Greater Cambridge Local Plan Issues & Options 2020

It is requested that the policies in the emerging GCLP are consistent with national guidance on adapting to climate change.

Natural Cambridgeshire has a vision to double nature by 2050 and has produced a ‘Developing with Nature Toolkit’ to achieve the aim of a net gain in biodiversity through new development. The Toolkit identifies ten actions for nature, which relate to the following: • site selection; • strategic planning and design of developments; • appoint professional ecological expertise; • understand context of development site within landscape and ecological networks; • plan green and hard infrastructure at the same time; provide sustainable drainage systems; undertake an audit of green infrastructure including biodiversity; • demonstrate a clear rationale for landscape design and species selection; • provide the full range of breeding sites, shelter and all year round food resources; and • demonstrate continuity of management of important natural features. It is noted that Natural Cambridgeshire’s vision and toolkit acknowledge the role that development has in supporting the delivery of net biodiversity gain. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding which sites to allocate for development, the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The promoted development at South West Cambridge would include a new country park with potential connections to Coton Countryside Reserve, wildlife areas and strategic landscaping. It would retain and enhance existing ecological features on the site and provide biodiversity enhancement including a new wetland habitat at Bin Brook which, in addition, would also retain floodwater. It is considered that the promoted development would score very well against the nature matrix system in the ‘Developing with Nature Toolkit’. A Preliminary Ecological Appraisal (prepared by The Landscape Partnership) is submitted with these representations.

It is considered that one approach to improving the green space network is to create significant new green spaces within strategic developments. The selection of suitable strategic sites within the emerging GCLP provides an opportunity to create new green spaces that connect with existing spaces and the surrounding countryside; new spaces would provide alternatives to existing green spaces and divert and reduce recreational pressure from those spaces. The promoted development at South West Cambridge would include a comprehensive new green infrastructure network in conjunction with a landscape-led urban extension, including a new country park with potential connections to Coton Countryside Reserve and an extensive green corridor from Cambridge to the surrounding countryside. A Vision Document and Masterplan for the promoted development at South West Cambridge is submitted with these representations.

The response to Question 12 refers to Natural Cambridgeshire’s ‘Developing with Nature Toolkit’, which aims to achieve the aim of a net gain in biodiversity through new development. The Toolkit acknowledges the role that development has in supporting the delivery net biodiversity gain. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The promoted development at South West Cambridge would include new accessible parkland and green infrastructure with potential connections to Coton Countryside Reserve. It would retain and enhance existing ecological features on the site and provide biodiversity enhancement including a new wetland habitat at Bin Brook which in addition would also retain floodwater. It is considered that this approach would result in significant net gain in biodiversity. Cambridge Past Present & Future (CPPF) owns and manages the Coton Countryside Reserve, which involved taking land out of agricultural use to create habitats for wildlife including trees, hedges, orchards and meadows. It is considered that the proposed new wetland habitat within the promoted development at South West Cambridge would represent a continuation of the environmental work that CPPF undertakes at Coton Countryside Reserve; subject to discussions, the consortium behind these proposals would be amenable to the possibility of CPPF taking on the management of the wildlife and countryside areas within the promoted site at South West Cambridge.

Yes, somewhat agree

Yes. It is noted that the existing adopted Tree Strategy is focussed on the protection and management of existing trees and will need to be updated. It is also noted that the Councils are actively promoting small local initiatives to plant additional trees, which is laudable, but is a limited approach and mostly involves public land. It is suggested that significant increases in tree cover is more likely to occur in conjunction with new strategic developments, which requires suitable sites being allocated in emerging GCLP. The promoted development at South West Cambridge would retain the existing trees and hedgerows on the site, and would provide additional hedgerows and woodland planting, street trees, and a new community orchard including fruit trees.

As set out in the response to Question 6 it is suggested that meeting housing and affordable housing needs must be part of the well-being and social inclusion theme of the emerging GCLP, since housing falls within the social objective of sustainable development as contained in Paragraph 8 of the NPPF. There are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities often have to endure longer and unsustainable commuting. Therefore, ‘good growth’ must include meeting housing and affordable housing needs within emerging GCLP by allocating suitable sites that can meet those needs in the most sustainable locations. It has long been recognised by the Councils that the most sustainable locations in the GCLP area are the City of Cambridge and its urban edge, and that these locations are preferable in these terms to dispersed growth including at new settlements. As set out in Paragraph 8 and Chapter 8 of the NPPF the other factors that relate to the wellbeing and social inclusion theme are about creating well-designed and safe developments, providing access to services and facilities, and providing open space. It is suggested that the emerging GCLP will need to allocate suitable sites that are accessible to services and facilities or can provide those facilities on site; the promoted development at South West Cambridge includes a local centre and substantial areas of open space. It is also highly proximate to the City Centre of Cambridge and the wide range of services and facilities available there.

It is anticipated that strategic allocations would be subject to detailed community involvement at supplementary guidance, pre-application, outline application and detailed design stages. It is both normal and good practice to undertake community engagement for large scale developments, and this should continue. The consortium behind the proposals at South West Cambridge would expect to fully consult on their emerging proposals.

Section 4.3.3 of the Issues & Options consultation document identifies the factors that are relevant to the creation of safe and inclusive communities. As set out in the response to Question 16, there are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer and unsustainable commuting. It is considered that the emerging GCLP should be informed by a cogent development strategy that seeks to meet housing and affordable housing needs in full, and which prioritises the location of new housing closer to employment opportunities to assist in reducing unsustainable in-commuting. It should be noted that the examining Inspectors for the Cambridge Local Plan 2018 and South Cambridgeshire Local Plan 2018 acknowledged that affordable housing needs within Greater Cambridge would not be met in full by the development strategy proposed at that time. It was noted that developer contributions would provide for only half of the affordable housing needs in Cambridge (see Paragraph 37 of the Cambridge Inspector’s Report) and that developer contributions would provide for affordable housing needs in full in South Cambridgeshire (see Paragraph 36 of the South Cambridgeshire Inspector’s Report). It should be further noted that the conclusions on whether affordable housing needs in South Cambridgeshire would be met was based on the assumption that all of the strategic sites would provide policy compliant levels of affordable housing, but as set out in the responses to Questions 44 and 46 below the strategic sites at Northstowe, Waterbeach, Cambourne West, and Wing (at Cambridge East) are not providing sufficient or policy compliant levels of affordable housing as intended; on this basis affordable housing needs in South Cambridgeshire will not be met. In addition, it is noted that the strategic developments in neighbouring Huntingdonshire at Alconbury Weald and at St Neots East are also not providing policy compliant levels of affordable housing. Therefore, affordable housing needs are not being met by current development strategies in Cambridge, South Cambridgeshire or in neighbouring Huntingdonshire. It is considered that this outcome is unacceptable in terms of delivering socially inclusive communities and meeting the affordable housing requirements of the area. It is requested that the development strategy for emerging GCLP seeks to meet affordable housing needs in full by allocating sufficient sites that are capable of delivering policy compliant levels of affordable housing.

Paragraph 91 of the NPPF seeks to deliver healthy, inclusive and safe places, and identifies a number of approaches to support healthy lifestyles. It promotes social interaction through mixed-use developments, strong neighbourhood centres, street layouts that include pedestrian and cycle connections, and active street frontages for example. It enables and supports healthy lifestyles, by providing green infrastructure, sports facilities, local shops, access to healthier food, allotments, and layouts that encourage walking and cycling for example. NHS England’s ‘Healthy Towns Initiatives’ identified ten principles to deliver healthy places, which relate to the provision of health services, meeting local and community health needs, and development design matters. In terms of design matters it is suggested that compact neighbourhoods, active travel, healthy eating opportunities, play and leisure facilities would contribute towards the delivery of healthy places. The promoted development at South West Cambridge would be consistent with guidance and initiatives to support healthy lifestyles e.g. it would include open space and recreation areas, a local centre, allotments and a community orchard, as well as numerous walking and cycling routes connected to the wider local existing infrastructure.

Paragraph 103 of the NPPF acknowledges the relationship between managing patterns of growth, reducing the need to travel and encouraging the use of sustainable modes of transport in order to reduce congestion and emissions and improve air quality. Paragraph 181 suggests that traffic and travel management and the provision and enhancement of green infrastructure may provide an opportunity to improve air quality. It is considered that the selection of suitable development sites in emerging GCLP will be an important factor in improving air quality. For example, development sites which are accessible by walking, cycling and public transport would enable travel by sustainable modes of transport leading to reductions in congestion and emissions. The promoted development at South West Cambridge provides an opportunity to locate development where travel by walking, cycling and public transport are realistic, and the site would connect with planned sustainable transport infrastructure improvements. An Air Quality Constraints Report (prepared by WSP) is submitted with these representations, which concludes that development at the site would be acceptable in terms of air quality, and a buffer with the M11 is included in the submitted Masterplan.