S/CE: Cambridge east

I have read the proposed local plan and welcome such aspects as tree planting in city centres and improved rail links. I do however wish to express reservations about other aspects of the proposed policies.

Ox Cam Arc

Creating good low carbon public transport links between important centres is good but this should be done in such a way that the natural environment and local ecology is impacted as little as possible. To upgrade this infrastructure into corridor developments for retail, commercial activity and housing will impact negatively upon the environment and will create 'soul-less dormitories' for resident workers; the only winners being developers and not local people. Natural environment cannot be 'enhanced' and it can only be replaced by an unnatural human-made environment, even if that new environment has some green credentials.

Water Pollution

My concerns are those eloquently expressed by the group 'Friends of the River Cam'.

Development in the East

The County Council's Highways Committee recently resolved that the levels of traffic on Cambridge's Mill Road are such that in the interest of health and protection from serious accident, its traffic volumes need to be controlled by creating a 'separate' albeit 'integrated' policy for Mill Road. This should be noted in the policy on development to the East of Cambridge.

Water supply for the plan consultation on idea of 48,000 new households during building and completion after estimated 20 years:
a)Water to supply such a project is unsustainable. We are already in a place of deficit - the flow of the river Cam is substantially reduced due to increase in the area’s population.
. Anglia Water is driven to plan new sewage works on green belt land which was promised to not be touched - ie Green Belt.
. Any plans to “create green spaces and nature reserves in the area” would need water for plant/tree life, currently this is hard to sustain and we know drought in summer will only increase.
. Any idea that we take water from other areas of the UK is magical thinking - they will also be suffering water shortages.
. Building reservoirs in the Fens is way out as with climate crisis it is envisaged they will be flooded with salt water.

b)Ecological issues regarding development around the Biomedical Site/Addenbrookes/SCBC/A Nine wells etc - will have a negative impact on bio-diversity that will be difficult to mitigate. More loss on insect, plant & wild life bring a further loss to falling farm bird populations. It’ll be hard to irrigate the plantations.
. We need every bit of land to grow our food in order to be secure when markets for our food importation might change. We import more than 50 per cent of our needs. The area around nine-wells Trumpington etc was historically excellent for agriculture. I have knowledge of south Cambridgeshire villages and the land is a major farming area for grain.

c) We already have a need for housing for key workers and we are not organised enough to achieve this. Developers and planning is not on top of this problem. Hopefully residential development opportunity at Marshals Airport will help but that brings up the transport problem.

d) Travel south up Babraham Rd and up on the Gogs, look back on Cambridge and often one sees a grey fog - Cambridge is in a dip which one reason for pollution being so high here. We are top in the nation for traffic jams, these are pollution machines, even electric cars produce toxic emissions. We need some of the measures proposed to dissuade car use in the area. Yes, I would agree to road charges that bring a noticeable reduction in car use. There could be a badge scheme for vans that have to carry tools and equipment.

To sum up: Such growth for the sake of the economy is not what we should be looking at in this way at this time. The climate crisis, covid and other pandemics that will follow is changing our work and travel pattern. It is changing our needs regarding water and land use and "levelling up”. Also consider AI as a big factor , many of the implications are unknown.

The area is too complicatedly organised by local government divisions with no satisfactory overview. We need to work on the many existing problems (some mentioned above) first before we totally fall for the Government’s hopeful plans for the south East and the Arc that are not regarding the complications realistically.

Context for this consultation

The current situation nationally and internationally with respect to Covid 19 could not have been foreseen when the review of the South Cambrdgeshire and Cambridge Local Plans commenced in 2019. The economic and social consequences of the pandemic and, at some point in the future, its aftermath, could be significant in both the short term and long term, yet no assessment of any possible future changes are built into the proposals set out in this consultation.

Given that certain major housing developments , such as Northstowe and Waterbeach are well underway and planning applications regarding new employment (such as at Granta Park and the Babraham Research Campus) are coming forward, is this consultation so time critical that it could not be delayed for, say,12 to 18 months ?

The location of at least some types of jobs could be affected by more remote working than pre-2020 and this, in turn, could mean that some individuals would no longer need to live close to the company or organisation for which they work, and this would have an impact on travel to work and commuting patterns.

A delay would give time for some indications of impacts relating to local jobs and housing to emerge and to be integrated into the emerging Plan prior to consultations such as this..


Location of housing

Much of the housing development the plan period will come from sites that are already in the current planning pipeline (that is, land already allocated for housing in the approved 2018 Local Plans or when developments has already commenced as , for example, at Northstowe, at Waterbeach and on the edge of Sawston).

However, I wish to comment on two of the new allocations.

I am concerned that the move of Marshalls from the airport site as this will lead to a reduction in the range of job opportunities available in the Greater Cambridge area. However, I accept that Marshalls do seem set to move, so development of the airport site (a brownfield site) is appropriate.

I am very concerned about housing on the waste water treatment plant site. It does not seem to me to be good use of more than £100 million of public money to move the waste water treatment plant about one mile in order to build houses on the present plant site. In fact, there is no need to build houses on the plant site. If the Councils were to revise their housing numbers to bring them more into line with government figures, then this site could be removed from the sites needed for housing development.


The Rural Southern Cluster

The First Proposals consultation includes policy areas for the Babraham Research Campus and for the Genome Campus. Given further likely developments at Granta Park, it is surprising to see that there is no such specific Policy Area for Granta Park.

Planning applications submitted over time are considered on an individual basis, but this approach fails to take into account the cumulative impacts of successive developments on Granta Park. In addition, successive planning applications that each involve building hundreds of car parking spaces do not seem to align with reducing dependence on motor vehicles.

Having a Policy Area covering the Granta Park site could provide a locally agreed framework for future development

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land off Shelford Road, Fulbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and dedicated cycle routes into the City Centre and Cambridge Biomedical Campus, including Addenbrooke’s Hospital, the Councils have not proposed any new site allocations around Fulbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land south of Cambridge Road, Melbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and a good range of services, the development strategy as currently drafted proposes relatively limited growth around Melbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

Cambridge East:
Any development at Cambridge East must first and foremost benefit local people. This is a deprived area within our affluent city which is in desperate need of good quality green and community spaces. We have previously shared a radical alternative proposal for the land at Marshalls [1].
[1] https://greens4abbey.org.uk/true-green-project/