Greater Cambridge Local Plan Issues & Options 2020

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Form ID: 48638
Respondent: Emmanuel College
Agent: Guy Kaddish

Yes, somewhat agree

5.16 Yes. With the right trees, in the right areas. A policy framework to seek tree cover increase, but allows for a planning balance within decision-making to enable the benefits and impacts of each development to be assessed. 5.17 This could be part of an on-site/off-site solution, which could generate notable s106 funds to achieve significant, meaningful and long-term planted and ecological areas. Ecological outcomes rather than an unconditional focus on native species should be considered in new planting.

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Form ID: 48639
Respondent: Emmanuel College
Agent: Guy Kaddish

5.18 Policies should highlight wellbeing and social inclusion as a key priority for new developments. 5.19 Good growth that promotes wellbeing (including health) should be inclusive and include antipoverty measures including: ● Energy efficient homes and employment space that deliver low energy and water bills; ● Promotion of commercial development and job creation that offers the Living Wage and opportunities for those on lower incomes to increase wages to easily access jobs; ● Allow for a wide range of social infrastructure and open space in new developments that provide pathways to free (i.e. no charge to the user) opportunities for improved health outcomes; ● Promotion of low cost housing proportionate to income in the area; ● Promotion of ‘fully accessible’ social housing, within active travel of employment; ● “ensure delivery of planned investment in transport infrastructure that improves connectivity between key employment locations and more deprived areas” Anti Poverty Strategy (DG23) 5.20 A spatial strategy that connects homes with jobs; good quality public transport; facilities/services and high-quality open spaces. 5.21 A policy framework that allows for innovative ways to deliver ‘affordable housing’; being a housing solution that provides for homes that are cheaper to buy or rent, whatever the planning mechanism; so long as the mechanism is robust and can be secured within a planning decision. 5.22 Assessment of schemes throughout the combined authority areas using a Health Impact Assessment (HIA) methodology that reflects best practice. Thresholds for HIAs should reflect the scale of the scheme and its ability to effect health outcomes. 5.23 Develop a policy framework that is based on empirical evidence of how good growth is delivered, rather than rely on policies based on perceived and sometimes unproven determinants of wellbeing and social inclusion. Focus policies on what really makes a difference. 5.24 Engagement with the combined authority, county council and CCG to understand community care and primary health care issues and needs, and to ensure facilities are available to deliver funded services.

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Form ID: 48640
Respondent: Emmanuel College
Agent: Guy Kaddish

5.25 Policies and procedures that encourage meaningful consultation and require developers to demonstrate how schemes have been influenced by local communities. 5.26 Community engagement should be sought during the design process, during construction and through opportunities to influence the scheme and /or be engaged in its management and maintenance after completion (where relevant), particularly in circumstances where unforeseen consequences emerge. 5.27 Such measures would assist with addressing the concerns of the community during the development management process.

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Form ID: 48642
Respondent: Emmanuel College
Agent: Guy Kaddish

5.28 First and foremost, to form a spatial strategy that ensures that new development is accessible or can be made accessible. Providing everyone with the opportunity to walk, bus and cycle to jobs, schools, shops, services and social activities. 5.29 Tenure blind development, with flexible housing mix policies to allow for the right homes in the right location. A clearer policy framework to support housing for elderly persons and increasing need for a range of homes and supported living. Page 14 5.30 Socially inclusive communities are created by people, but it helps if infrastructure is provided in time for first residents, either as a temporary facility or a smaller version of the final product. Ensure that support systems/management strategies are in place for community infrastructure. In new settlements, community development workers are key to establishing links between people and opening connecting newcomers to the wider environment. 5.31 Build in public realm to all forms of development (housing, employment and leisure) that encourages informal meeting and ‘bumping’ into people. 5.32 Ensure delivery of truly affordable homes

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Form ID: 48643
Respondent: Emmanuel College
Agent: Guy Kaddish

5.33 A spatial strategy that can support connected spaces where people do not have to rely on the private car for their daily routine of school, work, shopping and leisure. Enabling active lifestyles and opportunities for social interaction is a priority. 5.34 Providing open space within developments where possible, alongside a policy framework to allow for off-site enhancements where appropriate, particularly when they can improve provision for existing communities. Standards within policies that determine the quantity and quality of provision should reflect an evidence based assessment of need and benefits delivered. 5.35 Consider the needs of all age ranges and abilities in the detailed design of open spaces and public realm. 5.36 Ensure that new developments encourage healthy eating choices through the provision of healthy options (including supermarkets) and minimising/preventing fast food outlets.

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Form ID: 48644
Respondent: Emmanuel College
Agent: Guy Kaddish

5.37 Principally through the reduced use of polluting vehicles by: ● Locating development, particularly schools, places of work and other facilities that have a high footfall, where there is good access to active travel and affordable, frequent, reliable and high quality public transport options; ● Better cycle lanes, parking and cycle security – achieved by developments directly and through a coordinated s106 infrastructure programme; ● Reducing the volume of HGV movements in the city; ● Encouraging the use of less polluting vehicles particularly during rush hours when emissions from stationary traffic makes conditions for pedestrians and cyclists and other vulnerable groups particularly bad. 5.38 Tree planting in urban areas would also assist with tackling air pollution. Species in these locations should be selected for their pollution absorbing properties.

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Form ID: 48645
Respondent: Emmanuel College
Agent: Guy Kaddish

5.39 As part of a flexible development strategy, it is likely that an increase in the built density within Cambridge will be required. Given that the majority of Cambridge lies within a Conservation Area Page 15 and comprises many listed buildings, it is almost inevitable that new development will have a level of impact on such designated heritage assets. It needs to be acknowledged, however, that when determining applications within Cambridge a planning balance will likely need to be made in terms of weighing heritage conservation against the demand for new housing and economic growth and the associated public benefits. 5.40 Paragraph 196 of the NPPF notes that where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use. A similar line of enquiry is stipulated in Paragraph 195 regarding proposals which would result in substantial harm to or the total loss of the significance of heritage assets. 5.41 The proposed policy framework should therefore take the above into account. Where a proposal would result in a level of harm to a designated heritage asset in Cambridge, it should be balanced against the public benefits of the scheme. Although decisions will be made on a case by case basis, it is considered that great weight should be given to proposals which would provide substantial public benefits, including the provision of high-density, well-designed housing on sites which are in close proximity to the city centre and/or public transport routes. While it is acknowledged that many sites in central Cambridge comprise, are adjacent to, or are within designated heritage assets, the opportunity to provide extensive public benefits associated with large scale developments should not be balanced against the potential harm to designated heritage assets. 5.42 Paragraph 200 of the NPPF notes that Local Planning Authorities should look for opportunities for new development within Conservation Areas and the setting of heritage assets, to enhance or better reveal their significance. Proposals that achieve these elements should be treated favourably within the emerging policy framework. An example of how this could be achieved would be for proposed developments to concentrate public open space around designated heritage assets. Such measures would likely enhance the significance of designated heritage assets, while at the same time still ensuring the delivery of much needed dwellings and employment floorspace.

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Form ID: 48647
Respondent: Emmanuel College
Agent: Guy Kaddish

6.2 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed, as indicated by Paragraph 59 of the NPPF.

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Form ID: 48648
Respondent: Emmanuel College
Agent: Guy Kaddish

Nothing chosen

6.3 Yes, strongly agree – The Councils correctly recognise that housing is one of the most important issues in planning and one that for Greater Cambridge must extend beyond considerations of meeting the minimum needs as calculated using the standard method. Using the Governments approach results in a local housing needs assessment of circa 1,800 dwellings per annum (dpa). However, it is important to recognise that the Government state in the PPG that this is the minimum number of homes that must be planned for and that it does not attempt to predict the impact of other factors. Therefore, in an area with strong economic growth, and aspirations to maintain this growth, as well as the affordability of its housing stock continuing to decline it will be important for the Greater Cambridge Plan to establish a housing requirement that seeks to address both these concerns. 6.4 What is evident from the evidence base supporting the local plan is that 1,800 dpa minimum established using the standard method will not be sufficient to support the economic growth expectations of Greater Cambridge. The work of the Cambridge and Peterborough Independent Economic Review (CPIER) sets out a compelling case for higher levels of housing growth within the Greater Cambridge area and warns of significant negative impacts on both the local and national economy should housing needs continue to be constrained. It is noted that the consultation document recognises this fact and it must play a significant factor in the decisions regarding this local plan. The economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. 6.5 However, the increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. Whilst this is an undoubted concern for all residents of Cambridge looking to meet their housing needs, it is also an issue for businesses looking to move to the area. It is interesting to note from the CPIER report that the Greater Cambridge area would seem to have been underestimating jobs growth and its impact on the demand for new housing. Whilst the insufficient supply of housing does not appear to have, at present, impacted on economic growth, the ramifications of under provision can be seen in the housing market where affordability has worsened significantly over the last 10 years. Housing that is available at a reasonable price is key to attracting and retaining skilled employees. Without it there must be a concern that Greater Cambridge may not be able to achieve its aspirations for continued economic growth and that it may actually suffer if this issue is not addressed. 6.6 Coinciding with the above point, a Housing Needs Report accompanies this representation that undertakes an objective review for what the future housing needs of Greater Cambridge are. It finds that there is an underlying and systemic affordability issue that is making it increasingly difficult for those on lower incomes to afford to live in the Greater Cambridge area. Alongside, the Cambridge economy has seen a prolonged and steady increase, which has attracted a larger workforce and increased the pressure on the housing market; availability and affordability. Alongside this trend is a clear political aspiration to see the Cambridge economy grow further; mostly clearly expressed by the Combined Authority that has a growth target as set out in its Devolution Deal of doubling GVA over 25 years. All of this clearly points to the need to plan for an amount of housing well above the minimum housing requirement. 6.7 All these factors will require the Councils to establish a housing requirement far in excess of the minimum number of homes that results from the application of the standard method. It is evident that the Greater Cambridge area has been providing too little housing in recent years and the substantial uplifts being suggested are clearly necessary. The option of delivering at least 2,900 homes per annum within this local plan is supported.

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Form ID: 48649
Respondent: Emmanuel College
Agent: Guy Kaddish

6.8 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. Consideration of individual site circumstances and the circumstances of a local area should be taken into account to determine the appropriate type of housing for development sites. Separate housing needs assessments should be used to inform the appropriate size, type and tenure of housing needed for different sections of the community, as set out within the Greater Cambridge Housing Strategy 2019-2023. 6.9 Flexibility will be key to a successful Local Plan, through market housing, low-cost and affordable housing.

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