, hotels, pubs and the like, many short-term visitors generate little benefit yet their increasing numbers damage the functioning and amenity of Cambridge city centre. • We strongly support the provision of employment land in new settlements such as Northstowe not only to provide opportunities for their own residents but also to provide lower cost sites and premises for businesses that provide essential services across the subregion but cannot afford the high rents in Cambridge. Continued vigilance will be required to ensure that higher-value housing development is not allowed to crowd out employment uses.

• Over-reliance on inward investment is a high-risk strategy. To support indigenous growth through knowledge-based firms, the Plan should encourage development of incubator and innovation developments in prime locations. Cambridge needs to do more to support its own “home-grown” commercial opportunities • The departure of Marshalls from their East Cambridge site will significantly disrupt the balance of employment opportunities and training opportunities in the Plan area. Manufacturing should be recognised as contributing both to the range of employment opportunities and in capturing value from scientific and technological innovation. The Plan should ensure that any major new developments allocate land for manufacturing enterprises.

CambridgePPF would support the protection of industrial sites unless they are poorly located in terms of their impacts on the environment and provision of public transport. • The major shifts in the retail sector may make it appropriate, in certain locations, to allow redevelopment of retail sites and premises for a mix of other uses.

• CambridgePPF recognises the need for a range of different jobs but, in view of likely pressures from growth arising from knowledge-intensive sectors, we suggest that it would be inappropriate to actively encourage inward investment from sectors unrelated to the knowledge cluster through specific land allocations in the Plan. • Cambridge’s reputation is that of a fast-growing centre of high-tech so these are the sorts of employers it is likely to attract. It is therefore important that sites are allocated for jobs that support knowledge-intensive sectors and their associated services. Because of the high rental costs within the City, it is likely that employment opportunities in other sectors, like construction or warehousing, will be located outside the City, preferably this should be in one of the new settlements where the necessary services and infrastructure can be provided or in existing but under-used science and business parks. • We are concerned about the proliferation of science/business parks dotted around the rural fringes of Cambridge. Collectively they are having a significant impact on travel patterns (exacerbated because some of them are poorly located for public transport or cycling) and the previously rural character of the area.