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?
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. 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. Grosvenor 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, it is essential that there should be regular reviews at least every five years in accordance with the legal requirement under Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012 and 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.
No uploaded files for public display
Yes. Planning to 2040 adheres to paragraph 22 of the NPPF and the requirement for strategic policies to look ahead over a minimum 15 years from adoption. It is reasonable to expect that by 2025 this Local Plan would be examined and adopted.
No uploaded files for public display
19. 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. 20. Land to the south of Cambourne provides an opportunity for allocating a broad location for growth within the new plan period.
No uploaded files for public display
3.1 Paragraph 22 of the National Planning Policy Framework 2019 (NPPF) states that strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. The proposed plan period up to 2040 will meet this minimum requirement, subject to the plan being adopted by 2025; this should be closely monitored as the preparation of the plan progresses. 3.2 However, there are several national and regional strategic spatial strategies and policies e.g. the Combined Authority’s Non-Statutory Spatial Strategy, the national requirement to achieve target net carbon zero by 2050 and the economic potential of the Cambridge-Oxford Arc, which look forward towards 2050 and will still be evolving during the course of the plan period. Therefore, the new Local Plan needs to build in sufficient flexibility to respond to these changes. 3.3 Moreover, it is imperative that the new Local Plan has flexibility to allow for additional growth to come forward to realise the potential of the economic corridors as they develop through cross boundary and national discussions, potentially within the early/mid stages of the plan period. Mechanisms, such as triggers for an early review of the Local Plan, should be explored.
No uploaded files for public display
A. Whilst we agree that planning for the period up to 2040 is appropriate, in accordance with Paragraph 67 of the NPPF, it is more important for plans to identify a supply of specific, deliverable sites for years one to five of the plan period. Following this, the NPPF directs that specific, developable sites or broad locations for growth should be identified for years 6-10 and, where possible, for years 11-15 of the Plan. Therefore, it is clear that more focus should be placed on years 1-5 of the plans than years 15+. B. When planning for the shorter term, it must be acknowledged that medium and smaller sites are often best placed to come forward quickly (in years 0-5 years). This is because, like our Site, they are typically not constrained by multiple land owners, viability issues or delays in progressing detailed design. As such, these smaller, well located sites must be allocated now, as part of the development strategy, to provide an immediate and robust supply of sites for years 1-5 of the Plan. Larger allocations may then be more appropriate for long-term growth for years 11 onwards.
No uploaded files for public display
Q4: 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? 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.
No uploaded files for public display
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.
No uploaded files for public display
2.06 We agree that 2040 is an appropriate date in the future to plan for.
No uploaded files for public display
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).
No uploaded files for public display
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 (paragraph 67).
No uploaded files for public display
"We would suggest a plan period of 15 years from the date of adoption of the new local plan, as advised by paragraph 22 of the NPPF. If that is what the two planning authorities have in mind, then it is disappointing to note that it is expected to take 5 years for a new plan to be adopted? We do not fully understand, and it is not explained, why the start date is 2017, especially as the current Local Plans were not adopted September 2018. This should be set out in the next stage of the Local Plan. The plan should also include appropriate mechanisms to allow early reviews of the plan if there is a shortfall in housing delivery or significant economic changes."
No uploaded files for public display
"We would suggest a plan period of 15 years from the date of adoption of the new Plan. If that is what the authorities have in mind, then it is disappointing to note that it is expected to take five years for a new Plan to be adopted. We do not fully understand, and it is not explained, why the start date is 2017. This should be set out at the next consultation."
No uploaded files for public display
"4.5 The councils are anticipating adoption in 2023. Having regard to the current timescales and work required prior to adoption , this would only leave 17 years up to 2040 for the plan period. The climate change strategy also refers to net zero by 2050, 10 years beyond the plan period. Paragraph 22 of the NPPF states a Local Plan should cover a minimum period of 15 years from adoption. 4.6 There are also significant areas of growth identified in the Plan including the Oxford/Cambridge Arc. This scale and nature of development is of a strategic nature and the plan period may not be sufficient to ensure delivery within this timeframe. There is already an acknowledgement that if the level of growth continues at current levels, a review of housing/employment numbers would need to take place during the plan period. If a longer plan period is not considered appropriate, it is essential that the Plan is flexible to change and allow further allocations of land to meet the needs identified. If this does not occur, the level of growth will either be restricted or led by appeal."
No uploaded files for public display
"[Note for the reviewer: we will send a PDF copy of all our responses, attached to an email, that is easier to read; if you need help finding referenced papers please get in touch] Please take careful consideration of the contributions from Camcycle and include them in ongoing development on the Local Plan. In addition to widespread consultation, you should be hosting workshops on specific topics, and bringing in expertise from the local community regarding matters such as cycle parking design."
No uploaded files for public display
· Given that a climate emergency has been declared by both the South Cambridgeshire District Council and the Cambridge City Council we urge them to take swift action to transition the Cambridge region to sustainable transport including cycling. · Local Plan strategies for cycling and public transportation (which include understanding where and how new developments should be located and designed) must assume a radical shift away from cars well before 2040.
No uploaded files for public display
Yes. Planning to 2040 adheres to paragraph 22 of the NPPF and the requirement for strategic policies to look ahead over a minimum 15 years from adoption. It is reasonable to expect that by 2025 this Local Plan would be examined and adopted.
No uploaded files for public display
Disagree – whilst the NPPF requires that strategic policies should have a minimum 15 year time horizon on adoption, there would be 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 Given the issues at stake and the length of time it has taken for local plans in the area to be adopted, there is a risk that the plan may not be adopted by April 2025. In order to minimise risk of delays, it would be appropriate to look further ahead. A plan period to 2045 would also provide a clearer strategy for investment decisions of both the public and private sector and enable the longer-term planning of infrastructure
No uploaded files for public display
We do not dispute that planning for the period up to 2040 is appropriate. However, in accordance with Paragraph 67 of the NPPF, it is more important for plans to identify a supply of specific, deliverable sites for years one to five of the plan period. After this, developable sites or broad locations for growth should be identified for years 6-10 of the Plan and, where possible, for years 11-15 of the Plan. 45. As such, it is clear that there should be a focus on allocating sites for delivery in years 1-5 of the Plan rather than planning for up to 2040. Medium and smaller sites, such as our Site, are best placed to come forward quickly (in years 0-5) as typically, they are not constrained by multiple land owners, viability issues or delays in progressing detailed design. As such, these smaller, well located sites must be allocated now to provide an immediate and robust supply of sites in the short-term.
No uploaded files for public display
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).
No uploaded files for public display
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.
No uploaded files for public display
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).
No uploaded files for public display
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).
No uploaded files for public display
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. 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. 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.
No uploaded files for public display