Greater Cambridge Local Plan Issues & Options 2020

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Form ID: 49236
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

National Planning Policy states that good design is a key aspect of sustainable development, creating better places in which to live and work, and more support for development among communities. The Local Plan should include for a policy framework that sets out a positive strategy for the conservation and enjoyment of the historic environment. New development within or in proximity to heritage assets can be appropriate and make a positive contribution to local character and distinctiveness. This is supported by the NPPF (paragraph 185). A Concept Vision has been prepared for the Site, this together with future detailed masterplan, will taken into account the context of the site in order to suggest a layout that would sensitively respond to the context of the site. A design-led new community of the scale proposed will allow ensure that new development is well design and can positively contribute to local character and distinctness.

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Form ID: 49237
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

New development can provide opportunities for improvements in the quality of the historic environment. For example, the setting of heritage assets often has elements that detract from the significance of the asset. However, it will be important for the Local Plan to balance heritage protection with the demands of growth and proposals affecting heritage assets should continue to be required to include for an assessment of significance of any heritage assets affected.

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Form ID: 49238
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

‘Place-making’ – creating and sustaining a positive and distinctive character in an area – is important to the economic success of the Greater Cambridge area, as identified by the CPIER. This is also supported by the NPPF (paragraph 124) which confirms that good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities. The NPPF continues by advising that plans should set out a clear design vision and expectations and design policies should be developed with local communities so they reflect local aspirations. To provide maximum clarity about design expectations at an early stage, plans or SPDs should use visual tools such as design guides and codes. The Cambridgeshire Quality Charter for Growth sets out core principles of the level of quality to be expected in new developments in Cambridgeshire and the four ‘C’s’ of Community, Connectivity, Climate and Character align well with the four big themes of the emerging Local Plan. This forms a good basis to set out a design vision for the new Local Plan.

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Form ID: 49239
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

Nothing chosen

National policy requires Local Planning Authorities to support development that builds on economic growth, increases productivity and where development builds on a location’s strengths. The National Planning Policy Framework (NPPF)1, paragraph 7 confirms that the purpose of the planning system is to contribute to the achievement of sustainable development. One of the three overarching objectives intended to contribute towards sustainable development, as set out in paragraph 8, states: “An economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure.” Chapter 6 of the revised NPPF specifically deals with the need to build a strong competitive economy. Paragraph 80 states: “Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.” Cambridge has a recognised role in delivering the UK Industrial strategy. Particularly it can help increase UK GVA growth through higher productivity as well as employment growth. Cambridgeshire and Peterborough Industrial Strategy supports the UK Industry Strategy. It looks to leverage the strengths of the Cambridge cluster, support the Cambridge innovation system, continue to attract international firms and support the expansion of high growth companies. Economic growth projections for Greater Cambridge have come under scrutiny with the Cambridgeshire and Peterborough Independent Economic Commissions (IEC) providing evidence in their report (CPIER) suggesting official statistics under represent past levels of economic growth in the region and have projected them forward, thereby underestimating future employment growth. To meet C&PCA target of doubling GVA by 2041, a significant increase in growth in both employment and productivity is required in Greater Cambridge. This in turn will require a step change in the level of both office and industrial premises to accommodate this growth. 1 MHCLG. February 2019. National Planning Policy Framework. The emphasis on clean growth places a responsibility on planners to make the most of locations, benefiting from rail infrastructure and active travel opportunities. Investment in low energy buildings is also key to improving energy productivity. Economic Growth is essential to Greater Cambridge and the surrounding area as identified by CPIER (Cambridgeshire and Peterborough Independent Economic Review). As part of the devolution contract to Cambridgeshire and Peterborough is a commitment to doubling the economic output of the area (Gross Value Added) over 25 years. This target needs to be at the heart of the Plan.

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Form ID: 49240
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

The Local Plan needs to ensure that there is sufficient land for business uses, in the right places and to suit different business types and specific business clusters. The Local Plan should recognise that employers come in a range of sizes, from start-ups with a few individuals to major firms with hundreds of employees, and the area needs to have the right range of premises to support these varied needs. As recognised in the Issues and Options consultation document, while technology is important to the local economy, other types of industry and agriculture also play an important role and ensure a variety of jobs for local people. To ensure a broad economic basis, it is essential that a range of business and industrial space is provided. This should include space for start ups (for those business in the early stage of a new business), Incubator (providing start-up and scale-up space for companies, including support and services) and grow-on space (premises suitable for small growing businesses). The plan should be flexible to adapt to changing working practices and respond quickly to opportunities for specialist space.

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Form ID: 49241
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

Locations with high levels of public transport access should be identified for businesses with high employment densities. This would include sites within walking distance of train stations, travel hubs and along transport corridors. “by ensuring good quality public transport is in place before development, the number of those new residents who will use the transport is maximised. This is also likely to be the best way to stretch some of the high-value businesses based within and around Cambridge out into wider Cambridgeshire and Peterborough. These companies will not want to be distant from the city, but these clusters could ‘grow’ out along the transportation links, providing connection to other market towns.” 2 The new community proposed at the Six Mile Bottom Estate would provide for jobs and homes significantly reducing the need for car journeys. The proposal is for a balanced job ratio of 2 CPIER p41 approximately one job per household, this level of internalisation of job creation will significantly aid to achieving zero carbon. The Vision capitalises on: ● The Site's locational advantage in respect of Cambridge’s established high tech business locations and its associated supply chain, as well as The Fens micro and agritech businesses; ● Its emphasis on delivering fast and convenient public transit / mobility through rail, road and CAM; ● The compact and critical mass of its resident population creating a Natural Capital approach to capturing the growing home-work / flexible workplace opportunities, and; ● An ability to deliver a zero carbon living and working environment in part through significant on-site renewables. We anticipate these unique qualities will support significant job growth and new employment facilities at Six Mile Bottom for: ● The high tech sector; ● Establishing an Agri/Equine Tech ‘launchpad’; ● Create significant advance of home-work hubs; ● Co-working and flexible working centres; as well as, ● Providing strategic space for supply chain and emerging technologies that would benefit from the locational benefits. Whilst this approach to jobs is specific to the established and emerging work sectors, it importantly creates the conditions for new businesses, start ups and grown on space to succeed, and critically provides the mobility, energy and community infrastructure to deliver a zero carbon living and working community.

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Form ID: 49242
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

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 (NPPF Para. 59). The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: there is a growth strategy in place to promote and facilitate additional growth; strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and, an authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met

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Form ID: 49243
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

Nothing chosen

While the Government’s National Planning Policy Framework (NPPF) makes clear that the minimum number of homes a plan-making authority should plan for should be calculated using the Local Housing Need Standard Method (LHNSM), the presumption in favour of sustainable development and the tests of soundness still require an objective assessment of need (OAN) to determine if a higher number of homes should be targeted. This OAN for housing should be based on demographic need and housing market signals. However, in a rapidly growing economy, such as Greater Cambridge, it is impossible to ignore the demand for housing generated by the incoming workforce. The alternatives would be to either stymie that economic growth or accept increased inflow of commuters; neither of which are compatible with the presumption in favour of sustainable development, or the Government’s aspirations for the Cambridge – Oxford Arc. To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to being a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that if there is an insufficient supply of housing, the economic growth plans will not be realised. The role of housing in attracting and retaining skilled employees is widely recognised and should be adequately address in the Plan. There is a well-evidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”3 The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. It identifies a need for at least 2,900 per annum within this Local Plan. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to be a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that, if there is an insufficient supply of housing, the economic growth plans will not be realised. The role of 3 Cambridgeshire and Peterborough Industrial Strategy 2019, p13 housing in attracting and retaining skilled employees is widely recognised and should be adequately addressed in the Plan. If the economic growth of the area is to be facilitated through increased commuting from beyond the sub-region, then the goal of zero carbon and balancing health and wellbeing will not be achieved. 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 indicated by the Standard Method.

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Form ID: 49244
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

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. Flexibility will be key to a successful Local Plan; through market housing, low-cost and affordable housing. The Government is committed to building a housing market and recognise that for too many people homeownership is unaffordable. The Local Plan should seek to facilitate home ownership and support established, new and innovation routes into home ownership. Appropriately worded design policies should require a high-quality design for new developments. 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.

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Form ID: 49245
Respondent: L&Q Estates Ltd and Hill Residential Ltd
Agent: Guy Kaddish

L&Q Estates Ltd and Hill Residential Ltd have vast experience of promoting and delivering sites for high quality new communities. The Council’s ambition for the Local Plan to ensure that high quality developments and homes are delivered aligns with the values of the promotors and the development of the Site would contribute to the delivery of high-quality housing across the area.

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