Question 4. Do you agree that planning to 2040 is an appropriate date in the future to plan for? If not, what would be a more appropriate date and why?
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On behalf of Southern & Regional Developments (Swavesey) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date and coers the minimum time frame. The timescale of any plan should however alsoo respond to long-term requirements and opportunities including major improvements to infrastructure It is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond this proposed plan period so that a sustainable strategic approach is adopted that has longevity. This is demonstrated by the strategic plan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positely to address the associated strategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040, whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adopts. Major infrastructure projects that will provide for long term requirements have already been identified at the New Towns of Northstowe and Waterbeach. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Swavesey must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Boxworth End can demonstrate such deliverability as an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing for beyond this period too.
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4.18 In general terms, Local Plans are encouraged to look forward at least 15 years when setting strategic policies as set out in paragraph 22 of the NPPF. The emerging Local Plan seeks a period of 20 years up to 2040. Given the period required through to adoption, we consider this date to be a reasonable and realistic light-time for the Plan. 4.19 That notwithstanding, and in order to respond to long-term requirements of particular uses and major improvements in infrastructure of which there are few in the region i.e. the A14 improvements, the Oxford, Milton Keynes and Cambridge Arc and the Cambridge to Norwich technology corridor, it is considered that the Local Plan should provide sufficient flexibility to respond for business and industry locational and demand changes that may result and in line with up-to-date market and needs assessments for all uses.
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This and any future Local Plan must take account of National Statutory and Interim Climate Change targets (2050 Net Zero and 2030 Clean Growth Strategy respectively) including those for all existing buildings. The Plan’s 2040 target is an appropriate date to consider both the 2050 and 2030 targets – but neither are considered credibly in this consultation. Focused research is needed to assess the implications of these targets for Greater Cambridge, and to identify the key issues and choices arising from them. These will be fundamental for the Plan.
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European Property Ventures (Cambridgeshire) agree that planning to 2040 is an appropriate timescale for the plan. The NPPF states that plans should look ahead for at least 15 years from the point of adoption, which suggests that 2040 is an appropriate end date. The timescale of any plan should be able to respond to long-term requirements and opportunities including major improvements to infrastructure It is directed however that it is imperative for the Council to deliver sufficient housing to cover this extended plan period and address future needs in full. As such, the emerging plan must also seek to plan for needs and strategic growth beyond thi proposed plan period so that a sustainable strategic approach is adopted that has longevity. Thi is demonstrated by the strategic lan for the Great Cambridge areas that is considering infrastructure delivery up to 2050. As such the emerging plan must consider the requirements over this period and plan positely to address the ssocaited astrategic requirements, even if the plan will be reviewed in full at 2040. The ability for the plan to adopt the timescale to 2040 whilst addressing strategic requirement up to 2050 must mean that the plan's approach should be aspirational and not be constrained by the time period it adoptes. Major infrastructure projects that will provide for long term requirements have already been identified at the New Towns of Northstowe and Waterbeach. Whilst the value of strategic sites such as these is identified within NPPF, Paragraph 72 emphasises that realistic lead-in times must be incorporated into a spatial strategy to ensure that the delivery of these sites remains practical in realising the housing trajectory. As such the importance of small and medium sites are identified in Paragraph 68 of NPPF as these sites can robustly contribute to housing numbers given the relatively rapid build out times. The expansion of Development Frameworks of sustainable villages such as Oakington must be recognised as a method of deliverying a boost of housing that would contribute toward sustaining the housing trajectory. The promoted site at Dry Drayton Road, Oakington can demonstrate such deliverability as an important contribution to assist in meeting the demanding housing needs for Greater Cambridge whilst complementing the delivery of strategic infrastructure. Summary of Comments: 2040 is an appropriate date in future to plan for however the Council needs to ensure it delivers sufficient housing to cover this period.
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4.1 Agree. 4.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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2050 would be a more appropriate date. This plan is being prepared with undue haste. The current South Cambs. Local Plan was only signed off in 2019 and runs to 2031. By taking this plan out to 2050, there will be more time to consider it carefully and there will be much better information available about the effects of climate change on our county and City. This information is critical to the county and the City with current projections of sea level rise by the end of the century varying between 1.1 mtrs (IPCC) and 4.7 mtrs (Climate Central).
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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We suggest that the data from the 2021 Census will be important since so much has changed since 2011; a base date which is often quoted in your documents. You should examine the choice of 2040 against the likely availability of census data.
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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We agree that 2040 is an appropriate date to plan for delivery of housing on the basis that the minimum housing and employment needs are already set out – i.e. minimum 41,000 new homes between 2017 and 2040, potentially increasing up to 66,700 to rebalance new housing against jobs growth. The current uncertainty about the Oxford-Cambridge expressway and other national infrastructure projects that are being explored, but are not yet committed, should be considered but should not overly influence the plan for this review. We consider there should be a clear mandate to consider the complementary 2050 vision that may give rise to an additional growth in terms of how sites that would already meet the NPPF objective of delivering sustainable development can be readily extended to meet further housing requirements from 2041-2050.
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While the aspiration to plan for a twenty-year period is welcomed, CUH advocates considering developing a plan with a longer term time horizon, to ensure the co-ordinated planning of the area for the long term. Given the significant level of growth envisaged in Cambridge City and South Cambridgeshire, CUH considers that the plan should seek to guide development up to 2050 and so align with the anticipated delivery of our long term vision, the 2050 vision for the Cambridge Biomedical Campus (CBC) due in Summer 2020 and to align with potential delivery of major strategic sites that may come forward during the plan period. It would also allow planning on a longer time horizon having regard to planned infrastructure projects, including those promoted by the Cambridgeshire & Peterborough Combined Authority (such as the Cambridgeshire Autonomous Metro) and the Greater Cambridge Partnership (e.g. Cambourne to Cambridge, South East Transport Corridor). It is recognised that communities are concerned about such matters as green belt release, and by setting a longer term growth horizon, would allow the Greater Cambridge Planning Service to make longer term decisions about the future role of Cambridge, to help inform decisions on such matters as Green Belt, the special qualities of Cambridge and South Cambridgeshire, how they should be protected, whilst also stimulating growth through infrastructure, housing and the economy. Clear long term growth plans will also ensure other infrastructure (including health) can be developed as part of a long term strategy for the area .An end date of 2050 would also align the Plan with the UK government’s commitment to be net zero carbon by 2050
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While the aspiration to plan for a twenty-year period is welcomed and in line with the National Planning Policy Framework, CUHP would consider developing a plan with a longer term time horizon to 2050 given the significant level of growth envisaged in Cambridge City and South Cambridgeshire. This would ensure the co-ordinated planning of the area for the longer term, while also aligning with potential delivery of major strategic sites such as North East Cambridge, any development of Cambridge Airport or other new settlement proposals should they be necessary. It would also allow planning on a longer time horizon with regard to planned infrastructure projects, including those promoted by the Cambridgeshire & Peterborough Combined Authority (such as the Cambridgeshire Autonomous Metro) and the Greater Cambridge Partnership (for instance Cambourne to Cambridge, South East Transport Corridor). Clear long-term growth plans will also ensure other infrastructure (including health) can be developed as part of a long-term strategy for the area. Further, it is recognised that communities are concerned about such matters as Green Belt release. Setting a longer term growth horizon would allow the Greater Cambridge Planning Service to make longer term decisions about the future role of Cambridge, to help inform decisions on such matters as Green Belt, the special qualities of Cambridge and South Cambridgeshire and how they should be protected, whilst also stimulating growth through infrastructure, housing and the economy. Finally, a CBC Strategy Group with representation from all campus organisations has agreed to develop a Vision 2050 for the CBC. Subject to ratification by the CBC Strategy Group, this will be shared with the Greater Cambridge Planning Service by summer 2020 to define the extent, scale and location of development proposed throughout the timescale of the next Local Plan, and the anticipated number of jobs to be supported by the CBC by 2050.
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3.1.1 Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the National Planning Policy Framework (NPPF) for local authorities to identify strategic policies looking ahead over a minimum 15 year period from Plan adoption, to anticipate and respond to long-term requirements and opportunities, making sufficient provision for housing, employment, retail, leisure and other commercial development (Para.’s 20, 22).
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3.1 Paragraph 22 of the National Planning Policy Framework (NPPF) requires Local Plans and strategic policies to plan for a minimum period of 15 years from the date of adoption of the Local Plan. 3.2 Figure 5 of the Issues and Options document outlines the Councils ambition to adopt the new Greater Cambridge Local Plan (GCLP) in Summer 2023. Working off this estimate the Plan would need to cover up to 2038 as a minimum. Given the that the Plan is proposed to run to 2040 there is some flexibility to allow for any delays in the plan preparation process. 3.3 Notwithstanding the above, it is recommended that the Council retains a flexible stance on the potential Plan period until later stages of the plan preparation process sufficient to allow for any future delays. This recommendation is based on the previous experience of South Cambridgeshire District Council, whereby it took six years for the Local Plan to move through the process from the Issues and Options stage through to formal Adoption. In addition to this, the Cambridgeshire and Peterborough Strategic Spatial Framework (CPSSF) sets out a longer-term growth strategy to 2050, and so the Councils may also want to consider extending the Greater Cambridge Local Plan (GCLP) period to correspond with this. 3.4 In our assessment the need to maintain a flexible approach in these early stages of the plan preparation is also influenced by other external factors, such as, the announcement and delivery of major infrastructure projects in the region. These projects and estimated delivery timetables are set out below: - The A14 road improvements between Huntingdon and Cambridge. Expected completion date December 2020. - A new railway station close to Addenbrookes Hospital to the south of the city centre. Expected completion date 2025. - The duelling of the A428 between Black Cat Roundabout and Caxton Gibbet. Expected completion date 2026. - Cambridge Autonomous Metro route. Expected delivery of the core infrastructure by 2029. It is estimated that the delivery of the Metro route could create 100,000 new jobs and the opportunity to deliver 60,000 new homes in Cambridge and the wider region. - The delivery of East-West rail, which includes a Phase 3 link running between Bedford and Cambridge. Expected completion date 2030. As with the Black Cat to Caxton Gibbet A428 road improvements, the delivery of East-West forms key elements of Oxford-Cambridge Arc which will unlock the 1 million new homes by 2050. 3.5 These major infrastructure improvements will influence the level and spatial distribution of growth in Cambridge City and South Cambridgeshire. Projects of this scale and cost are often subject to delay or changing delivery timescales, on this basis, it is essential that the Councils adopt a flexible approach to determining the time period for the new GCLP. Moving forward the Councils will need to ensure that the Plan is capable of responding to the changing infrastructure needs of the area and how this could potentially impact upon the level growth required and the need to deliver sustainable development which reduces the need to travel by private car.
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Neither agree nor disagree. Whilst we neither agree nor disagree with the proposed plan period to 2040, we are in agreement with the Councils that it is imperative there is flexibility with the strategy to ensure a balance is struck “between planning far enough ahead to make informed decisions about growth and the reliability of long-term future predictions for housing and jobs”. We therefore suggest a date for a review of the Plan is incorporated to ensure it is delivering what is required and is able to respond to changing circumstances.
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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2.11. The Planning Practice Guidance states: “…The National Planning Policy Framework requires strategic policies to look ahead over a minimum 15 year period from adoption, although authorities are required to keep their policies under review…” (Paragraph: 012 Reference ID: 2a-012-20190220). 2.12. It is acknowledged that both the adopted Cambridge City Local Plan (2018) and the adopted South Cambridgeshire Local Plan (2018), include policy commitments to undertake an early reviews of the respective Local Plans to commence before the end of 2019 with submission taking place by the end of Summer 2022. 2.13. A Greater Cambridge Local Development Scheme has been produced (as updated in November 2019) which identifies the key stages of the emerging Greater Cambridge Local Plan. A further Draft Local Plan (Reg 18) is to be published in Autumn 2020 and the Regulation 19 Proposed Submission Local Plan is due to be the subject of consultation in Autumn 2021. The Councils anticipate adoption of the emerging Local Plan in Summer 2023. 2.14. In light of the Council’s anticipated timescales, the emerging Local Plan could be adopted in 2023 and would therefore policies it would contain would have 17 year longevity, exceeding the minimum requirement for a 15 year longevity is supported. The additional flexibility allows for potential delays at Examination stage. 2.15. The Plan makes sensible assumptions about the timescales to be considered for growth. There will be substantial change in the period to 2040, including those relating to the carbon zero agenda and the development of new public transport schemes, but this length of time is necessary both to meet the requirements of the NPPF and to properly consider how strategic infrastructure will work.
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The logic behind the proposed end date of 2040 is broadly supported. However, given that the end date of the existing plans is 2031 and given the strategic context being provided by the Combined Authority’s Non-Statutory Spatial Framework to 2050 and the delivery timetable for currently envisaged infrastructure and employment/housing growth it is considered that a plan that only adds nine years to the current framework is perhaps failing to address the longer strategic context for this plan period. In addition, NPPF para 22 advises that strategic policies should look forward over a minimum of 15 years. The suggested program for adoption of the Joint Plan by September 2023 is challenging and any slippage could result in a plan that is already on the 15-year minimum at date of adoption. For this reason, 2043 is suggested.
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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4.1 Agree - The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67). 4.2 As recognised, Greater Cambridge falls at the crossroads of a number of key economic corridors, including the Oxford-Cambridge Arc, London-Stansted Corridor and the Cambridge-Norwich tech corridor. The Oxford-Cambridge Arc in particular is a key economic priority as recognised by Central Government. Further work on the delivery of these initiatives will take place including the need for cooperation between authorities and stakeholders. 4.3 It is imperative that the New Local Plan has flexibility to allow for additional growth to come forward to meet the needs of this important initiative as it develops through cross boundary and national discussions take place, potentially within the early/mid stages of the plan period.
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The NPPF requires that strategic policies should have a minimum 15 year time horizon on adoption. There is considerable merit in strategic policies looking beyond this time period to 2050. The development plan system provides for policies to be reviewed every 5 years and hence if there are significant changes in circumstances that would be picked up during a review of strategic policies and trigger an updating of the plan. Planning to 2050 would provide a clear direction and base and would simply mean that in future the plan making process can focus on allocating land to meet agreed development needs, rather than revising and debating growth levels. That would greatly speed up plan making. We also consider there is a practical reason to look further ahead. The local plan will need to be adopted by March 2025 to provide a 15 year horizon to 2040. Experience suggests that such a timetable will be challenging and may not be achieved. It would be disappointing to get close to adoption only to find that there will not be a 15 year time horizon on adoption and hence further work required, delaying adoption further. We consider it would be prudent therefore to plan to 2050.
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The Greater Cambridge Planning Authority’s ambition is to submit a new Local Plan for examination by 2022. Given the complexities of the planning issues associated with Greater Cambridge and its future development, it is reasonable to assume that the examination process will not be straightforward. The original Local Plans were submitted in 2014 and were not adopted until 2018 and even then, were subject to a commitment to an immediate review. While the new Local Plan will be based on a lot of the adopted Local Plan work, a pragmatic time table for adoption from submission would be a minimum two year period resulting in adoption in 2024 at the earliest rather than 2023 as suggested. Paragraph 67 of the NPPF requires planning policies to identify specific deliverable sites for the first five years of the plan period and specific, developable sites (or broad locations for growth) for years 6 to 10 and where possible for years 11 to 15 of the plan period. The plan should therefore cover a minimum period of 15 years from adoption, if future development is to be based on a genuinely plan lead approach. While the currently adopted Local Plans may provide some certainty, subject to housing delivery and five year housing land supply issues, for the first five years, i.e. 2018 to 2023, the new Local Plans should follow on for the next 15 years, i.e. up to 2038 as a minimum. If as set out above the reality is that the new Local Plan is not adopted until at least 2024, 15 years on would take it to 2039. It is therefore concluded that a plan period to 2040 is an appropriate plan period, in particular having regard to climate change and the imperative to take action now. However, the plan needs to be visionary looking forward beyond 2040 in particular having regard to the Greater Cambridgeshire non statutory plan which covers the period to 2050 and the Government’s commitment to reach Net Zero Carbon by 2050. The plan needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the plan area. Summary of Comments: We agree that the plan period to 2040 is appropriate although the plans vision should be beyond 2050.
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We regard it as important for this Plan to be strategic in nature, encompassing the measures required to meet the Climate Change challenges alongside our priorities in meeting the public’s expectations for growth, jobs, homes, health and well-being. That strategic focus should therefore extend to 2050, in line with national objectives, and in coordination with the Combined Authority’s non-statutory spatial strategy. Recognising the difficulty in extending the specific requirements, eg for a five-year supply of new homes, to 2050, we would advocate a distinction between the strategic principles-based plan through to 2050, and the detailed and more site-specific plans, which would extend to 2040. This would mean that the subsequent Plan updates would not reopen the principles of the Plan or its’ priorities, but would focus on zonal allocation and site selection; with a greater degree of predictability in the extended period. In this Plan, too, whilst we recognise that the availability of base data may require it to be based on 2017, we would look for the Plan to be explicit that it would not expect the policies to impact upon planning decisions prior to its’ submission for examination.
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The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).
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3.86 Planning for a 20 year period time scale allows for recognition and appreciation of some of the longer term strategic issues facing the region. However, being able to create certainty beyond the 15 year time period on issues such like housing is more challenging and difficult. Technology will also change immensely over this period so we cannot be certain that the mobility solution for today will be suitable in 20 years’ time. 3.87 The National Planning Policy Framework (NPPF) is clear that strategic policies should be prepared over a minimum 15 year period and a local planning authority should be planning for the full plan period. This is particularly relevant to the Greater Cambridge area where major improvements in infrastructure are likely to happen in that period and there is a need to anticipate and respond to them. 3.88 Grosvenor and USS broadly agree that this plan period is an appropriate response to the Government’s guidance on meeting housing needs. Even though a plan period to 2040 is supported, the importance of regular reviews at least every five years in accordance with paragraph 33 of the Framework should be adhered to. Such reviews will be important in ensuring that the Plan remains relevant to local circumstances and able to effectively guide the long-term growth and development of the Greater Cambridge area. We note that the above plan period is based on adoption of the Local Plan in 2023, and would suggest that the plan period is reviewed if the timeframe for the preparation of the Local Plan Review were to slip.
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3.86 Planning for a 20 year period time scale allows for recognition and appreciation of some of the longer term strategic issues facing the region. However, being able to create certainty beyond the 15 year time period on issues such like housing is more challenging and difficult. Technology will also change immensely over this period so we cannot be certain that the mobility solution for today will be suitable in 20 years’ time. 3.87 The National Planning Policy Framework (NPPF) is clear that strategic policies should be prepared over a minimum 15 year period and a local planning authority should be planning for the full plan period. This is particularly relevant to the Greater Cambridge area where major improvements in infrastructure are likely to happen in that period and there is a need to anticipate and respond to them. 3.88 Grosvenor and USS broadly agree that this plan period is an appropriate response to the Government’s guidance on meeting housing needs. Even though a plan period to 2040 is supported, the importance of regular reviews at least every five years in accordance with paragraph 33 of the Framework should be adhered to. Such reviews will be important in ensuring that the Plan remains relevant to local circumstances and able to effectively guide the long-term growth and development of the Greater Cambridge area. We note that the above plan period is based on adoption of the Local Plan in 2023, and would suggest that the plan period is reviewed if the timeframe for the preparation of the Local Plan Review were to slip.
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29. We agree that planning for the period up to 2040 is appropriate. As part of this plan period, a range of Sites need to be allocated starting with those immediately available in years one to five of the plan period, followed by developable sites and broad locations for growth for years 6-10, 11-15 and, where possible, beyond. 30. The U&I site is available now to provide in excess of 250 additional homes for Cambourne West as well as employment and retail uses to support the new homes and the Cambourne Business Park. The further land to the west of A1198 and south of Cambridge Road (A428) provides an opportune Site for allocating a broad location for growth within the new plan period.
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