Greater Cambridge Local Plan Issues & Options 2020

Response to Question 2 3.1 The site was submitted as part of the Call for Sites consultation in 2019 and Emmanuel College is continuing to promote the site for allocation in the Local Plan. The site is an opportunity to deliver a medium to large scale residential development to help meet the housing needs of the Greater Cambridge Authority. Description of the Proposals 3.2 A concept masterplan has been prepared to show how up to 120 new dwellings could be delivered on the site. The proposed development density would be 30 dwellings per hectare, with a net density likely being in the region of 40 dwellings per hectare. Such a density is consistent with national policy, as indicated by Paragraph 123 of the NPPF, and the context of the site. Figure 2: Concept Masterplan 3.3 The proposals seek to incorporate a range of features which would culminate in the delivery of key public benefits. 3.4 One such feature is the proposed oval of open space which is to be the focal point of the development and will enable a large part of the site to be made permanently available to the community. It is considered that the size and location of the public open space would create an appropriate setting for the Grade II listed building in the south-east of the site. 3.5 The existing Grade II listed building and its associated structures would be retained, with options for their conversion to be explored such as the provision of a community facility for future and existing residents. 3.6 The existing boundary vegetation would be protected, retained, and strengthened along residential boundaries. The scheme would seek to reinforce these existing corridors and would also provide access to the proposed biodiversity enhancements surrounding the oval-shaped area of public open space. 3.7 Further features of the concept masterplan, including commentary on the site’s opportunities and constraints, can be found in the accompanying Vision and Delivery Document. Justification 3.8 Whilst it is acknowledged that the land is designated as protected open space in the adopted Cambridge City Local Plan (2018) and has been discounted in the previous Call for Sites exercise in 2013, the site’s circumstances have since changed. Emmanuel College attained planning permission (REF: 08/0873/FUL) for the change of use of agricultural land to a playing field at land adjacent to Rutherford Road, which was implemented in 2011. This playing field is considerably larger (over seven hectares) in comparison to the site at Wilberforce Road and would comprise a greater quality of sports pitches due to the ability to include a contemporary sustainable drainage system. Consequently, it is Emmanuel College’s intention to relocate the existing sports ground provision at Wilberforce Road to the land adjacent to Rutherford Road, in order to make more efficient use of the land and concentrate the College’s sport provision in one location. 3.9 Such justification is therefore considered to satisfy the criteria set out in Paragraph 97 of the NPPF (pertaining to the development of open space, including playing fields), as it has been demonstrated that the playing field at Wilberforce road is surplus to requirements, and the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location (at land adjacent to Rutherford Road). Consequently, it is considered that the principle of relocating the existing sports provision at Wilberforce Road to the land adjacent to Rutherford Road would be acceptable. 3.10 Although it is noted that Emmanuel College Sports Ground is located within the Conservation Area and is adjacent to a Grade II listed building, such constraints are considered to be overcome via the proposed layout concept masterplan, which indicates an extensive provision of public open space and tree planting. Such measures would retain the existing open space within the curtilage of the on-site listed building, while the proposed dwellings would be sited relatively far away and screened from view via tree planting. 3.11 The listed building on-site could be put to a long-term beneficial use whether this be residential or community uses. 3.12 The concept masterplan indicates that the proposed development would seek to retain and protect the nine TPO-protected trees on-site. 3.13 Notwithstanding the above points, it is evident that the residential development of the site would result in the following benefits: ● The opportunity to deliver a valuable amount of market and affordable housing to help meet the needs of Cambridge; ● Locating residential development in a sustainable location. The site is approximately 1.6km from Cambridge City Centre and is well placed for future residents to be able to walk and cycle, rather than travel by private car, to access higher-order services and facilities. In addition, the site benefits from being located within 500 metres of a bus stop, which is served regularly by services travelling to Cambridge City Centre, Cambourne, and various University of Cambridge institutions; ● Making efficient use of land in a sustainable location, as supported by Paragraph 122 of the NPPF; ● Development in a non-Green Belt location; ● The delivery of over one hectare of public open space; ● Supporting Cambridge’s economy, including local shops and services; and ● Enhancing biodiversity levels across the site through proposed planting and increasing natural capital. Summary of Technical Assessments 3.14 A Highways Access Review has been carried out to support this promotion. The assessment acknowledges that the proposed access can achieve more than satisfactory visibility splays off Wilberforce Road, with a 2.4m x 90m splay being possible. 3.15 The Review also illustrates that the site is in a highly sustainable location, with future residents being able to access a wide range of facilities available within Cambridge City Centre without relying on the use of a private car. 3.16 A TRICS assessment has been undertaken using the nationally recognised trip rate database to determine the likely vehicle trip rate generated as a result of the proposals. This assessment indicates that the proposals would result in an imperceptible impact on the local highway network. 3.17 A Flood Risk and Drainage Site Appraisal has also been undertaken to support this promotion. This report notes that the site is wholly within Flood Zone 1 and mostly at a very low risk of flooding, although the southern boundary is at a low risk of surface water flooding with low depths. 3.18 The report indicates that there is a low potential for infiltration drainage, due to the clay-based geology of the site. It is therefore likely that an attenuation strategy would be implemented subject to further infiltration testing on site. 3.19 In terms of foul drainage, the closest public sewer is immediately adjacent to the east of the site within Wilberforce Road. Therefore, connection to the public foul sewer would be required for the development. 3.20 A Preliminary Ecology Appraisal also accompanies this submission. This document indicates that the site falls within the Impact Risk Buffer Zone of the Histon Road SSSI, which is located approximately 2.3km to the north. It should be noted, however, that Natural England do not consider new residential development within this risk zone to constitute a risk to the SSSI. 3.21 A non-statutory County Wildlife Site, Coton Path Hedgerow, is located close to the south-west boundary of the site, while a City Wildlife Site, Adams Road Sanctuary, is located on land to the east of the site. Neither of these sites are likely to be directly adversely impacted by future redevelopment of the site. 3.22 The Preliminary Ecology Appraisal also notes that the site has a baseline biodiversity value of 7.46 habitat units. In order to achieve no net loss to biodiversity, the report stipulates that 1.05 hectares of grassland would need to be created (26% of the total site area). To achieve a 10% net gain, then 1.17 hectares of grassland would need to be retained and enhanced (29% of the total site area). Such calculations, however, do not take into account the opportunity for the provision of additional ecological compensatory measures such as the provision of bird and bat boxes across the site. It is therefore likely that less grassland would need to be retained and enhanced in order to achieve a biodiversity net gain, on the basis that additional ecological mitigation is provided as part of the development. 3.23 In terms of protected species, the report indicates that the site has the potential to support the following fauna: ● Birds; ● Bats; and ● Great Crested Newts. 3.24 The Preliminary Ecological Appraisal therefore concludes that follow-up surveys of the above species should be undertaken in order to demonstrate that no harm would come to them as a result of the proposed development. 3.25 An Initial Heritage Appraisal also accompanies this representation, which should be read in conjunction with the Vision and Delivery Document. This report indicates that the illustrative layout of the proposed development would likely result in less than substantial harm to the significance of the on-site and adjacent heritage assets. However, the principles set out in the concept masterplan are considered to provide a suitable approach to the development of the site which takes account of the heritage considerations, although further detail at the design stage would be required to determine the exact levels of impact arising. Summary 3.26 Emmanuel College Sports Ground represents a sustainable residential development opportunity which would greatly assist the Greater Cambridge Authority in contributing to its housing need. The site has good public transport links and is located in close proximity to Cambridge City Centre, therefore indicating that future occupiers would likely use sustainable modes of transport to access key services and facilities. 3.27 While the indicative proposals indicate the loss of Protected Open Space, a suitable, larger alternative playing field used by Emmanuel College has been secured at land off Rutherford Road, Cambridge, which has been in use since 2011. Such a justification satisfies the criteria of Paragraph 97 of the NPPF, as it has been demonstrated that the playing field at Wilberforce Road is surplus to requirements, and the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location. The proposals therefore provide a further key public benefit, in that they present an opportunity to unlock a significant amount of public open space which was previously in private use and thus inaccessible to the public.

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Agree

Agree - The proposed Local Plan period up to 2040 is considered appropriate and accords with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Paragraph 67).

Agree

Agree - The four big themes for the Local Plan are considered suitable and all are considered to be important in the consideration of the spatial distribution of growth in the district, and for the determination of planning applications. The four big themes will generate a new way of planning, this may require a different way to make decisions; to allow other impacts to happen in order to achieve these four priorities. The Local Plan policy framework will need to allow for a clear planning balance to take place to assess and prioritise impacts.

5.3 The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 5.4 A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 5.5 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 5.6 The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound.

5.7 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for people, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework that recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

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5.8 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.

5.9 To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

5.10 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. 5.11 An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account.

5.12 This should come through from an up-to-date base assessment of Greater Cambridge assets, which leads to a Local Plan wide (and beyond) strategy. For example, landowners of existing Page 12 green spaces could be surveyed to assess their current usage and whether they are publicly accessible. It may be apparent that some green spaces are defunct and/or not publicly accessible, which would then encourage a strategy to identify new green spaces that can be accessed by the public. Development proposals could then be shaped around any identified priorities. 5.13 As part of a policy framework, it would also be logical to enable a level of flexibility with regard to the provision of green spaces. In some circumstances it may not be possible to deliver a sufficient amount of green space as part of a development. Policies should therefore allow for offsite mitigation and off-site net gain enhancements which can be used to improve the wider green space network.

5.14 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible. 5.15 A flexible, diverse approach should be allowed which entails no restrictive elements. For example, policies should not include an exhaustive list of what features must be required to deliver a biodiversity net gain. Rather, it is considered best to allow applicants to bring forward bespoke solutions based on their expertise and the context of their respective sites.