Greater Cambridge Local Plan Issues & Options 2020

• Policy 61: the lack of any Historic Environment Strategy should be a source of embarrassment for an historic city like Cambridge that is facing such profound change. It is also in breach of the NPPF. • The abuse of economic Viability Assessments by some developers to reduce the proportion of affordable housing agreed in the planning permission. Councils will need to develop policies that ensure much tighter regulation of the use of such assessments • It is CambridgePPF’s view that there are sound policies in the 2018 Plan that are becoming ineffectual because of inadequate enforcement and because of the government’s relaxation of permitted development rights. To address these the Councils need to invest in more resources. For example, South Cambs does not have a list of Buildings of Local Interest and Conservation Area Appraisals are non-existent or not up-to-date. This means there is a risk that heritage is not being adequately protected even though there are adequate policies in the Local Plan to protect heritage.

• The 2018 Plans from both Councils included a strong and clear statement of their future Vision of the Greater Cambridge area. This is lacking in this consultation. The Plan must include a comprehensive overview of the sort of place we want Greater Cambridge to be in 20, 30 or even 50 years’ time. • An assessment must be made of the environmental capacity of Great Cambridge to absorb the scale of growth proposed in the consultation as a key document in the supporting evidence-base. Simply adding additional housing to an already stretched resource capacity is plain bad planning. • Greater Cambridge already faces a massive infrastructure deficit. If the level of the Objectively Assessed Housing Needs is determined by the Councils at a level greater than the minimum proposed by the government, then it must first show how the extra infrastructure is to be funded. Lacking any such financial analysis, including an assessment of the willingness of the private sector to take up the challenge, then the Plan will lack any sense of reality • The impact of London on Greater Cambridge’s development must be assessed. To what extent are housing pressures for the Greater Cambridge area being driven by increasing demand by London commuters, and the market’s ambition to make profit by meeting that demand? This trend will accelerate with the opening of Cambridge South station (see our response to Q4). To what extent can the Councils influence this issue?