Greater Cambridge Local Plan Preferred Options

Endorse in general the proposed policy direction especially to enable the development of the airport site. However, the delivery of only 2,900 homes out of the proposed 7,000 by 2041 appears lacking in ambition. Of those 2,900 homes preference should be given to affordable and social housing to ensure housing available for the employment mix proposed. The council should support Marshall Holdings to bring forward their relocation of airside activities to Cranfield Airport to release brownfield land for housing and employment development, especially that of affordable housing which is a priority in this part of Cambridge.
The mix of employment uses needs to be scrutinised in the light of post-Covid working and living conditions.
It will be important to retain the individual character of Teversham village and prevent encroachment on the Green Belt. The maintenance of the green corridor widening out at Teversham to provide a green separation as adopted in the 2010 Local Plan must be retained. The proposal for relocating Cambridge Waste Water Treatment Plant to an area of unspoiled Green Belt at Homey Hill between the villages of Horningsea and Fen Ditton does not accord with the policy’s intention to provide additional wildlife habitat as part of Eastern Fens green infrastructure initiative. It is also contrary to Policy GP/GB
The policy proposals should not depend on complete integration with or extension to the proposed North East Cambridge Area Action plan which predicates on the relocation of Cambridge Waste Water Treatment Plant to an area of Green Belt at Honey Hill which is the subject of a Development Consent Order. It is recommended a more ambitious target of 4000 homes during the plan period . This could be achieved with forward planning prior to Marshalls final departure. Ensuring protection and a green separation of dwellings from Teversham village is important . Opportunities to link cycle ways across Coldhams Common, through the airport and out towards National Cycle route No.11 & National Trails eg Harcamlow Way should be fully optimised as part of the development plan - Enabling safe foot-cycle access to SSSI Quy Fen; SSSI Wilbraham Fen and wider network of surrounding PRoW’s.

The objectives of the Policy:
preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
maintain and enhance the quality of its setting
prevent communities in the environs of Cambridge from merging into one another and
with the city.
Endorse the general principles of the policy however they are not reflected in the rest of the Local Plan which claims that only four areas of development have been taken out of Green Belt without referencing the relocation of Cambridge Waste Water Treatment Plant (CWWTP) to Honey Hill. Relocating the CWWTP to Green Belt in order to create a brownfield site to develop housing for NECAAP does not meet these objectives above. The Green Belt Assessment 2021 considered that the Cambridge Green Belt Purposes of 2003 and their inclusion in subsequent Local Plans, including the 2018 LP, were still relevant and they were used to assess the potential harm of new development. However, this 2021 Local Plan fails to include the incursion in the Green Belt at Honey Hill in order to release a commercial site (Cambridge Waste Water Treatment Plant at Cowley Road) in order to produce a brownfield site on which to build housing, retail and offices.

The relocation of the CWWTP to Honey Hill is contrary to Policy BG/PO: Protecting open spaces (p183 pf Greater Cambridge Local Plan First Proposals) which states that a Local Green Space is required to be demonstrably special to a local community and hold a particular local significance. Honey Hill is important to the local communities of north east Cambridge, Horningsea and Fen Ditton where it is used for recreational purposes by walkers, runners, cyclists and equestrians and is good quality agricultural land with rich mixture of fauna.
It is also contrary to Policy BG/EO: Providing and enhancing open spaces which states that open spaces are often fundamental to the character of the area. Honey Hill is flat fenland close to the SSSI at Quy Fen and therefore the relocation of the CWWTP will change that character.

Not supported The area is described as a significant brownfield site. This is not correct as it is occupied by commercial buildings. It can only become brownfield if vacated by relocating the Cambridge Wastewater Treatment Plant to Honey Hill, an area of Green Belt, and therefore contrary to Policy GP/GB Protection and Enhancement of the Cambridge Green Belt. The policy also fails to take into account the changed working and living conditions resulting from the Covid 19 pandemic. The increased densification also appears to be contrary to Policy GP/GB. As the policy states that only 4000 dwellings will be accomplished during the local plan period, and there is no operational need to relocate the plant, the relocation of the plant and the consequential damage to the Green Belt, is not necessary and the North East Cambridge Area Action Plan and this policy should be reconsidered.
Greater Cambridge Shared Planning, in response to the CWWTP Scoping Report, has themselves stated they would like to clarify that the relocation of the Cambridge WWTP is not a “requirement” of the North-East Cambridge Area Action Plan and must not be referred to as such - see Page 6 https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf.
The housing development at North East Cambridge is not supported, a focus on employment growth in the area and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region as an alternative is recommended.
The spatial options review supporting the existing Local Plan (2018) identified a medium growth approach to NEC that did not require the relocation of CWWTP. This focused principally on employment, 15,000 jobs with homes in the region of 200 close to the station area and outside of the 500m odour buffer zone. These employment targets without the relocation of CWWTP match those of S/NEC in the First Proposals. It is recommended this option is represented as an alternative policy.
·Cambridge Airport now presents as a realistic alternative for major housing development on brownfield. The site fares well in the Sustainability Assessment. It will have access to North East Cambridge employment via the new Chisholm Trail and is equal distance to the Science Park and Addenbrookes/Bio-Medical Campus.
Alternatives to meet the target of 4,000 housing supply in the plan period intended at NEC could be attained within a similar time period with forward planning and mixed development for example via: an additional 1,000 houses in plan period Cam Airport ; 2-3,000 homes Cambridge Bio-medical Campus; 1000 Areas of Major Change. These 3 sites in addition to New Settlements will also offer housing capacity beyond the plan period eg Cam Airport has a 7000 allocation to full build out and potential further allocations as indentified in S/CB & S/NS.
A case has been made under S/JH to reduce the housing Growth Option from Maximum + (11,500 additions required) to the Minimum (3000 additions required) or Medium range (8000 additions required). In the case of either of these alternative Growth Options being adopted the alternative site options above could absorb the additional housing target required and further housing beyond the plan period.
Focusing on Cambridge Airport as the alternative major housing development within Cambridge City boundary would remove the risks to the Aims & Vision of the Local Plan and contravention of Policies associated with the unprecedented high level of densification proposed and the necessity to relocate CWWTP to fulfill the S/NEC Policy into the Green Belt within Greater Cambridge.
The impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase homes already existing in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further, in the case of North East Cambridge with’ high densification housing at unprecedented levels for Cambridge’. The Aims of the Local Plan : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here.
Changes in working practices post COVID to home working and reduced daily commutes now widely recognised for a number of industries, particularly the tech industries, to be permanent. Thus, reduced CO2 emissions for existing and future forecast employees and reduced demand for housing close to work.
The CPIER (2018) report which informed the Densification strategy advises young people will still wish to be in a centre where they can physically group together, this may be so for those in their first 5 years of work but beyond this, high density living with restricted car use, home working opportunities and affordable housing in the wider region means living in high density housing is unlikely to remain attractive for those in stable relationships seeking family accommodation.
4,000 homes have been proposed for completion in the plan period (2041) at North East Cambridge, the first homes being available from 2030. 8,000 plus have been allocated to full build out beyond this. Inevitably supply will be determined by the developers. If the vision for North East Cambridge level of densification etc., proves not to be popular and sustainable solutions to support the 31,000 homes already committed and yet to be built are not delivered, these homes, including the promise of affordable homes, may not be built in a timely way or the infrastructure promised realised.
Concerns expressed about the level of demand for housing and sustainability of those proposed is most often placated with the assurance that every 5 years the housing supply, demand and need will be reviewed and adjustments made accordingly. However, in the case of North East Cambridge in order to pursue the S/NEC Policy, Anglian Water have been requested to relocate the existing fully operational waste water treatment plant. If their DCO application is successful, long before any of the above are known or review of the impact of the high growth housing targets for Greater Cambridge are realised, relocation will have taken place with significant negative impacts on another area of Greater Cambridge in the Green Belt. The effects of the relocation on the area surrounding the site identified by AW , Honey Hill, will jeopardise the Aims and Vision of the Local Plan and many Policies laid out in the First Proposals listed below will be compromised.
Pursuing housing development at scale in North East Cambridge as a result of the requirement of the relocation of CWWTP to fulfil the S/NEC Policy and the site selected by Anglian Water to do so, will require the introduction of an industrial plant into an area of open Green Belt , where development has been identified by the First Proposals’ Green Belt Study (2021) as bringing about ‘very high harm’. The area is within close proximity to three conservation areas and villages; green infrastructure and numerous historical assets. The historical setting of Cambridge will be impacted and there will significant negative environmental effects impacting on local residents and wider users of the area. The proposed relocation arising from the S/NEC Policy will be contrary to Policies:
o Bio-diversity & Green Spaces:
BG/GI ; BG/RC ; BG/PO ; BG/EO
o Great Places:
GP/LC ; GP/GB; GP/QP ; GP/HA
o Wellbeing & Social Inclusion:
WS/HS
o Climate Change:
CC/NZ – Carbon expenditure, emissions and embedded carbon to decommission fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon cost of fulfilling S/NEC Policy
CC/CS – decommissioning and building a new Waste Water Treatment Plant on prime agricultural land as a means to fulfil S/NEC Policy is in contrary to CC/CS
The following Local Plan Vision & Aims will be jeopardised:
Bio-diversity and green spaces:
‘Increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.’
Wellbeing & Social Inclusion:
‘Help people in Greater Cambridge to lead healthier and happier lives, ensuring that everyone benefits from the development of new homes and jobs.’
Great Places:
‘Sustain the unique character of Cambridge and South Cambridgeshire, and complement it with beautiful and distinctive development, creating a place where people want to live, work and play.’
Infrastructure:
‘Plan for transport, water, energy and digital networks; and health, education and cultural facilities; in the right places and built at the right times to serve our growing communities.’

Object to parts of this policy as being incomplete. The Local Plan (LP) states that it will include settlement boundaries around settlements, identifying areas that are considered to be part of the settlement for planning purposes. However, it fails to include, or refer to the area between Fen Ditton and Horningsea known as Honey Hill despite the fact that building a commercial development there extends the building capacity of North East Cambridge as described in the proposed North East Cambridge Area Action Plan.

Object also that the LP also states that where planned developments, such as new settlements, have reached sufficient certainty regarding their exact boundaries, new settlement boundaries will be drawn. This does not allow for a finite point at which that certainty is assessed and allows for “mission creep”. More careful wording is needed for this policy to prevent description of boundaries becoming vague. While the LP proposes that no development would be permitted outside settlement boundaries with exception, these exceptions include development supported by other policies in the plan. This would allow incursion in the Green Belt if it became expedient to enlarge a development already covered by other policies, such as Policy S/NEC: North East Cambridge.

Not supported. Assessment of housing and employment needs were made before Brexit and before the Covid-19 pandemic. We suggest that these should be re-assessed. Housing aspirations have changed and major conurbations are no longer so attractive. It is recognised that personal and communal space, with access to green space, is necessary for mental and physical wellbeing.

It should also be recognised that Cambridge has a highly mobile work force, especially in the sciences and technology industries, where employees rarely stay at the same job for their whole working life. Skilled service professionals, e.g electricians, plumbers, are necessarily itinerant.

The impact on carbon expenditure, water use and flood risk due to ground cover should be assessed in the light of climate change.

The prediction of 2,111 homes produced per year is not going to have a major impact on Cambridge high house prices or the provision of social and affordable housing for the lower paid of the 58,500 jobs.

More investigation is needed on employment sites, especially office space, which has become available since the pandemic. These include office space at the Biomedical Hub at Addenbrookes Hospital Biomedical Hub, changes from retail to other use at the Grafton Centre Grafton Centre and the Dirac Building at St.John’s Innovation Park among many others.

The development targets for housing in Greater Cambridge are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan .

The Medium plus Growth Option is not supported, a Minimum or Medium Growth Option is recommended requiring an additional 3,000 homes (rounded & incl 10% buffer) and Medium Option an additional 8,500 homes (rounded & including 10% buffer). [figures pg.84 of the SA and pg.42 of Development Strategy Topic Paper]
Minimum or Medium Growth Option can be justified on the grounds of:
1. Sustainability - where solutions to support both the existing population and housing already in plan are yet to be resolved (eg Water, Electricity, access to Health, Transport infrastructure)
2. The impact of large population increases in Greater Cambridge as a result of an unprecedented  amount of new homes already in the pipeline, 30,000 + amounting to a 37% increase of existing homes in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further. The Aims of the Local Plan : ‘Wellbeing & Social inclusion’ and ‘Great Places’ are of particular relevance and at risk here.  
3. Changes in working practices post COVID to full or partial home working and reduced daily commutes now widely recognised for a number of industries, particularly the tech industries, to be permanent. Thus, reduced CO2 emissions for existing and future forecast employees and reduced demand for housing close to work.

Agree in principle with the exception of North East Cambridge site (see comments on Policy S/NEC). Wherever possible low carbon expenditure conversion should be employed rather than demolition and construction of existing buildings, e.g.Henry Giles House. Some downward revision of proposed total numbers of dwellings is needed in the light of post-Covid working practices and the need for recreational and personal space to support mental and physical well-being

Agree in principle. However, the policy direction is towards taking into account the whole-life carbon emissions which are defined as emissions associated with constructing buildings. This needs to be expanded to include the carbon emissions associated with decontamination and demolition of existing buildings on the site, such as at the current Cambridge Waste Water Treatment Plant and the eventual demolition of the new building, ensuring that low carbon materials are used in construction and avoiding those with high carbon expenditure in their manufacture, e.g. cement.. This should include the carbon expenditure of Heavy Commercial Vehicles (HCVs) used to transport demolished building materials and the disposal of such materials with their embodied carbon.

Carbon expenditure, emissions and embedded carbon to decommission fully operational CWWTP and decontaminate site and build new plant within 1 mile of existing inclusive of transfer tunnels, HGV traffic etc., should be factored into carbon expenditure associated with fulfillment of S/NEC Policy

Agree in principle. This policy sets out to to take account of changing climate, such as heat waves and flash flood, when designing developments but refers only to new dwellings for low overheating risk. It should be expanded to include large industrial developments such as the Waste Water Treatment Plant proposal to relocate to Honey Hill, especially the office block and visitor centre. More detail is needed to ensure such commercial developments do not suffer from, or contribute to, flood risk after prolonged periods of rain or flash flooding and their operation does not contribute to released heat production. Some existing retail buildings use a "heat barrier" to ensure their entrances are warm; this contributes to CO2 production, is expensive and adds to heat spill. New buildings should use alternative entrance methods to preserve heat and reduce CO2production, and where possible efforts should be made to adjust existing retail buildings. Tree cover as a cooling mechanism cannot be achieved quickly in large urban developments but grass cove, which contributes equally to CO2 absorption, has similar effects and green landscaping allows surface drainage. These also follow the Dasgupta principles of the economics of biodiversity https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/957292/Dasgupta_Review_-_Abridged_Version.pdf

Endorse in part. Care must be taken to prevent meanwhile use on sites proposed on Green Belt while waiting for consents. Such use would be incursion into the Green Belt and contrary to Policy GP/GB Protection and Enhancement of the Cambridge Green Belt and could cause unjustified damage should the applications fail.
In the case of Policy S/NEC North East Cambridge, consideration should be given to established businesses, including those on Nuffield Road, which would vacate the site when development starts and support should be given them to maintain businesses as long as possible and in finding a new site.
Where possible meanwhile use should concentrate on low carbon use, minimal CO2 producing construction and where possible provide green space, adequately maintained to prevent vandalism.

This policy states : ‘Development will be required to demonstrate how it preserves or enhances the significance of the heritage assets of the Greater Cambridge, their setting and the wider townscape, including views into, within and out of conservation areas.’
Relocation of CWWTP to Green Belt is in contravention of this policy. Views within and out of conservation areas (Horningsea, Quy and Fen Ditton) will be damaged. See ‘Greater Cambridge Green Infrastructure Opportunity Mapping: Baseline Report’, LUC/South Cambridgeshire District Council & Cambridge City Council , November 2020,
Greater Cambridge Green Infrastructure Opportunity Mapping Baseline Report (Land Use Consultants) November 2020 (greatercambridgeplanning.org)
Fig 6.2, Cultural Heritage, p46 - this map shows conservation areas and listed buildings encircling the  proposed site of the CWWTP on the pristine Green Belt  between Fen Ditton, Stow cum Quy and Horningsea.
Other heritage assets and conservation areas such as Biggin Abbey, Baits Bite bLock, Anglesey Abbey may have reduced enhancement due to odour and proximity of commercial development.
Size of the development, height of the development, industrial nature of the development dwarfs heritage assets. Impact intensified by open nature of the landscape between the conservation areas.

The underpinning Strategic Heritage Impact Assessment considers 8 strategic spatial options across 3 potential growth levels:
https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/StrategicHeritageImpactAssessment_GCLP_210831.pdf
The report clearly indicates development for the Green Belt spatial option to represent Moderate/High risk for the medium growth option and classifies this option among the least preferred.
The subsequent Impact Assessment Supplement which further refines study focus on the Medium growth level establishes a Preferred Options Spatial Strategy as being the best performing:
https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/StrategicHeritageImpactAssessmentSupplement_GCLP_210831.pdf
While the assessment documents, along with the initial baseline study, offer a methodical approach to the assessment, they are fundamentally flawed as they do not consider the consequential land take required for relocation of the Waste Water Treatment Plant (WWTP) currently proposed for the Green Belt.
In order to deliver the intent of the Local Plan in considering land allocation, use and forward planning these assessments should be reconsidered taking into account the consequential Green Belt land take associated with the North East Cambridge development / WWTP relocation and re-classified accordingly.