Greater Cambridge Local Plan Issues & Options 2020

1. Introduction 1.1 This statement has been prepared by Turley on behalf of The Bell Educational Trust Limited (the Trust) in response to the questions set out in the Greater Cambridge Local Plan Regulation 18: Issues and Options Consultation 2020 (the Consultation). 1.2 The Trust is the charitable shareholder of the Bell School which is located on the southern edge of the City in Redcross Lane, in close proximity to Addenbrookes. 1.3 This statement specifically considers those matters most relevant to the Trust and their current and future role within the City. Whilst the current Cambridge City Council Local Plan 2018 acknowledges the role that language and specialist schools make to the economy of the City, it also places a number of restrictions on their future expansion and ability to accommodate their students. 1.4 These restrictions are considered within this statement and emphasise the need for future policy to provide flexibility and give due consideration to all types of education provision within the City. 1.5 Section 3 of the report provides a detailed response to the Consultation on behalf of the Trust. The comments made focus on jobs, homes and biodiversity and green spaces.

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2. Background 2.1 The Bell Educational Trust Limited (the Trust) owns the site and wholly own Bell Educational Services (Bell), its trading subsidiary. Bell is an English language school for international students and has been established for over 60 years in Cambridge. 2.2 The school was founded by Frank Bell, a University of Cambridge graduate who had a vision to promote intercultural understanding through language education. Following his experience during the second world war, where as a prisoner-of war he established an “undercover University” and organised language courses to promote understanding and harmony through language education. In 1955 he opened his first language school in Cambridge. Since then Bell has grown to become a high-quality education business. The school offers a wide selection of English language courses, as well as university foundation courses for graduate and post graduates, young learners’ courses and teacher training. 2.3 Bell runs English language courses for international students, of variable duration, depending on student requirements. These courses run all year and provide the majority of the student intake. Bell also provides longer term courses for international students preparing for entry into higher education, where the study is in English. 2.4 The need to provide student accommodation has to be considered in the wider context of the expansion of the school teaching space and support facilities as a whole. In order to ensure that Bell continues to operate at the premium end of the market, the Trust needs to ensure that the school facilities are at the very least compatible with the best of its competitors. 2.5 The long term aspirations are to expand the current language school on the site at Redcross Lane through both the ability to increase the teaching floorspace and also to accommodate future students within a campus setting. 2.6 The following sections of this report provides specific comments in relation to the Trust’s views on the future policy approach for the Local Plan. Namely; • the provision of a policy which covers all education establishments in equal measure including the requirements for residential accommodation; • the removal of any requirement to restrict the occupancy of student accommodation to those undertaking a full-time course of a year or more; and • the re-assessment of the criteria relating to the designation of Protected Open Space.

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Summary: 3.12 In summary, the Trust consider that future Local Plan policy should provide a coherent and inclusive approach to the expansion of all educational establishments in the City with no exceptions. The current policy approach creates restrictions for those establishments falling within the ‘specialist colleges and language schools’ category. The contribution that these establishments make to the local economy means that their future expansion should be enabled without overly restrictive measures being put in place. Full Text: 3.2 Cambridge is a renowned area for high quality employment and innovation in business. The Cambridge Cluster Study prepared by SQW (2011) recognised the increasing contribution language schools make to the local economy. The Study stated that ‘the Eastern Region spokesman for English UK recently estimated that the sector contributes £78m per year to the economy of the Cambridge area’ (Page 90). 3.3 The Cluster Study suggested a review in policy approach to the development of language schools stating that the NPPF supported this. 3.4 The current Local Plan 2018 allows for the expansion of language schools and other specialist colleges subject to them being able to provide residential accommodation, social and amenity facilities for all non-local students. Paragraph 5.2 of Section Five: Supporting the Cambridge Economy: states that the Council aims to strengthen and diversify the economy and provide a range of job opportunities. The Plan acknowledges, at paragraph 5.30 the significant role that language schools and other specialist colleges play in contributing to the local economy benefiting retailers, service providers and host families and the tourism sector. However the current policy also restricts the ability of this sector to grow. 3.5 The Trust made representations about the negative impact of these restrictions in the consultation for the previous Local Plan 2018 and at that time it was pointed out that the proposed wording of policy 44 did not properly reflect the positive national policy position which seeks to build a strong competitive economy. The revised NPPF 2019 continues to encourage significant weight being placed on the need to support economic growth through the planning system. The advice continues in paragraph 80 where it states that, “Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development”. 3.6 The Greater Cambridge Shared Planning Service (hereby referred to as the ‘Councils’’) have a target of doubling the total economic output of Cambridgeshire and Peterborough over the next 25 years. Continuing economic growth for the next Local Plan is therefore a key priority. Accordingly, all future policies must support this ambition and aid the Councils’ in achieving this aim. 3.7 It is acknowledged that there is a need to strengthen and diversify the economy of Greater Cambridge and in doing so there should be a difference in approach to the current Local Plan with both non-university schools and colleges being considered equally with the Universities in terms of their future expansion within the City. 3.8 Policy 44 of the Local Plan 2018 requires the development of support facilities including residential accommodation to be in step with the expansion of student places for specialist colleges and language schools. No such restriction is imposed on University development. 3.9 A suitable place to live along with access to adequate social and amenity facilities is needed for any non-local student irrespective of where they are studying. Any future policy should consider this approach and encourage the future development of existing business in this manner to enable future expansion to take place without overly restrictive measures being put in place. 3.10 The Issues and Options document places a key emphasis on the need to meet the net zero carbon target by 2050. This runs in tandem with the goal of doubling the economic output of Cambridgeshire and Peterborough over the next 25 years. It is therefore most logical to direct employment development to locations where the need to travel is reduced in order to meet both targets. Locations such as that occupied by the Bell School have good access to public transport and are within walking and cycling distance of the City Centre making them ideal for future expansion. 3.11 It is existing businesses such as these, in sustainable locations which should be assisted and promoted through changes to future policy.

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Summary: 4.17 In summary, the Trust seek to ensure that any policy relating to student housing should remove the criteria restricting the provision of new student accommodation to those attending a full time course of one year or more. This would enable the provision of student accommodation, outside of the two universities, to be provided and hence enable the expansion of and continued contribution of the establishments to the local economy while being more inclusive. Full Text: 4.2 The Issues and Options document sets out that the next Local Plan period will be 2017-2040. The currently allocated sites and planning permissions are likely to provide 36,400 homes, and a further 9,660 may be built after 2040. A number of sites are already planned which will contribute to future housing need for the next Local Plan. However, the current calculations using Standard Method indicate a need for 1,800 homes per year or 40,900 for plan period 2017-2040. 4.3 It is important to take into account that the Standard Method does not work when applied to ‘niche’ housing and therefore when considered alongside job growth, which has been faster than expected and is likely to continue to grow, undoubtedly results in the demand for housing being exceptionally high. In the Issues and Options document it is set out that if full jobs growth is achieved then 2,900 homes a year would need to be built, equating to 66,700 homes between 2017-2040. 4.4 There is therefore likely to be an additional need beyond the local housing need derived from the standard method of an additional 30,000 homes, particularly if the requirements of specialist housing are not met through the proposed method. 4.5 As has been set out earlier in these representations, continued economic growth within the Greater Cambridge area is a key priority, and therefore there will be a greater demand for more housing to meet the needs of those employed in the area. The Councils’ clearly acknowledge this in their Issues and Options by providing the above higher end growth figures. 4.6 This factor along with the different type of housing required, including student accommodation, will only serve to increase the demand for residential accommodation within the Greater Cambridge area for the foreseeable future, therefore additional housing will need to be provided at the upper level. 4.7 Question 33 of the consultation document asks; “What kind of housing do you think we should provide?” 4.8 The Issues and Option document acknowledges that there is a need to provide market and affordable housing that meets the needs of communities including amongst others, students. 4.9 In January 2017 the Assessment of Student Housing Demand and Supply for Cambridge City Council (ASHDS) was published to help inform the emerging planning policy relating to student accommodation. 4.10 The ASHDS provides a comprehensive assessment of student supply and demand in Cambridge and valuable background evidence. At the time Bell Educational Services participated in the survey undertaken as part of the ASHDS. 4.11 The school falls within the category of ‘non-University institutions’ as defined in the ASHDS. The ASHDS identifies the diverse accommodation arrangements and needs of non-education institutions and confirms that a large proportion of their students make no impact on the housing stock in the City. (Appendix 2 Paragraphs 1.16 part g and 1.34 of ASHDS). 4.12 In paragraph 1.16 of the ASHDS, of the 15,000 non-institutional students in Cambridge, 5,000 (33%) live locally in the parental home. Nearly 30% of students are housed in home stay. This being a fundamental part of their learning experience whilst attending the school. Just under 30% of students are housed in Purpose Built Student Accommodation (private halls or their own accommodation) with extensive use made of this accommodation out of term time making a very efficient use of existing available accommodation. Only 2% of the non-educational institution students (according to the ASHDS) are accommodated in shared housing. 4.13 The ASHDS identifies that all educational institutions in Cambridge have part time students. Both Universities have a proportion of part time students but the majority of part time students (75% of the total population) attend non-university institutions. The non-university educational institutions, such as Bell, offer a range of accommodation for their students who have different accommodation needs. For example, those students under 16 need a place with suitable element of care and supervision. 4.14 The study concludes that due to education being one of the fundamental drivers of Cambridge’s economy, ‘the provision of student accommodation is a necessary feature of the city’s development’. The assessment also advises that ‘a policy that requires new student housing to be located near the education institutions, assuming a walk, cycle or perhaps bus ride’ would be suitable. Reference is also made to the benefits of having a concentration of students residing close to their institution, as this would ‘enable some degree of management and coherent service provision’. 4.15 The current Local Plan 2018 currently differentiates between those institutions providing housing for students on full time courses of a year or more and those that are on shorter courses, many of whom attend the Bell School. 4.16 The Trust considers that there is a clear need for future policy to remove this differentiation and to consider all institutions in a comparable way. Currently policy 46 of the Local Plan 2018, criterion a) requires there to be a proven need for the accommodation to serve that institution. The submission of evidence to prove need as part of a planning application would enable the non-University educational institutions to demonstrate this in the same way as the universities and allow the local planning authority to interrogate the information. A distinction between the Universities and non-university institutions is not necessary and should be removed in future policy.

Summary 5.7 In summary, the Trust is seeking to ensure that the future criteria adopted for the justification and designation of POS is reconsidered, and that there is a set of requirements which should be met rather than just one. In doing so, the Trust would like to ensure that there is a removal of a ‘blanket approach’ to the designating of sites and instead only specific areas of high importance included within a site. Full Text: 5.3 Most of the Bell School site is designated as Protected Open Space (POS) in the Local Plan 2018. Policy 67 seeks to protect all open space whether designated or undesignated. It makes no differentiation between Protected Open Space and undesignated space. All are considered protected by virtue of meeting just one of the assessment criteria as listed in Appendix I of the Local Plan. 5.4 The Issues and Options consultation makes it clear there is a need to consider how attractive, accessible and well-designed open space is created and protected as well as looking at how to improve, add to and connect up our green spaces. The Trust is in favour of supporting improvements to the natural environment and improving the green space network, however, there is a need for consideration to be given to those existing allocations and whether they fulfil the objectives of future policy. 5.5 The site at the Bell School provides an attractive area of open space for the students and staff of the school. The Trust consider this to be an important feature of the site which should be retained, and over the years have employed a groundsman to maintain the attractive grounds. However, since its designation as POS some of the areas included within the designation contribute far less in terms of quality and are not visible from outside of the site. The opportunity to improve or connect this site with other green spaces is not currently possible and particularly since the development of Ninewells to the south and south east of the site. 5.6 The Trust is not seeking to remove the designation of the site but suggest that as part of the consultation process there should be a review of the criteria against which POS is considered, and in allocating or retaining POS a need to ensure that there is a set of criteria against which all sites are assessed and all elements should be met in order to warrant its designation.

Summary 5.7 In summary, the Trust is seeking to ensure that the future criteria adopted for the justification and designation of POS is reconsidered, and that there is a set of requirements which should be met rather than just one. In doing so, the Trust would like to ensure that there is a removal of a ‘blanket approach’ to the designating of sites and instead only specific areas of high importance included within a site. Full Text: 5.3 Most of the Bell School site is designated as Protected Open Space (POS) in the Local Plan 2018. Policy 67 seeks to protect all open space whether designated or undesignated. It makes no differentiation between Protected Open Space and undesignated space. All are considered protected by virtue of meeting just one of the assessment criteria as listed in Appendix I of the Local Plan. 5.4 The Issues and Options consultation makes it clear there is a need to consider how attractive, accessible and well-designed open space is created and protected as well as looking at how to improve, add to and connect up our green spaces. The Trust is in favour of supporting improvements to the natural environment and improving the green space network, however, there is a need for consideration to be given to those existing allocations and whether they fulfil the objectives of future policy. 5.5 The site at the Bell School provides an attractive area of open space for the students and staff of the school. The Trust consider this to be an important feature of the site which should be retained, and over the years have employed a groundsman to maintain the attractive grounds. However, since its designation as POS some of the areas included within the designation contribute far less in terms of quality and are not visible from outside of the site. The opportunity to improve or connect this site with other green spaces is not currently possible and particularly since the development of Ninewells to the south and south east of the site. 5.6 The Trust is not seeking to remove the designation of the site but suggest that as part of the consultation process there should be a review of the criteria against which POS is considered, and in allocating or retaining POS a need to ensure that there is a set of criteria against which all sites are assessed and all elements should be met in order to warrant its designation.

6. Summary and Conclusions 6.1 This representation has been provided on behalf of The Bell Educational Trust to the Greater Cambridge Local Plan Regulation 18: Issues and Options Consultation 2020. 6.2 These representations have provided general comments to the document subject to consultation and specifically relate to the Bell School site at Redcross Lane, Cambridge. 6.3 The school has been part of Cambridge since the 1950’s and has played a valuable role in encouraging students from abroad to the City. The Trust is seeking a more flexible policy approach to the future expansion of ‘non-university’ institutions in recognition of the important role that they play within the economy of the City and tourism. 6.4 Importantly, the removal of restrictions on those student attending short or part-time courses in terms of student accommodation and a more comprehensive approach to all education provision across the City. The Protected Open Space allocation for the wider school site currently makes it very difficult for the school to expand and the restrictions enforced through Policy 46 of the Cambridge Local Plan 2018 only add to this. 6.5 Accordingly we seek the following specific policy changes in the emerging Local Plan to facilitate the future growth of the Bell School; • The removal of any policy relating specifically to language schools and specialist schools and instead a broad policy that covers the expansion of all educational institutions with no requirement for residential accommodation; • Any policy relating to student housing should remove the criteria restricting the provision of new student accommodation to those attending a full time course of one year or more. This would enable the provision of education, outside of the two universities, to expand and continue to contribute to the local economy while being more inclusive; and • The review of the criteria attached to any Protected Open Space designation and the area to which this refers. The Trust wish to see the attractive grounds of the site retained but consider there to be no justification for the inclusion of some of the areas within the blanket designation. 6.6 The Trust is happy to meet with officers to discuss the matters raised further in order to assist with the drafting of the new Plan if that would be helpful.

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Summary: 4.17 In summary, the Trust seek to ensure that any policy relating to student housing should remove the criteria restricting the provision of new student accommodation to those attending a full time course of one year or more. This would enable the provision of student accommodation, outside of the two universities, to be provided and hence enable the expansion of and continued contribution of the establishments to the local economy while being more inclusive. Full Text: 4.2 The Issues and Options document sets out that the next Local Plan period will be 2017-2040. The currently allocated sites and planning permissions are likely to provide 36,400 homes, and a further 9,660 may be built after 2040. A number of sites are already planned which will contribute to future housing need for the next Local Plan. However, the current calculations using Standard Method indicate a need for 1,800 homes per year or 40,900 for plan period 2017-2040. 4.3 It is important to take into account that the Standard Method does not work when applied to ‘niche’ housing and therefore when considered alongside job growth, which has been faster than expected and is likely to continue to grow, undoubtedly results in the demand for housing being exceptionally high. In the Issues and Options document it is set out that if full jobs growth is achieved then 2,900 homes a year would need to be built, equating to 66,700 homes between 2017-2040. 4.4 There is therefore likely to be an additional need beyond the local housing need derived from the standard method of an additional 30,000 homes, particularly if the requirements of specialist housing are not met through the proposed method. 4.5 As has been set out earlier in these representations, continued economic growth within the Greater Cambridge area is a key priority, and therefore there will be a greater demand for more housing to meet the needs of those employed in the area. The Councils’ clearly acknowledge this in their Issues and Options by providing the above higher end growth figures. 4.6 This factor along with the different type of housing required, including student accommodation, will only serve to increase the demand for residential accommodation within the Greater Cambridge area for the foreseeable future, therefore additional housing will need to be provided at the upper level. 4.7 Question 33 of the consultation document asks; “What kind of housing do you think we should provide?” 4.8 The Issues and Option document acknowledges that there is a need to provide market and affordable housing that meets the needs of communities including amongst others, students. 4.9 In January 2017 the Assessment of Student Housing Demand and Supply for Cambridge City Council (ASHDS) was published to help inform the emerging planning policy relating to student accommodation. 4.10 The ASHDS provides a comprehensive assessment of student supply and demand in Cambridge and valuable background evidence. At the time Bell Educational Services participated in the survey undertaken as part of the ASHDS. 4.11 The school falls within the category of ‘non-University institutions’ as defined in the ASHDS. The ASHDS identifies the diverse accommodation arrangements and needs of non-education institutions and confirms that a large proportion of their students make no impact on the housing stock in the City. (Appendix 2 Paragraphs 1.16 part g and 1.34 of ASHDS). 4.12 In paragraph 1.16 of the ASHDS, of the 15,000 non-institutional students in Cambridge, 5,000 (33%) live locally in the parental home. Nearly 30% of students are housed in home stay. This being a fundamental part of their learning experience whilst attending the school. Just under 30% of students are housed in Purpose Built Student Accommodation (private halls or their own accommodation) with extensive use made of this accommodation out of term time making a very efficient use of existing available accommodation. Only 2% of the non-educational institution students (according to the ASHDS) are accommodated in shared housing. 4.13 The ASHDS identifies that all educational institutions in Cambridge have part time students. Both Universities have a proportion of part time students but the majority of part time students (75% of the total population) attend non-university institutions. The non-university educational institutions, such as Bell, offer a range of accommodation for their students who have different accommodation needs. For example, those students under 16 need a place with suitable element of care and supervision. 4.14 The study concludes that due to education being one of the fundamental drivers of Cambridge’s economy, ‘the provision of student accommodation is a necessary feature of the city’s development’. The assessment also advises that ‘a policy that requires new student housing to be located near the education institutions, assuming a walk, cycle or perhaps bus ride’ would be suitable. Reference is also made to the benefits of having a concentration of students residing close to their institution, as this would ‘enable some degree of management and coherent service provision’. 4.15 The current Local Plan 2018 currently differentiates between those institutions providing housing for students on full time courses of a year or more and those that are on shorter courses, many of whom attend the Bell School. 4.16 The Trust considers that there is a clear need for future policy to remove this differentiation and to consider all institutions in a comparable way. Currently policy 46 of the Local Plan 2018, criterion a) requires there to be a proven need for the accommodation to serve that institution. The submission of evidence to prove need as part of a planning application would enable the non-University educational institutions to demonstrate this in the same way as the universities and allow the local planning authority to interrogate the information. A distinction between the Universities and non-university institutions is not necessary and should be removed in future policy.