Greater Cambridge Local Plan Issues & Options 2020
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New search5.1 Agree - The four big themes for the Local Plan are considered suitable and all are important in the consideration of the spatial distribution of growth in Greater Cambridge, and for the determination of planning applications. 5.2 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 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. The need for homes and jobs remains as does the need to ensure development is viable and can come forward.
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5.4 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 new Local 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. 5.5 A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. 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. 5.6 If the new Local Plan is to achieve its ambitious targets on climate change, the Councils should consider new ways of achieving net zero. It should recognise that seeking to achieve net zero on all sites regardless of their location and site-specific factors may not be feasible. Linked initiatives such as an offsetting scheme, secured through S106 financial contributions, could be an appropriate way of achieving net zero for small and medium developments. As recognised in the NPPF, small and medium developments, with their ability to be delivered early in the plan period at pace, will play an important role in meeting the Councils housing requirements and the needs of existing villages. Such sites may best secure net zero by contributing to an offsite initiative as well as minimising their own carbon dioxide emissions. This can be done through measures such as high insulation standards and the use of solar panels. 5.7 If an offsetting scheme is the preferred mechanism, then the Councils will need to set out a clear, appropriate and practical way to implement this, which will mean identifying strategic off-setting projects with Greater Cambridge, and potentially beyond, in collaboration with other key stakeholders. Any financial obligations towards an offsetting scheme will need to meet the statutory tests and considered in the context of viability. 5.8 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. 5.9 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.
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5.10 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 new Local Plan progresses and must build in flexibility.
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5.11 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new developments. 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. 5.12 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 considered. A policy basis to facilitate off-site biodiversity net gain is essential for smaller and medium sized developments. As recognised in the NPPF, small and medium developments, with their ability to be delivered early in the plan period at pace, will play an important role in meeting housing requirements and supporting existing villages. Such sites may best secure biodiversity net gain by contributing to an offsite initiative. A strategy for the delivery of off-site biodiversity net gain funded through development contributions would allow the Council new green infrastructure and biodiversity habitats to be strategically planned, which in turn, would provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new developments. Nonetheless on-site measures are also possible at many sites such as suitable hedge habitats, green spaces, wildlife corridors and enabling hedgehogs to move freely between plots.
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5.13 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. Development proposals can then be shaped around the identified priorities. As part of a policy framework that allows for off-site mitigation and off-site net gain enhancements can be used to improve the wider green space network.
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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 The Council should develop a strategic offsetting mechanism. This would allow for new green infrastructure and biodiversity habitats to be strategically planned to provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new developments.
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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. 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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5.17 The Local Plan should deliver a spatial strategy that connects homes with accessibility to good quality public transport, facilities and services and high quality green spaces. 5.18 The Local Plan should also establish a policy framework that allows for innovative ways to deliver ‘affordable housing’ across tenure types. Housing mix policies should also be flexible to allow for the right homes to come forward in the right location. 5.19 As stated in our response to Question 2. The proposed sustainable extension at Land East of Boxworth End, Swavesey is an example of how a development can contribute to achieving ‘good growth’. The Site is within walking and cycling distance of a range of services, facilities and public transport modes. Future residents would benefit from easy access to on-site green space, shops and education and community facilities, maximising opportunities for positive influences on their overall health and lifestyle. The proposals also seek to deliver affordable housing which would be tenure blind, providing a significant amount of affordable housing in a sustainable location. These principles should be used to assess the merits of proposed development sites.
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5.20 The community at all levels should be encouraged to engage in the development process to help shape new proposals. Policies and procedures should encourage meaningful consultation and require Parish Councils to engage with developers in advance of planning applications being submitted. 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).
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5.21 New development should include a range of new homes and associated infrastructure which can be accessed and enjoyed by all groups in society. 5.22 To achieve this, the Local Plan should include policies which allow for innovative ways to deliver ‘affordable housing’ across a range of tenure types. It should include a clearer policy framework to support housing for elderly persons. 5.23 New policies should carefully consider the necessary infrastructure to create socially inclusive communities, these policies could cover open spaces, play areas, community buildings, street design, travel management and technology requirements (Wifi, 5g and beyond).
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