Question 51: Generic Question
Some Key Issues Not Addressed by the Consultation: In seeking to formulate our responses, Cambridge Past, Present & Future believes that certain fundamental issues have either been ignored or assumed. As these have an influence on the strategic thinking behind any responses, we feel the consultation is deficient in that it gives little or no recognition to the importance of these issues. 1. Lack of any Clear Vision of the Future: The consultation fails to set out any clear vision for Greater Cambridge for 2040 and beyond. What sort of place do the Councils want Greater Cambridge to grow into over the next two decades? How do they envisage Greater Cambridge looking for residents at the end of the Plan period? Without any vision of the future, it is difficult to judge the merits, or failings, of the various options for the spatial development of the area. For example, how can we assess the relative merits of development around the City fringe as opposed to development along Transport Corridors or beyond the Green Belt in South Cambridgeshire if there is no clear statement of what sort of city Cambridge is expected to grow into? It is our belief that the consultation should have opened with a question about what sort of future the respondents want, rather than inferring this indirectly through the responses. A question asking whether Cambridge should continue as a compact city or significantly expand into a much larger urban area, would help the Councils determine their spatial strategy. Instead, responses are being solicited in a strategic vacuum. The statements presented in Section 2.4 are not visions so much as political slogans which provide little context for spatial planning. One way of provoking debate about a vision would be to publish for consultation the Centre for Science and Policy’s report “Visions of Cambridge in 2065”. This report (referenced by the City Council in the draft “Making Space for People” consultation) has never been subject to the public consultation which was originally mooted. 2. Lack of any clear understanding of Cambridge’s national and international significance as a historic city and “one of the loveliest cities in Western Europe” (David Attenborough). Cambridge meets four of the Outstanding Universal Value criteria for World Heritage Site designation (see our response to question 22), and its historic environment should be valued accordingly. It is this historic environment (man-made and natural in combination) which makes Cambridge such an attractive place to live, work, study in, and visit. “Cambridge” in this context includes the historic riverside setting all the way from Byron’s Pool through Grantchester Meadows and the city to the course of the rowing races out past Fen Ditton to Baits Bite. This Plan is an unprecedented opportunity to consider Cambridge and its historic landscape setting together, but this is totally unrecognised in this consultation. 3. The Environmental Limits to Growth: The document gives the impression that Greater Cambridge has the capacity to absorb a massive increase in human population and housing with little or no enhancement of the resources and services on which the additional people will depend. The belief that up to 66,000 more homes can be built in the area over the next two decades, an uplift of some 50% on the current housing stock, without a massive investment in infrastructure and resources is, in our opinion, highly irresponsible. Yet the document gives no indication of any awareness that resources might very soon limit the capacity of the area for further growth. Take, for example, our water resources: in May this year, the River Cam recorded its lowest flows for that month since records began in 1949. Our chalk streams are in crisis, they are drying up because the water in the chalk aquafers is declining due to a combination of climate change and increasing abstraction caused by a growing population and economy. Yet, without any recognition of the water crisis we currently face, the Councils seem to be proposing that up to 66,000 more homes can be built in the area. Unless the document shows awareness of the issue and what might be done at the regional level to mitigate it (like a new reservoir), the public will feel that the whole exercise lacks credibility. Similarly, what provision is to be made for upgrading the electricity supply and the waste management system? Presumably the Councils are aware of these potential limitations and have therefore commissioned research to analyse the limits to growth of the Greater Cambridge area, in which case we would like to see the evidence-base that some of the levels of growth proposed in the consultation are genuinely achievable in a sustainable way. 4. Impact on Quality-of-Life: Inevitably, the document focuses mainly on the planning of future developments, so what’s in it for existing residents? Residents are understandably worried that their quality-of-life is likely to be negatively impacted by the massive scale of new development but this is largely ignored. People are worried about issues like education and the availability of places at schools of their choice, medical services and the ready access to see a doctor, or be able to book a recreational activity without it being over-subscribed – all these are fundamental to the quality-of-life and need to be given greater recognition. 5. Investment Deficit: It is clear that infrastructure investment in the UK lags behind the growth of housing and business. By infrastructure we mean utilities, medical facilities, schools, green infrastructure, etc as well as transport. This means that rapidly growing areas such as Cambridge are constantly lacking sufficient infrastructure. By the time new infrastructure is provided more is already needed. This situation would only get significantly worse with some of the growth options proposed in the consultation. Potentially doubling the number of dwellings over the next two decades cannot be seriously considered without a substantial investment in the local infrastructure – or it will have an unacceptable impact on the qualityof-life of residents. Yet there is no obvious awareness in the document of this problem. Where is this investment to come from, especially now that Government has turned its attention to the North?
No uploaded files for public display
Question 2: Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Q2 response: Within Cambridge there are significant areas that are currently wasted as surface-level car parking. At a time when efforts should be made to reduce car use and improve air quality, we suggest that some of these car parks should be re-used for development. • Cambridge Retail Park on Newmarket Road. This area includes some 25 acres of surface parking. If a multi-storey car park was built on a small portion of this land, some 20 acres could be released for development. CambridgePPF submitted an outline proposal for the redevelopment of the car parking area on both sides of Coldhams Lane during the public consultation for the 2018 Local Plan. This showed how the site could accommodate 1200 dwellings with only a marginal loss of car parking space through the provision of a multi-storey facility and by allowing parking beneath the residential blocks which were raised on columns. Because Cambridge has such a dearth of possible brown-field development sites, we believe this site could provide valuable residential use, and must therefore be given serious consideration.
No uploaded files for public display
Question 3: Please submit any sites for green space and wildlife habitats you wish to suggest for consideration through the Local Plan. Provide as much information and supporting evidence as possible: Q3 response: CambridgePPF owns and manages land in and around Cambridge, some of which we would like to put forward for consideration. These sites include: - Wandlebury Country Park This 60ha country park has been expanded over the decades by converting agricultural land into meadows and woodlands with public access. It is a County Wildlife Site that provides a green lung for Cambridge, with over 60,000 visits a year. As the population of greater Cambridge is growing, so is the pressure on the park, its habitats, heritage and infrastructure. We would like to explore opportunities for further expansion of the park as part of a Nature Recovery Network for the Gog Magog Hills. - Coton Countryside Reserve We own over 100ha of farmland and semi-natural habitats around Coton village, which makes up Coton Countryside Reserve. We would like to include the farmland for consideration as part of a Nature Recovery Network. - Land at Balsham We own c15ha of farmland to the southeast of the village of Balsham, close to Balsham Wood SSSI. We would like to include the farmland for consideration. • In our answer to question 12 we have proposed the creation of 5 nature recovery networks (NRN). We will be carrying out work through 2020 to identify land that could become future habitats or green spaces within these NRNs. We intend to submit these to you later in the year for consideration.
No uploaded files for public display
Question 3 Call for Green Space and wildlife habitats Rouses failed last time, will fail again if criteria the same. Now evidence of badgers so we should try again.
No uploaded files for public display
Location of Growth In terms of where growth across the Greater Cambridge area is delivered, CBC welcomes the six options identified within the I&O document. We would obviously support the development of Brownfield sites as a priority, in line with sustainability objectives. We would suggest the option for delivering growth along public transport corridors is widened to consider key strategic transport corridors, including the A1 corridor and in relation to the preferred corridor route for East West Rail, as recently announced.
No uploaded files for public display
The following comments are made on behalf of the Wildlife Trust. We are the largest local nature conservation charity dedicated to the conservation of nature and have over 35,000 members, and manage over 2,000 hectares of land for nature conservation. These comments follow the questions asked in the Issues and Options consultation where possible, though inevitably go beyond this in places. The Wildlife Trust would like to play an active role alongside the two councils as they prepare this Local Plan, to ensure that it really moves us in the direction of sustainable development, is visionary and looks to the long-term.
No uploaded files for public display
Question 2: Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Q2 response: Camcycle is not suggesting sites as we remain neutral on the issue of growth. However, we will strongly object to any sites and developments that do not support and integrate with sustainable transport, not only within the site but also in a well-connected way to the wider sustainable transport network. • Development sites must support the sustainable transport goals of shifting the vast majority of everyday travel out of cars and into walking, cycling and public transport. • If it is not possible to produce a realistic Transport Assessment achieving that goal, then the site must be rejected. • It is important that sustainable transport is not only considered within the site but also the connections to the transport network and other sites. • Transport cannot be looked at in a silo. Transport, including cycling, is integral to planning of new developments and must be considered from the very start. • To reduce car usage within the site also requires reducing the amount of land, money and resources devoted to subsidising car ownership and driving (Manville, 2017). “Providing the choice of sustainable transport alongside conventional car-based options is insuffcient to change travel habits. This makes essential the constraint of car use through location, development design and planning requirements [...] Where new urban extensions or new towns are an acceptable or appropriate option, particular attention must be paid to locating the development where it can access public transport networks; designing it to be pedestrian, cycle and public transport friendly; and tackling journeys to work and school generated by the new development.” (Campaign for Better Transport, 2015) “Munich, Berlin, Hamburg, Vienna, and Zurich — the largest cities in Germany, Austria, and Switzerland — have significantly reduced the car share of trips over the past 25 years in spite of high motorisation rates. The key to their success has been a coordinated package of mutually reinforcing transport and landuse policies that have made car use slower, less convenient, and more costly, while increasing the safety, convenience, and feasibility of walking, cycling, and public transport.” (Buehler, 2017) “Governments give drivers free land; people as a result drive more than they otherwise would. That’s it. The rest is commentary.” (Manville, 2017) Evidence for our response to Question 2. • Campaign for Better Transport (2015). Getting there: How sustainable transport can support new development. • Ralph Buehler, John Pucher, Regine Gerike & Thomas Götschi (2017). Reducing car dependence in the heart of Europe: lessons from Germany, Austria, and Switzerland. Transport Reviews, 37:1, 4-28, DOI: 10.1080/01441647.2016.1177799 • Michael Manville (2017). Travel and the Built Environment: Time for Change. Journal of the American Planning Association, 83:1, 29-32, DOI: 10.1080/01944363.2016.1249508
No uploaded files for public display
Summary of Comments: The Local Plan must enable and encourage cycling for all ages and abilities in all developments, and ensure high-quality, convenient and safe cycling infrastructure is put into place. Car usage must be restrained and reduced; transport demand must be satisfied using sustainable modes in order to achieve the goals of meeting the climate challenge, creating better places with stronger biodiversity and social inclusion.
No uploaded files for public display
Question 2: Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible: Q2 response: HIPC does not wish to propose any additional sites to those we have been informed have already been put forward by developers. Our answers to later questions indicate the essential analysis that should be applied to each and every potential site before it is included in a draft plan. HIPC is aware that there will not be, as happened last time, an opportunity to comment on all the sites which meet fundamental criteria (such as having an acceptable access) to ensure local knowledge is applied to the selection of sites in the draft plan.
No uploaded files for public display
Question 3: Please submit any sites for green space and wildlife habitats you wish to suggest for consideration through the Local Plan. Provide as much information and supporting evidence as possible. Q3 response: There is a draft Neighbourhood Plan in the final stages of examination before proceeding to a local poll. It is assumed that the Neighbourhood Plan will be approved before the issue of the draft new plan, and the neighbourhood plan includes a full catalogue of green, biodiversity and wildlife sites.
No uploaded files for public display
Summary of Comments: On process: • Issues too complex for short answers at supermarkets. • Many oppose more housing, traffic. • Wording of 50 questions not a high standard. • Should be more flexible, reactive. • Greater Cambridgeshire as one supported. On issues, options. • Will evolve over several years making assumptions. • Demand for housing based on extensive growth but more recent predictions not considered. • Last 5 years growth greater than forecasted. • Shortfall in infrastructure exacerbated by major jobs growth. • Concerns over lack of climate suggestions. • No emphasis on desirable place to live. • Mixed community essential. • Expect more aged population. • City and villages different.
No uploaded files for public display
I want to thank the officers and councillors who have created this consultation. It is so much clearer and more accessible than previous local plan consultations. I hope it reaches far and wide into communities which are usually absent from this process. For communities which seem to have made little or no input in this first phase, please reach out proactively. At https://greatercambridgeplanning.org/greater-cambridge-local-plan/what-s-this-all-about/ you say “One big question affecting all these themes will be the number of jobs and homes to plan for. Central government has set us the target of planning for a minimum of around 41,000 homes between 2017 and 2040. We are doing more work to understand future jobs growth and housing growth to support it. However, to give an indication, if the recent high level of jobs growth was to continue, there may be a case for making provision beyond the local housing need to include flexibility in the plan and provide for around 66,700 homes during this period. We already have about 36,400 homes in the pipeline for this period, but it will be for the new Plan to find sites for the rest. “ That is a huge difference of 4,600 vs. 30,300 new homes. This target clearly determines the overall scale of the new plan. I challenge any assumption of continued jobs growth as there is so much uncertainty ahead. Remember the technology crash of 1999? The financial crash of 2008? What crashes will extreme weather events or new diseases bring? And dare I mention Brexit? The main impacts of that have not started yet. I also challenge the assumption that economic growth is good in itself. We know that resources are finite and material wealth cannot grow forever. Policy must evolve to use other metrics for success based on health and happiness. Moreover local economic growth to date has created the greatest inequality amongst all UK cities. Policy must evolve not merely to ensure fair shares of any new economic growth but also to redistribute the riches generated by previous growth. If we are to plan (nationally) for economic growth then the development should be in deprived areas crying out for regeneration. Other than affordable housing, there is no need for it here in Greater Cambridge. I want the councils to make this case to the government - you might actually get heard, because the new government has a “levelling up” agenda. 3.4.1 Gathering the evidence I intend to repeat my 2009 survey of allotment usage and demand in the city this spring. When published I hope this will be taken into account when planning further allotment provision for Cambridge because it relates to three of your research areas: Leisure Needs, Responding to climate change and the transition to Net Zero Carbon, Green Infrastructure and Biodiversity Net Gain. 3.6.1 London-Stansted-Cambridge corridor. We must reduce flying, for emissions reduction. Electric-powered passenger aircraft are pie in the sky so this is very clearly an unsustainable sector. Everyone except for the industry, central government and affluent holidaymakers seems to understand this now. Therefore our plan should do nothing to encourage Stansted expansion or capacity increase. We must play no part in sustaining or growing it. Give them no excuses to push for expansion in capacity or a second runway. Consider how our plan can reduce aviation. 3.6.2 If spatial framework phase 2 goes to 2050 then local plan should have the same horizon in order to meet the aim to “provide a complementary vision for the area.” 3.6.2-3.6.4 General point after reading p21 & p22. Cambridgeshire’s local government is a right old mess! What a hotchpotch. You know this. It’s good that the two district councils are now combining planning, but the disjoint roles of CPCA planning transport and spatial strategy, and GCP implementing transport improvements, and County council controlling highways and buses, flood management and schools, is unhelpful. It feels undemocratic because almost nobody understands who is responsible for what. Greater Cambridge could do so much better as a unitary authority, especially with the control of transport policy that would bring. 4.1 Climate change. The councils’ 2050 zero carbon target is not nearly ambitious enough. Climate breakdown is happening right now. The IPCC tells us we must implement major systemic change by 2030 to have a good chance of preventing the worst of it. Should our plan respond directly to this entirely credible call from the UN which is based on 6000 peer-reviewed papers? Of course it should! Some local authorities are responding by aiming for net zero carbon by 2030. Why not Greater Cambridge? Wealthy areas of our country such as ours have a moral duty to take a lead by reducing emissions faster than poorer areas. Wealthy countries such as the UK must take a lead by reducing emissions faster than poorer countries. The ethical argument for climate justice is very strong. Ever more frequent extreme weather events, combined with growing evidence that these are due to man-made global heating, strengthen the argument for rapid mitigation. Whether or not our current government or its successors bring forward the zero carbon target, we should do so locally. I understand that the two district councils have relatively little power to ensure success; but they can and must show leadership by setting an ambitious ZC target such as 2030, together with ambitious interim targets, and doing everything possible to meet these targets. 4.1.1 Greater Cambridge, as one of the most affluent regions, should aspire to take the lead in GHG reduction. Let’s not merely be “in line” with CCA objectives, let’s plan to beat the national target. Poorer communities cannot change as quickly as we can. 4.1.3 Mitigation I would extend the food growing point to say: “Creating opportunities for growing, distributing and serving food.” 4.1.3 Adaptation I would amend the last two points thus: “...the adaptation of agriculture and the whole of our food system.” “...trees and plants...resilient to a warmer climate which is drier in summer and wetter in winter.” 4.2 The network of semi-natural spaces includes allotments. Please state that explicitly. Their primary purpose is growing food but the modern trend towards organic cultivation (and the occasional overgrown plot!) make them valuable for wildlife too. It’s a significant amount of land: the city now has over 100 acres of allotments. I wonder if anyone knows the total allotment provision in South Cambridgeshire? 4.4 There are some shockingly bad recent constructions in Cambridge. Examples which frequently spoil my day as I cycle past are the ugly Marque thing on Hills Road and the completely inappropriate columns at the hotel on Regent St. Architects gone mad. Can we consult residents more widely so they get a chance to intercept such rubbish at the drawing board stage and prevent it blighting our beautiful old city? In our information-dense world it’s a real challenge to engage enough people at the right time. Perhaps street displays of a developer’s proposal at the actual site would help, by engaging directly with those people who will most often see the eventual carbuncle or masterpiece. 4.5.2 The CPCA’s CPIER was produced by people most of whom appear to have interests in development. It is a subversion of democracy that their influence already appears here at the launch of the “The First Conversation” for Greater Cambridge. Please discount their calls for continued and rapid economic growth. Consider that we can find better ways to measure success, consider that growth to date has led to huge local inequality, and that it causes the pollution which is causing climate breakdown. It is time to put the brakes on economic growth in Greater Cambridge. Sustainability appraisal 3.20 states “ Co-ordinating economic and housing growth, including considering the needs of people who work from home, could result in people working more locally and reducing in- and out-commuting, leading to reductions in emissions of greenhouse gases and air pollutants. As such, positive effects would be expected for SA objectives ... 12: climate change mitigation and 13: air quality. “ That is simply not true unless the economic and housing growth is actually carbon-negative and actually cleans our air somehow. I think you mean that the co-ordination would act to minimise emissions and pollutants generated by the new population, which is fine, it just needs stating accurately please.
No uploaded files for public display
1./ Sustainability We are in the midst of an environmental crisis and the Local Plan needs a competent and meaningful sustainability strategy to be a central consideration. It needs experts from across the commercial, academic and NGO spectrum to work with relevant local groups and officers (who cannot be expected to have the same levels of expertise), to incorporate an enforceable framework into the planning process to ensure that sustainability is taken seriously. It needs to be deliverable and have the necessary ambition and this cannot be something that is consigned to the ‘too difficult’ tray. I feel the need to say this because there are unprecedented pressures on environment at a global, national and local level yet the concessions to this in large planning applications seem barely discernible. Consider that the levels of water abstraction have increased to such an extent (due to the recent population growth) that the Nine Wells Springs that feed the Hobsons Brook would have dried up completely if Anglia Water didn’t artificially pump water into the surrounding aquifer to disguise the magnitude of the crisis. Concurrently, in a large application on my doorstep the only concession to biodiversity is a recommendation for a swift box on the roof but no requirement for green spaces (see point 3 below) - any sane person can see that that is pathetically inadequate in the current climate. The wording of the last Local Plan included an ‘aspiration’ for greening of this area. For heaven’s sake, if an aspiration is possible why can’t it be a requirement?!
No uploaded files for public display
2./ Climate neutrality Linked into the themes in point 1, there should be a mechanism that encourages a shift to more carbon neutral building materials and processes (beyond the existing insulation requirements etc). There needs to be a recognition of the massive impact of cement/concrete on carbon emissions (8% of global emissions) and enough penalty/incentive built into the new Local Plan and/or related document/policy to shift behaviour and actions in this regard. It needs to be sufficiently strongly worded that designers are thinking of this throughout the process rather than viewing it as a few cheap bolt-on’s at the end.
No uploaded files for public display
3./ Green Spaces vs Public Art Leading on from the previous point, I would urge the Council to remove this escape route. Large developers predominantly go for the public art option as the alternative that seems often to be offered in lieu of provision of green space for dense developments. The reality is that the public overwhelmingly want and enjoy green space and think that the public ‘art’ that we get instead is rubbish and a waste of time. Developers obviously take the opposite view as public art is substantially cheaper and allows them to maximise their profits by cramming more building space onto restricted plots. Green space is also obviously more valuable than public art for infiltration/aquifer recharge and flood control.
No uploaded files for public display
4./ Aesthetics One of the greatest frustrations looking around Cambridge and how it has been developed over recent years is how ugly and/or dull most of the modern buildings have become. In my own immediate neighbourhood there has been substantial massing with many massive buildings squeezed into small sites. I understand that the regulatory process and the Local Plan may have limited scope to influence the aesthetic part of this issue but one simple way of improving the county’s cityscape/landscape would be to stipulate a requirement for 10% of ‘unused’ space (above and beyond garden/seating areas). Looking beyond the immediate definition of ‘unused’, this is not so odd as it might sound. The wording might have to change but the underlying idea is that by forcing architects away from developer requirements to build right up to the boundary on every side and squeeze as many people into as many tiny internal boxes as possible, this would foster better design throughout. Look at most buildings that are appealing and add character to an area and they will generally have some unused space that emphasises architectural form or detail – this indirectly contributes to the health and wellbeing of the local population.
No uploaded files for public display
5./ More specificity in planning requirements I understand the reason for trying to avoid being too prescriptive in a document such as the Local Plan and related documents, but this simply leads to developers exploiting the guidelines beyond planners’ original intentions and leaves planning officers in an invidious position where they are hamstrung by loose language – worried about potential legal cases if they don’t err on the side of developers. What we end up with as citizens of Cambridge is a situation where the best we can ever expect form new buildings are developments that are barely acceptable rather than genuinely positive. There are two possible approaches to prevent this. Either the Local Plan (and or subordinate documents such as SPD’s) should be more prescriptively worded (see point 6 for an example) or the thresholds of acceptability relating to size, massing etc should be selected in the expectation that developers will push beyond what is written to allow flexibility (they ALWAYS do!!!). Given that recommendations in the Local Plan seem to be offered as guidelines rather than hard & fast requirements, another safeguard might be a statement incorporated somewhere to the effect that stipulated guidelines can only be exceeded in exceptional circumstances and with consent of locally affected stakeholders. This might allow some architectural creativity without opening the floodgates for greedy expansion beyond recommended scales of development (an interesting skyline with a narrow turret is quite a different proposition to a long flat roofline that might have a lower overall peak height).
No uploaded files for public display
6./ Height ambiguity Painful (and multiple) local experience illustrates the inadequacy of the current system where allowable building sizes are suggested by the overly simplistic device of indicating number of storeys. I live in a pretty standard small Victorian terrace, which happens to be on the edge of a conservation area. The intention of the last plan was for any future adjacent development to blend in with the “fine-grain of the conservation area”. The terminology used to specify what would be appropriate was simply 2+1 implying 2 storeys to match the Victorian terraces and +1 to represent either a pitched roof or something enclosed within such a space (via a setback from the main façade). This offers no specific control over storey height or setback distance, something that should surely be incorporated into a document that pretends to be regulating development. In the instance immediately above, when development inevitably arrived, the developer chose to make their own storeys 50% larger than those buildings with which it was supposed to be blending in. Similarly, the setback distance was initially little more than a pigeon ledge although this was subsequently slightly increased, but consequently the building as constructed, dwarfs the adjacent houses. This is such a simple thing to fix – straightforward rules to say what the storey height references in any given location should be and what rules are used to determine what constitutes an appropriate setback in any given location.
No uploaded files for public display
7./ Mistakes must not become precedent The Council needs to accept the principle that its officers, however well -intentioned they may be, cannot be perfect and get everything right 100% of the time. The importance of this is that previous planning approvals should not act as precedents for other planning submissions. The planning department will pretend that this is not the case but we all know that it is. I don’t expect much on this point, no one let alone a public body, is inclined to volunteer that they might have made a less than ideal judgement in the past, but at the very least, this idea of precedent needs to be taken more seriously. For one of the multiple large developments close to me, where it was argued that allowing a single building of that height would not mean that the rest of the road would be developed in similar fashion, we now have four further developments that have matched that height, no doubt in part due to the difficulty an officer would inevitably face in refusing to match a previous approval.
No uploaded files for public display
8./ False Statements Recent experience of multiple major planning applications on my doorstep has revealed a routine tendency of applicants to submit documentation that contains misleading and inaccurate statements. These ‘mistakes’ generally seem to act to the benefit of the applicant. This obviously makes the job of planning officers more difficult and can frustrate the efforts of local objectors to get a fair outcome. To discourage inaccurate and/or lazy submissions that increase the workload of others, for large applications where there is little excuse for not taking due care and attention to submit accurate and compliant documents, there needs to be a mechanism for penalising organisations that submit documents that contain more than a defined threshold of inaccurate statements etc. Whether these be misleading visuals, incorrect measurements on drawings, false statements in supporting text etc if there were notional financial penalties for each that would quickly mount up for documentation that was unfit for purpose. Whilst the planning officer role should not be to check the work of the applicant, neither should they be accepting what’s submitted at face value. At least this way, as and when they encounter false statements, the penalties could offset their time that is being wasted by lazy or careless applicants. Members of the public should be able to notify officers of such mistakes and it should logically lead to an increase in the reliability and quality of applications. (This may not be something to incorporate into the local plan but is long overdue as an upgrade to the planning process. Drawings should also contain scale bars etc rather than ratios to make them more accessible to officers and the public.
No uploaded files for public display
9./ Validity of Consultation For resident consultation to be meaningful, there should have been targeted notifications to those living in areas proposed for major change. Whether this occurred this time around, I’m not in a position to say. Sending generic mailshots/adverts to those members of those public who are likely to be particularly affected by provisional plans is disingenuous and insufficient. Receipt of a mailshot that simply says the Local Plan is being updated and their views and input are welcome will attract little attention. Then, when the Local Plan has been pushed through on the quiet it will be too late for residents to have a say. My personal experience of this is that my local community only really got to hear about the last new Local Plan when it had already been passed despite being heavily affected by it. We have been consistently fighting planning battles for 10 years now but effectively have no say in the way our local environment is changed – 6 major developments within 100m of my house. It has ruined the last 10 years of my life!
No uploaded files for public display
Working relations Central Bedfordshire Council (CBC) welcomes the opportunity to comment on the early stages of the new local plan for the Greater Cambridge area and we look forward to continuing the good working relations that CBC has already forged with the two substantive authorities.
No uploaded files for public display
Cross boundary issues CBC welcomes the recognition early on in the Issues and Options Paper (I&O paper) of the strategic position of the Greater Cambridge area, particularly in relation to the Oxford to Cambridge Arc, within which Central Bedfordshire also sits. The level and delivery of growth across this spatial area is of great importance to all constituent authorities and is a key component of our current local plans as well as the focus for current and future reviews. The recognition of the importance of working with neighbouring authorities is particularly welcomed. CBC supports the identification at 3.6.5 of the I&O Paper of the strategic cross-boundary issues. However, in addition to working collaboratively to assess housing need, including Gypsy and Traveller accommodation needs, it is considered that the delivery of such needs is also a strategic cross-boundary issue that should be a consideration in both our respective plans moving forward.
No uploaded files for public display
Big themes The ‘Big Themes’ identified within the I&O Paper are welcomed and whilst it is recognised that these broad themes cover a multitude of issues and challenges, CBC considers that connectivity both within and beyond the Greater Cambridge area should be considered as a fifth Theme within the plan moving forwards. CBC welcomes the recognition of the numerous issues and topics that need to be addressed within the local plan and looks forwards to future discussions as to how many of these can be achieved and delivered complementarily across a much wider area.
No uploaded files for public display
Economic growth It is noted within the paper that is it identified that the local economy across the Greater Cambridge area has been growing continuously and at a faster rate than previously envisaged, and that this rate of growth is expected to continue. CBC welcomes economic growth of neighbouring authority areas, particularly where there are opportunities for complementary economic growth within our own administrative area. However, it is also recognised that the I&O identifies that more recent housing and infrastructure delivery across the area has not been able to keep pace with the demands resulting from such economic growth.
No uploaded files for public display
Housing growth To combat this, the I&O Paper identifies two potential levels of housing growth to be considered within the plan – the housing growth arising as a result of the Standard Methodology which would require 1,800 homes per annum and a plan target of 41,000 homes; or a significantly higher target of 2,900 homes per annum and a plan target of 66,700 new homes in order to provide flexibility and support the expected continuation of economic growth. Whilst CBC recognises the benefits of delivering the requirements established through the Governments Standard Methodology, the need to meet more locally identified demand and need is also supported. However, we would not support a level of growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations. CBC very much supports a collaborative, complementary approach to growth and therefore looks forward to future discussions as to how the aspirations of both areas can be achieved.
No uploaded files for public display
GREATER CAMBRIDGE PLAN: ISSUES & OPTIONS CONSULTATION: MELBOURN FUTURES WORKING PARTY COMMENTS Plan Duration We suggest that it would be better to plan to 2050 to tie in with the wider 2050 climate emergency goals. Using a 2040 timescale may encourage adoption of interim policies. However, we also want to see shorter term plans included and reviews in the light of key external factors such as a decision on the East-West Railway route. The Big Themes Yes. We agree with the suggested big themes. In addition, we propose ‘Localism’ – encouraging people to live, learn, work and play in their area rather than travelling long distances for any or all of their activities. Recognising that this will not always be possible, we also suggest that there is a focus on movement of people, for example improvements in public transport into Cambridge (extension of hours of the train service) and that bus services are extended and subsidised to encourage use. Climate Change Promote Self build to encourage people to build really energy efficient homes Use planning policies to ensure that new buildings are as efficient as possible in terms of insulation, heating, generating power and water recycling. There should be a focus on upgrading efficiencies of the current housing stock which stalled because subsidies have been withdrawn. Use the LP as a catalyst to providing good advice to local residents. In particular, the area has a lot of Listed Buildings – encourage these to be made energy efficient whilst respecting their heritage. All new developments should be required to include planting of trees. Woodland should be established in small pockets of publicly owned land and Fields in Trust. Natural Environment Tree planting and woodland pockets should be developed as part of measures to create wildlife corridors, enhance existing wildlife habitat and benefit climate change. Plan for local communities to green up. Make grass verges etc wildlife friendly and save money on grass cutting. Wellbeing and Inclusion There should be a focus on building community and self sufficiency in community. This could be achieved through planning policies which ensure that developments are linked into the rest of the community and include facilities which bring other residents into the development. All development must consider local health wellbeing and community initiatives when agreeing s106 money. The Plan should incorporate some measure, based on baseline and on-going surveys as short term developments take place, which will help to guide long term planning. Great Places Fund village design surveys and plans for all to keep the individual character of South Cambridgeshire villages. A key decision to make is whether the priority is ‘Roofs over heads’(ie focus on numbers and building them quickly and cheaply) or to make all development environmentally friendly. Jobs We think it is very important to plan for economic growth but the very important rating comes with the proviso that it is economic growth at all levels. We need to encourage jobs for all levels of education and to support people in less well paid jobs by ensuring a good and affordable public transport system. Keep commercial properties rather than make all into homes –we want mixed communities to support the ideal of working where you live where possible. Homes We ‘somewhat disagree’ with this proposal. More homes can be added in at the review stage. Demand cannot be predicted accurately that far ahead. Landbanking must not be encouraged by any aspects of the Plan. We also strongly object to including any policies which encourage (explicitly or by default) development of South Cambs villages into dormitory villages to service Cambridge and London. There needs to be an overall limit on development – Cambridge is big enough. Developers will always say there is more demand. Infrastructure The focus should be on developing infrastructure in a strategic way and then developers work around that. The current system, whereby developers say where they want to build and infrastructure then has to support piecemeal developments, does not work. Melbourn’s experience with Anglian Water suggests that there needs to be much better consideration by the utilities as to whether the current infrastructure really can support the level of development suggested. During the normal process of developers seeking assurance from utility providers, AW said there was capacity. However, when the capacity was properly modelled, it was clear that the system was already at 100% capacity. There seems to be a lack of strategic planning within LAs ie there is a need to join up the planning permission authority with deliverers eg County Highways. In addition, Melbourn has much shared infrastructure across the border with Hertfordshire and there must be cross-border collaboration. For example, are they working with Herts CC in their growth and transport consultation? We are very concerned about the health infrastructure challenge. Melbourn PC has been trying to work with our GP surgery and the NHS to develop a way of providing the facilities Melbourn needs to support current growth. Over the past 4 years, no progress has been made. How is the plan going to address the issues of Primary Care Networks and what they require at a community level? Similarly, our experience with education is that the piecemeal development Melbourn has suffered leaves us with insufficient primary school place even though the school has just been expanded. S106 contributions do not provide enough money for the expansion required. Make developers work together on infrastructure in context of the Local Plan. Where several developers are working in the same area, the rates of delivery of homes will vary so all need to make a strategic plan for and commit to the s106 money and be held to it. Or if development is sequential there needs to be an obligation to correct previous developers’ work if necessary (we have the example of the New Road developments). We wish to see utility delivers required to give concrete plans for the timescale for delivery of the required services before planning permission is given. We would like to see a review of the trigger points for infrastructure requirements and link this to a strategic view of what the community has been shown to need to sustain future development. This may be via a Neighbourhood Plan. Melbourn is pleased that the concept of limited development in Minor Rural Centres was upheld at the recent Appeal for a development in Melbourn. However, we wonder if the exercise should be updated since there have been many changes since 2012. Dispersal - Villages We urge that the unsolicited development in Melbourn as a result of the late adoption of the current LP is taken into account when considering which villages are targeted for dispersion. This unsolicitied development has left us with an urgent need for infrastructure improvements. We support dispersal on a pro rata basis or at least by putting development in those villages that have not been affected by last round of speculative development. We support the development of local brownfield sites except where this would result in a large new community being tacked onto the outside of the existing community without extensive efforts to integrate the new residents through infrastructure improvements to the whole community. The PC has previously supported the strategy of ‘Infill without overdevelopment’. However, that does not now hold because we want more tree planting etc in village for environmental reasons and wildlife reasons and to combat climate change. We support a general requirement (through planning policy) for buffer zones such as we achieved for the 199 homes on New Road) on all developments to shield from view. Villages should identify areas within the envelope for greening. Cumulative development within villages needs to be controlled. It is unsustainable to keep adding 30 +30 in Minor Rural Centres because of infrastructure issues. Current village development frameworks need to be respected. Where unsolicited development has already taken place, this must not be used as an excuse to justify further infill. Public Transport Corridors This is a good starting point but the future capacity of the transport links need to be taken into consideration. The Kings X to Cambridge line is now at capacity with no significant scope for further services. In addition, the old infrastructure at the village stations needs to be taken into account eg the lack of accessibility at Meldreth station. Again, this is a longstanding issue which is raise – but not solved- every time there is proposed development. Is there liason with Network Rail on this? There is a problem when villages start to join together along the corridors. We want to maintain separate identities. This should be supported by walk/scooter/cycle paths and bus links between villages to reduce car congestion on the minor roads. The local cluster of villages is on a corridor already – impact of additional traffic on current circumstances. We would want to see rigorous consideration analysis of the impact of further development on current traffic issues and potential ones such as the replacement of the Foxton Level Crossing, the proposed Foxton Travel Hub and the East-West Railway. Village Sites Communities will change as a result of the impact of the current Local Plans. For example, Melbourn has had a higher than normal elderly population until recently. As a result of recent development, that is no longer the case but we now have a full Primary School and 3 residential homes for the elderly. If flexibility means monitoring the changing needs of the community and adapting plans, we agree that there should be flexibility. We support looking again at the current classifications of villages as things have changed since 2012. However, based on the experience of Melbourn, there is limited opportunity for infill due to past development and we oppose this now on environmental grounds. The 30 homes maximum development for minor rural centres still stands as a useful upper limit. Particular Approach We want a strategic approach which takes into account cumulative development. This must include upgrading of infrastructure to support proposed development – taking into account any deficiencies cause by past speculative development. This must include health provision as that is the area where there has been no expansion of provision. Any strategy must acknowledge that Parish Councils cannot continue to take on responsibility for delivering the decisions made at Local Authority level. If PCs are needed to achieve the aims of the Plan, the requirements must be very focussed and developed in close co-operations with them. Views on specific policies in the current plans We strongly support the policy to restrict developments in Minor Rural Centres to 30 dwellings. We think this level is appropriate for enabling the development to be properly integrated into the village.
No uploaded files for public display
Structure and Content: The Essex County Council (ECC) comments on the Greater Cambridge Local Plan – Issues and Options 2020, highlights the background context and then provides views on matters relating to specific sections (and where appropriate the questions) of the Draft Local Plan reflecting the plan’s format and order. Background Context Cambridge City Council and South Cambridgeshire District Council (Greater Cambridge Authorities (GCA)) are currently preparing a Joint Local Plan. As part of this preparation the Councils’ have prepared an Issues and Options (Regulation 18) consultation to commence the conversation with relevant stakeholders, the local communities and those that invest in the locality. The Local Plan will impact the way that people within these communities live, work and socialise over the next 20 years.
No uploaded files for public display
Thank you for consulting the Home Builders Federation (HBF) on the Greater Cambridge Local Plan (GCLP). The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year. The consultation on the GCLP sets out a broad framework for growth and provides little in the way of detail on which to respond. As such we have provided some general comments on those question relating to housing needs and supply that we believe will help the Council prepare a sound plan.
No uploaded files for public display
42. Where should we site new development? 1.49 Rather than ranking the development options our client believes that the Councils should ensure consistent delivery across the plan period by avoiding an over concentration of development in a specific area or an over reliance on large strategic sites. Essentially, the Councils should not base their growth strategy on a single strategy. 1.50 Our client believes that a significant element of the new homes needed to meet the needs of the Greater Cambridge area will need to be accommodated in the higher order settlements near to Cambridge, like Comberton. Therefore, it is inevitable that the Greater Cambridge Local Plan will need to release sites from the Green Belt to allow the most effective form of development to meet the predicted housing needs of the area.
No uploaded files for public display