Greater Cambridge Local Plan Issues & Options 2020

• Rather than scattering employment sites across Greater Cambridge, they should be concentrated as far as possible into clusters which are served by public transport. Clusters within Cambridge are likely to attract knowledge-based employment with service and ancillary sectors mainly outside the City, where rents are lower. • A number of science, technology, and business parks in South Cambridgeshire, like Melbourn Science Park, Granta Park and Cambridge Innovation Park, currently have available space or the potential for further growth. Appropriate new employment should be focused in such sites before creating new commercial parks. • In our response to Question 24, we stressed the importance of employment space being provided in the new settlements. This is not just in order to help them achieve a degree of containment, but also because they should have environmentally sound transport access to Cambridge. More generally we believe that accessibility by walking/cycling and public transport should be a major consideration in deciding locations for employment space.

Somewhat inflexible

• To achieve some form of balance between the often-competing pressures facing Cambridge and the surrounding villages, there will be a need for the Councils to exercise a strong degree of control through the planning system. Market forces, if left unchecked through an open flexible approach, will encourage the creation of high density, high profit, developments at the expense of other uses. The level of flexibility must therefore be determined by the vision of the Plan as a whole and the wellbeing of its residents – this dictates a ‘Somewhat Inflexible’ approach. • The rapid rate of change in the retail and technology sectors dictates the need for flexibility in Plan making and implementation, especially in the later parts of the plan – see our response to Q4. Tourism is another area where flexibility may be necessary. • The need for flexibility emphasises the requirement for the continuous review of the Plan and its policies. NPPF Paragraphs 31 and 32 stresses that all policies in the Plan should be kept under review and up-dated as new evidence emerges. A Policy to this effect must be included in the Plan.

The rapid increase tourism in Cambridge has become a contentious issue with residents. Clearly it is an issue that requires effective management, although the Local Plan has limited ability to address this matter, which could be better dealt with through other Council departments. 30A. Managing Tourism in Cambridge • Avoid policies or new developments in the Plan that will exacerbate issues of mass tourism in the city centre. These might include: - developments that would increase crowding in already over-crowded locations. - developments which negatively impact on residential areas, such as budget hotels. - restrictions on the use of much needed local housing as short-term holiday letting (AirBNB). Councils elsewhere have proposed a licencing/registration scheme for AirBNB-type lets with a restriction of a maximum of 30 days per annum. - Developments which would encourage additional “day-tripping”: proposals that encourage longer-term stays and greater dispersal of tourism should be encouraged • Coaches should be discouraged from entering the City with parking facilities provided at P&R sites: tourists can then be transferred to the City Centre using electric shuttle services. The SW sector of the City Centre around Queen’s Green is being degraded because of its use as a drop-off/pick-up site by coaches, and this must be stopped. • A sustainable tourism plan/strategy should be produced to which developments must be in alignment. The potential to disperse tourism through tours to less visited parts of the City should be explored • Serious consideration should be given to the introduction of a tourism charge to fund the measures proposed in the strategy. Several cities, like York, Bath, and Edinburgh, are proposing a “tourism tax” to be applied through the tour operators or overnight accommodation. • Tourism not only erodes the enjoyment of the City by residents but also has a direct impact on the heritage assets themselves. This threat and appropriate counter-measures must be covered by the Historic Environment Strategy. It may, for example, be necessary to limit entry to assets only to guided parties whose numbers and frequencies can be controlled. 30B. Supporting tourism in rural areas • Most “tourists” visiting attractions in rural Greater Cambridge will be local people – for example, Wandlebury Country Park has over 60,000 visitors per year almost all drawn from within Greater Cambridge. Rural attractions include places such as Wandlebury, Wimpole Estate, Wicken Fen, Anglesey Abbey, Denny Abby and Fen Drayton Lakes. All of these locations are experiencing visitor pressure caused by a rapidly increasing local population, rather than tourists from further afield. Most of these attractions provide quality-of-life benefits to local people. • If the Greater Cambridge population continues to grow, then new visitor attractions will need to be created or existing attractions expanded. The expectations of visitors for high quality facilities are also rising, so attractions must be able to provide top-class interpretation and information, together with toilets, paths and ramps suitable for disabled visitors, refreshments, and vehicle parking. This also means that associated operational buildings may be needed, for example for storing machinery, work vehicles, and staff facilities. It may even be necessary to have staff permanently on-site for security or other operational reasons. The Local Plan policy should recognise these pressures and be supportive of measures to address them – within the historic and environmental constraints often present at visitor attractions.

• The policy of 40% affordable housing must be continued and rigorously enforced by the Councils. The use by developers of Viability Assessments as a justification to reduce the proportion of affordable must be resisted, and all viability appraisals must be transparent, publicly available, and subject to independent scrutiny. We don’t feel that the current system works and would suggest that this is an issue that needs to be addressed through an independent expert body that could act on behalf of the local authorities. • Developers have now had long enough notice that they are required to provide 40% affordable that this should have been factored into the land-value and therefore, going forward, viability assessments should not be used to avoid 40% affordable. If developers overpaid for the land then why should that impact those who can least afford housing? • Large developments should include housing provision for key workers. As well as those people who work in the public sector in roles that are vital to the infrastructure of the community, such as teachers, police officers, armed forces personnel and National Health Service, we believe that key workers for Cambridge should also include care workers, laboratory technicians, low paid public service workers and support workers (cleaners, porters, etc). • Large developments should provide a variety of housing options for different markets in order to achieve faster rates of completion - for example, the inclusion of private rented, social rented, retirement, self-build, etc, as recommended in the Letwin Report. • ‘Affordable housing’ is still unaffordable to those on the Councils’ housing list, so both Councils should explore with central government mechanisms to maximise the proportion of Councilowned new housing for affordable rental and other types of tenure. • The Local Plan should adopt the recommendations of the Building Better, Building Beautiful Commission when it reports in 2020.

No, somewhat disagree

• CambridgePPF strongly disagrees with this suggestion (we are curious as to why “strongly disagree” was not an option). We should not be planning to provide housing at a level above the requirement set by Government. • The Government’s minimum ‘standard method’ target of 41,000 by 2040 is realistic in terms of land availability and capacity to deliver, especially with the Cambridge Airport and the North East Cambridge sites coming forward during the Plan period. However, just to reach this minimum target will mean raising the annual target for home completions from 1,675 to some 1,800. At the moment, the Councils are failing to deliver even the current targets by a substantial margin so raising the targets will require a significant step-up in performance. • The 2018 Local Plan has proposed a significant amount of new development and a substantial increase in population. It will not start to become clear until 2025 and beyond what impacts this growth will have – for example, traffic congestion, overcrowding in Cambridge City Centre, or water shortages in our chalk streams. Therefore, it would seem unwise to continue to extrapolate growth to 2040 (or beyond) until the impacts of the ‘in-pipeline’ growth are better understood. This in turn would argue that a ‘precautionary approach’ should be adopted to the housing targets. If the continuous review process shows insufficient housing coming forward, then it is much easier to increase than to reduce targets during the course of the Plan – see our response to Q4 • The ‘Objectively Assessed Housing Needs (OAHN)’ will, as always, be the most contentious issue in this Plan’s preparation with the developers arguing for more and the residents’ organisations for less. In the absence of any clear Vision as to how the Councils envisage the Greater Cambridge area evolving over the next two decades, it is impossible to determine the ‘correct’ balance. • The question also raises the issue as to what are the resource restrictions that will eventually limit growth. Are these being assessed? Simply assuming that more and more housing can be loaded into Greater Cambridge is ludicrous without some examination of the capacity of the area to accommodate such growth. • To accommodate the doubling of the economic growth rate as set out in the CPIER, the Councils suggest that the OAHN target may need to be increased to around 66,700 by 2040, equivalent to a completion rate of some 2,900 each year. This represents an increase of some 75% over the current target which the Councils are failing to meet. It also represents an increase in the Greater Cambridge housing stock of more than 50% in just two decades. Is this realistic, deliverable or indeed desirable?: - are there sufficient sites that have the necessary transport and infrastructure in place without having to remove high quality agricultural land from food production or cause damage through new transport schemes? - is the water supply adequate for this scale of development? Electricity supply? How will the waste management be handled? - our large green spaces such as Wandlebury are already starting to reach capacity, where will the funds come from to provide additional large green spaces or expand the existing ones in order to have sufficient to accommodate such an increase in population? - what impact would such a massive and rapid increase in population have upon local services like education and healthcare? - how can the already overloaded infrastructure accommodate such an expansion? What effect will it have on traffic congestion, or crowds in Cambridge? - what impact would this growth have on the quality-of-life of current residents? • To absorb such a disruptive short-term increase would require a massive programme of capital investment – for example, a new reservoir in the East Anglia region to ensure adequate water supply, new waste incineration and sewage treatment works, additional capacity for the electricity supply, and the like. It would be folly to assume that the current infrastructure could accommodate such a massive surge in demand with just a little tweaking here and there. There is already a substantial infrastructure deficit just to accommodate the much smaller current growth projections, so where is this additional investment coming from? Central Government? Until and unless the investment funds are forthcoming, any increase over the Government’s figure of 41,000 should be resisted. • Even if the necessary infrastructure was forthcoming (which would seem improbable with the Government’s focus on the North), do we want to see Cambridge transformed from a compact, green city with its world-class historic core into a sprawling metropolis? The irony is that such a rapid rate of growth would do serious damage to the character and ambience of Cambridge such that its international competitiveness would be impacted, resulting in a drop in the demand that was driving the unsustainable growth in the first place. We cannot afford to trash a lovely historic city in an unsustainable dash for growth. • CambridgePPF is concerned that rapid housing growth together with a fast train service would simply attract more London commuters and that Cambridge could be providing London overspill. Does the Council have data that show the proportion of new build within and around Cambridge that is already housing London commuters? Cambridge South Station will increase the London commuter pressure and we won’t know the impacts of this until the late 2020s. • Some employment (and related housing) growth should be encouraged to disperse from greater Cambridge in order to reduce pressure on the over-heated local economy. Until pressures are relieved, we believe such growth would best be located in towns and cities that have good public transport connections to main centres (London, Cambridge) such as Ely, Peterborough, St Neots, Huntingdon, Bedford, Milton Keynes, etc.

• The types of housing set out in the Plan should be influenced by the allocations proposed in the SHLAA • The Letwin Review identified the low rates of house building on some large sites as being partially attributable to the lack of diversity of housing type in the housing offer. This must be addressed with a determination by the Council to ensure much greater diversity in the housing mix. • Cambridge needs more affordable housing but the ‘affordability crisis’ dictates that a wide range of affordable options must be pursued – affordable rents of Council owned properties, community-led housing (especially in villages where priority should be given to first-time buyers with a proven affinity to the neighbourhood), HMOs and shared-ownership models. Greater provision should be made for self-build which is an attractive method for young people to gain their independence. • Unfortunately, within the current development and planning framework the housing mix will largely be determined by the developers in response to market forces. The Councils will need to take a stronger stance if models like Eddington are to become the standard. • Greater provision should be given to accommodating an ageing population. New builds should have the structural flexibility for easy conversion to enable the elderly to remain in their own homes. Retired people whose children have left the family home may in principle want to down-size but in reality, baulk at the practical implications of leaving their home. Greater opportunity should be made to allow family homes to be subdivided with part of the property rented. • Greater Cambridge should also give consideration to expanding its definition of key workers. Essential local employment to support the high-tech sector includes relatively low-paid laboratory technicians, research assistants, ancillary support staff, cleaners, porters, and the like, and these categories should be included in ‘affordable’ housing schemes. • The register of empty properties needs up-dating and maintaining by both Councils. Bringing empty properties back into use would help alleviate some of the pressures on residential development.

• Developers who wish to operate in the Greater Cambridge area must sign up to the Cambridgeshire Quality Charter for Growth. Other quality initiatives, like Building Better, Building Beautiful, include recommendations for ensuring high standards, and these should be adopted by the Councils. • Many leading construction companies have now committed to either the Better Buildings Partnership or the UK’s industry-wide campaign, Advancing Net Zero, as part of their response to climate change. Developers supporting these initiatives should be favoured. • Introducing high standards at the planning stage is meaningless unless they are enforced during implementation. This raises the problem of the resourcing of the Councils’ Planning Departments, and their capacity to handle a near doubling of the house completion rates. It is appreciated that Local Authorities are grossly under-resourced for the scope of activities expected of them, but priority in budget allocations must be given to ensure adequate supervision and enforcement of planning policies at a time when pressures will inevitably increase.

• This question is the wrong way round – it is the development that needs to be in line with the infrastructure, especially transport, rather than visa-versa. The location of new development must be influenced largely through the capacity of the local infrastructure to support the development – rather than through the wishes of land-owners or developers. • To ensure that the right infrastructure is in place, two models are possible – either the Local Planning Authority provides the infrastructure itself, or the granting of planning permission is made conditional on the developer providing it. The issue for the first option is whether the Community Infrastructure Levy or Section 106 funding is sufficient to cover the Authority’s costs – for new roads or busways, this is unlikely to be the case, so where is the funding to come from? For the second option, there is the risk that making the CIL too demanding would trigger a claim by the developer that the burden would render the development unviable – and this is turn would result in a reduction in the affordable allocation. • Whatever the funding model, the fundamental necessity is that the infrastructure has to be in place and operational by the time the development is complete and ready for occupation.

• The Local Plan is limited in how it can address this issue. For example, it does not cover transport nor can it propose congestion alleviating measures. We feel that this should be made clearer so that people are not misled about what the plan can achieve or influence. • New developments should be required to provide sufficient secure cycle parking for every occupant of the dwelling. For example, a standard family house should have sufficient space for at least 4 cycles. The cycle storage needs to be large enough to accommodate a cargo bike or trailer to transport children, especially if new developments are too far to walk to school but within easy cycle distance. • New developments should be required to be laid out in ways which prioritise walking and cycling and public transport. Too often developments are laid out for cars and then walking, cycling and public transport are made to work around this layout. This nearly always results in a development that works well for cars but not for other modes of transport. Also see our answer to Q19. • Many Transport Plans created by developers tick all the boxes but do not deliver. What evaluation is carried out of these plans to assess whether they are successful? Can lessons be learnt about what works and what does not? If we know what fails then future Transport Plans would need to find alternative solutions rather than being able to repeat past failures. • It is now well researched that once a person’s commuting and travel behaviour is established it is very difficult to persuade them to change, so we would like to see more targeted effort go into working with new households during the first few weeks of their occupation - to motivate and support them to use more sustainable modes of transport. For example, cycle buddying.

• New water infrastructure is a necessity for Greater Cambridge if the levels of growth proposed in the consultation are to be delivered. Summer 2019 has shown that in dry periods there is insufficient water in the chalk aquafer to meet the needs of a growing population, to allow abstraction for economic uses, and to leave sufficient water to sustain the ecology of our rivers and streams. It will be impossible for the Local Plan to be considered sustainable, and thus compliant with the NPPF, without new water management infrastructure for the region. It will also be impossible to achieve aspirations for doubling nature or making our environment better for future generations without new water management infrastructure for the region. We understand that a new reservoir and/or open water transfer from wetter regions of the country are required. New development, above the level already set in the current Local Plan, should not be permitted until this water management infrastructure is in place. As well as protecting the environment, such a policy would provide an economic case for the financial investment that will be required.