Greater Cambridge Local Plan Issues & Options 2020

6.11 Local Plan policies can require a high standard of design for new residential development, leading from Government policy and guidance. Appropriately worded design policies should require a high quality design for new dwellings. This could include sustainable design principles including measures to improve the energy efficiency of new homes, water saving measures, use of efficient insulation material and heating systems, the reduction and recycling of construction materials, provision of appropriate amenity space and accessibility. Policy should not be prescriptive for precisely how it will be accomplished, it can set a policy-level, but developers should be able to use a host of options to achieve the target. 6.12 Health impact assessments on developments of a scale that can deliver meaningful health improvements can create a higher level of built environment in housing developments.

7.1 Greater Cambridge should continue to press ahead with ambitious public transport infrastructure projects, such as the CAM. It is evident that Cambridge’s public transport offering is not sufficient to give enough people a real alternative to otherwise using the private car. Furthermore, given the area’s potential for rapid growth, such transport infrastructure could assist in transforming the economy and improving people’s daily lives. 7.2 It is questionable, however, as to whether such transport infrastructure projects can be delivered during the proposed plan period. Throughout the plan period, it will be important to promote the development of sites that lie in close proximity to major corridors and/or are within walking and cycling distance to Cambridge City Centre. By siting development in these locations, people will be more likely to use sustainable transport modes to access key services and facilities.

8.3 While no single solution to development would deliver a sound Local Plan, the densification of Cambridge is considered to be a logical part of the solution when taking into account the potential economic growth raised by the CPIER report. 8.4 Paragraph 122 makes it clear that planning policies should support development that makes efficient use of land. Given the current and emerging local market conditions and its compact nature, as well as its capacity for future public transport infrastructure projects, it is considered that densification in Cambridge would be suitable.

‘Protection of Open Space’ (Policy 67) Cambridge Local Plan 2018 8.5 Policy 67 of the Cambridge Local Plan (2018) currently requires the following when considering development proposals on areas of land protected as open space: “Development proposals will not be permitted which would harm the character of, or lead to the loss of, open space of environmental and/or recreational importance unless: a. the open space can be satisfactorily replaced in terms of quality, quantity and access with an equal or better standard than that which is proposed to be lost; and b. the re-provision is located within a short walk (400m) of the original site. In the case of school, college and university grounds, development may be permitted where it meets a demonstrable educational need and does not adversely affect playing fields or other formal sports provision on the site. Where replacement open space is to be provided in an alternative location, the replacement site/facility must be fully available for use before the area of open space to be lost can be redeveloped.” 8.6 The designation of protected open spaces within the Cambridge Local Plan is too broad, the policy serves to protect most spaces in the City for recreation and environmental ‘importance’, using a broad ‘catch all’ assessment criteria and then applies an overly restrictive 400m distance restriction to any relocation. The 400m restriction does not allow for any balance of the issues, or benefits that may be accrued from a relocation that happened to be over 400m away. 8.7 This is highlighted by Emmanuel College Sports Ground which is identified within the Local Plan as a Protected Open Space and an Outdoor Sports Facility ‘Emmanuel College Playing Field (REF: SPO 16). The site is identified as having both environmental and recreational importance within the Open Space and Recreation Strategy (2011), however, the Strategy does not set out in any further detail as to how this assessment has been made. It is therefore not clear how the Council have determined that the site is of environmental and recreational importance. 8.8 Paragraph 7.48 of the Local Plan requires that replacement sites / facilities should be no more than a short walk (400m) from the site that is to be replaced. The plan in Appendix 1 shows that the 400 metre radius around the site is heavily constrained and already features residential development, Green Belt land and other protected spaces. There is limited opportunity to reproviding the open space within a 400-metre radius of the site, if that was the appropriate response. Major benefits could be achieved, in theory, by providing for a new purpose-built facility that was more than 400m away, but the policy is overly-restrictive to not allow a judgement to be made. 8.9 The Appendix 1 Plan shows all the currently Protected Open Spaces and their 400m isochrones to reflect the 400m described in adopted Cambridge Policy 67. This vast protection of spaces arises through an assessment criteria that is too broad and essentially forms a ‘catch all’ approach, protecting whole sites, when for example the environmental ‘importance’ only applies to a part of the site; such as with Emmanuel College Sports Ground and its planted boundaries, but yet the whole site is protected. 8.10 The approach to recreation protection is also not a robust policy position. Emmanuel College Sports Ground is now surplus to requirements following the land at Rutherford Road being secured as an alternative, larger location for College sports provision (REF: 08/0873/FUL), yet it is given the full protection of Policy 67 for its recreational importance. The Local Plan also requires that replacement sites/facilities should be provided so as not to increase any identified deficiencies in open space in the ward where the site is located. In the case of Emmanuel College Sports Ground, the site is located within the Newnham Ward, where no deficiencies are identified within the Open Space Strategy (2011). In this case the site would not lead to increasing deficiencies within Newnham, but this matter is not taken into account in making the designation, nor does Policy 67 allow for the same matter to be taken into account in application decision-making. On a related issue, Policy 67 does not relate well to NPPF paragraph 97 and its criterion (a) which allows for an assessment to be made to ascertain if the open space is surplus to requirements. 8.11 Paragraph 7.47 of the Local Plan identifies that there is a ‘clear presumption’ against the loss of open space of environmental or recreational importance, and that: “Any proposal involving the loss of open space must include an assessment (using the criteria listed in Appendix I) to determine the important aspects of the site that should be retained within the new development, in agreement with the Council. As part of any planning application, applicants will need to clearly demonstrate how the proposal will minimise its impact on the site’s intrinsic qualities and where possible enhance the remaining part of the site. Due regard must also be given to any potential impact on the character and wider setting of the site.” 8.12 The criteria used to assess open space in Cambridge are currently set out in Appendix I in the Local Plan. The criteria are summarised below alongside an assessment as to why the criteria are not useful in their current state, highlighted by example with Emmanuel College Sports Ground. CRITERIA FOR ENVIRONMENTAL IMPORTANCE OUR ASSESSMENT a. Does the site make a major contribution to the setting, character, structure and the environmental quality of the city? The site does not make a major contribution. The site is not referenced in the West Cambridge Conservation Area Appraisal in terms of its heritage contribution to the area. The tree line along the western boundary is identified as an important tree group on the Townscape Analysis map in Appendix 3 of the Appraisal, and this tree line can be retained without the need to protect the entire site as open space. The Townscape Analysis map also notes that there are Important Positive Views from the south-western boundary looking to the east and north-east. However, such views can be addressed without the need to protect the entire site as open space. b. Does the site make a major contribution to the character and environmental quality of the local area? The site is inaccessible to the public and is screened by existing trees along the western boundary. c. Does the site contribute to the wildlife value and biodiversity of the city? The accompanying Ecological Appraisal indicates that the site has the potential to accommodate bats, birds and great crested newts. QUESTIONS USED TO ASSESS ENVIRONMENTAL IMPORTANCE OUR ASSESSMENT i. Does it make a major contribution to the setting of Cambridge? ii. Does it have positive landscape features and/or a sense of place sufficient for it to make a major contribution to the character of the city? iii. Is the site an important green break in the urban framework? iv. Does it have significant historical, cultural or known archaeological interest? i. The site does not make a major contribution. ii. The site is not referenced in the West Cambridge Conservation Area Appraisal in terms of its heritage contribution to the area. The tree line along the eastern boundary is identified as an important tree group on the Townscape Analysis map in Appendix 3 of the Appraisal. This tree line can be retained without the need to protect the entire site as open space. The Townscape Analysis map also notes that there are Important Positive Views from the south-western boundary looking to the east and north-east. However, such views can be addressed without the need to protect the entire site as open space. iii. The site does not represent an important green break. The site is inaccessible to the public and is screened by existing trees along the western boundary. Further greenfield land can be found to the south of Emmanuel College Sports Ground and beyond the University Athletics Track. QUESTIONS USED TO ASSESS ENVIRONMENTAL IMPORTANCE OUR ASSESSMENT iv. The site is not referenced in the Cambridge Conservation Area Appraisal as being valuable in terms of its heritage status although it does contain a Grade II listed building. This listed building, however, can still be retained without the need to protect the entire site as open space. i. Does it have positive features such as streams, trees, hedgerows or meadowlands which give it a sense of place sufficient to make a major contribution to the character of the local area? ii. Is it an important green break in the framework of the local area? iii. Does it form part of a network of open spaces in the local area? iv. Is it enjoyed visually on a daily basis from public places (e.g. footpaths, vantage points)? v. Does it have local historical or cultural interest? i. The site does not contain any of these positive features, other than the tree line along the eastern and northern boundary. These can be retained without needing to maintain its designation as a protected open space. ii. The site is not an important green break. It is largely closed off from public access. iii. As above. iv. The site can be viewed along Wilberforce Road. v. The site is not considered to be important in terms of its historical or cultural interest. The site is not referenced in the West Cambridge Conservation Area Appraisal in terms of its contribution in heritage terms. i. Does it have any nature conservation designation? ii. Is it adjacent to or an important link to sites with nature conservation designation? iii. Does it contain important habitats or species sufficient to make it worthy of consideration for any nature conservation designation? iv. Is it an important wildlife oasis in an area with limited wildlife value? i. The site is not designated as a nature site. ii. The site is not adjacent to a nature conservation site. iii. The accompanying Ecological Appraisal indicates that the site has the potential to accommodate bats, birds and great crested newts. iv. The site is surrounded by residential development to the west, north and east. CRITERIA FOR RECREATIONAL IMPORTANCE OUR ASSESSMENT d. Does the site make a major contribution to the recreational resources of the city? The site does not make a major contribution to recreational resources of the city. e. Does the site make a major contribution to the recreational resources of the local area? The site does not make a major contribution to the recreational resources of the local area. The site is located within the Newnham Ward and whilst a detailed assessment of Newnham’s open space provision has not been undertaken, no deficiencies are identified within the Open Space Strategy (2011). It is therefore considered that the loss of the playing field on the site would not lead to increasing deficiencies within Newnham. QUESTIONS USED TO ASSESS RECREATIONAL IMPORTANCE OUR ASSESSMENT i. Is it of a size, quality and accessibility such that people would travel to use it for recreational purposes, no matter where they live, work or study in the city? ii. Is it an important part of the network of significant recreational open spaces? iii. Is it part of the sports provision which help to meet demand from people throughout the city, no matter where they live, work or study? The site has been surplus to requirements since Emmanuel College acquired and secured planning for a much larger playing field at land off Rutherford Road (REF: 08/0873/FUL), which was implemented in 2011. The site is therefore not an important part of the network of recreational open spaces. i. Is it of a size and accessibility such that people who live, work or study in the local area do or could use it for recreational purposes? ii. Is it an important part of the network and hierarchy of recreational facilities in the local area? iii. Is it a significant linkage between recreational areas? The site has been surplus to requirements since Emmanuel College acquired and secured planning for a much larger playing field at land off Rutherford Road (REF: 08/0873/FUL), which was implemented in 2011. The site is therefore not an important part of the network of recreational open spaces. 8.13 As set out above, removing the site’s designation as a Protected Open Space will not lead to the loss of any sports/recreation facilities. ‘Community, Sports and Leisure Facilities’ (Policy 73) Cambridge Local Plan 2018 8.14 Policy 73 of the Cambridge Local Plan (2018) states the following: “The loss of a facility or site that was last in use as a community, sports or leisure facility will only be permitted if it is demonstrated that: i. the facility/site can be replaced within the new development or relocated to at least its existing scale, range, quality and accessibility for its users. For leisure uses, it should satisfy peak period need; or j. the facility/site is no longer needed.’’ ‘’In providing evidence that a facility/site is no longer needed, the guidance in Appendix K of the plan should be adhered to. The redevelopment of school sites for other uses will be permitted only if it can be demonstrated that they are not required in the longer term for continued educational use.’’ 8.15 In terms of the site, criterion j is considered to apply given that the site has been surplus to requirements since 2011 and the facilities are no longer required. Paragraph K.3 of Appendix K requires that: “Proposals for either replacement or relocated facilities should demonstrate: a. equal or improved site accessibility to users by all means of transport including foot and cycle; and b. sufficient spare capacity or agreement to accommodate displaced users at other equivalent community/leisure facilities with similar accessibility for users. For existing leisure facilities, in the absence of a robust district-wide needs assessment/capacity assessment, applicants will be expected to carry out such an assessment at their own cost; and c. through local consultation, the level of interest in and viability of the continued use of the premises as a community/leisure facility.” 8.16 The Open Space and Recreation Strategy 2011 includes an assessment of sites identified on the Policies Map, including an assessment as to whether each site is important for environmental and/or recreational reasons, according to the assessment criteria listed in Appendix I of the Local Plan. It also identifies those wards with deficiencies in open space provision. The Site is referenced to as site SPO 16 in the Newnham Ward profile, comprising 4.02 hectares. The site is assessed as having both environmental and recreational importance. 8.17 An updated Open Space Assessment is required for Cambridge, in accordance with Paragraph 96 of the National Planning Policy Framework (NPPF) which requires the following: ‘’Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate.’’ 8.18 Paragraph 97 of the NPPF requires the following: “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: ● An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or ● 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; or ● The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss. 8.19 NPPF Paragraph 97 is considered to be the basis to assess this policy matter. This Policy sets out three criteria, but these are a series of ‘or’, so only one criterion has to be engaged and compliant. The second criterion is the appropriate test for the development proposal because the open space is considered to be surplus to requirements, with a replacement provision being located at Rutherford Road, Cambridge, which comprises a greater quantity of land used as playing fields. Consequently, this NPPF matter is not reflected in adopted Policy 67. Summary 8.20 Policy 67 requires an overhaul so that it allows for a clearer NPPF para 97 structure and criteria assessment and to remove the 400m restriction, which is too onerous and could prevent a planning judgement being made to account for benefits of a relocation. The assessment criteria to determine whether an open space should be designated is based on PPG17 and should have an overhaul to ensure there is a robust assessment criteria, to underpin the Big Theme around biodiversity and green spaces. By example, Emmanuel College Sports Ground should not be a protected open space; it has only planted boundaries to the west and north; comprises two Important Positive Views based in the southern portion of the site; and is surplus to requirements following the land at Rutherford Road being used as a larger, alternative playing field by Emmanuel College.

No choices made

Response to Question 42 8.2 No single solution will deliver a sound Local Plan; rather, a combination of approaches to the distribution of spatial growth will be necessary in order to establish the appropriate locations of new housing and employment development in the district. A hybrid approach will be required, but underpinned with a focus on transport corridors and accessible areas.

No choices made

Response to Question 7 5.2 The four big themes are all considered to be important aspects to achieving positive development. All four themes should be used to inform the spatial strategy within the Local Plan in terms of distributing growth and determining planning applications to deliver growth. It is therefore not considered necessary to rank the options in order of preference.