Greater Cambridge Local Plan Preferred Options
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Greater Cambridge Local Plan Preferred Options
Jobs
Representation ID: 57275
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
To ensure a wide range of jobs are available across Greater Cambridge, it will be important for the Local Plan to be flexible in its approach to commercial, retail and leisure uses. This is in accordance with paragraph 81 of the National Planning Policy Framework which requires Local Plans to support economic growth. It is also in line with the new Use Class E which encourages increased flexibility across use classes to allow for quick and effective reactions to changes in demand. Failure to provide sufficient flexibility across uses could stifle economic growth and risks the creation of underused and/or derelict sites.
To ensure a wide range of jobs are available across Greater Cambridge, it will be important for the Local Plan to be flexible in its approach to commercial, retail and leisure uses. This is in accordance with paragraph 81 of the National Planning Policy Framework which requires Local Plans to support economic growth. It is also in line with the new Use Class E which encourages increased flexibility across use classes to allow for quick and effective reactions to changes in demand. Failure to provide sufficient flexibility across uses could stifle economic growth and risks the creation of underused and/or derelict sites.
Comment
Greater Cambridge Local Plan Preferred Options
J/NE: New employment and development proposals
Representation ID: 57277
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS supports ambitions for Plan to encourage a flourishing and mixed economy which includes a wide range of jobs. To ensure this is achievable, important that policy J/NE allows flexibility for employment uses in accordance with Paragraph 82 of National Planning Policy Framework.
Government recently introduced new Use Class E to promote flexibility in town centres. Crucial the Plan does not seek to restrict sub-uses within wider Use Class E, in direct conflict with the aims of Use Class E.
USS notes an identified need for warehousing and distribution. Policy J/NE is intended to not support large scale regional and national distribution proposals. Request policy makes clear that small to medium sized warehousing and distribution will be supported to meet identified need. Make clear co-location is an acceptable way to meet both warehousing and distribution and housing needs. Also reflect in Clifton Road Industrial Estate site allocation.
USS supports the ambitions for the Local Plan to encourage a flourishing and mixed economy in Greater Cambridge which includes a wide range of jobs. To ensure this aim is achievable, it is important that proposed policy J/NE allows flexibility for employment uses in Greater Cambridge. This would be in accordance with Paragraph 82 of the National Planning Policy Framework which identifies that planning policies should “be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances.”
Further, the Government recently introduced the new Use Class E to promote flexibility in town centres. It is crucial that the Local Plan does not seek to restrict sub-uses within the wider Use Class E. This would be in direct conflict with the aims of Use Class E.
USS notes that there is an identified need for warehousing and distribution (Use Class B8) uses within Greater Cambridge. USS notes that the proposed policy J/NE is intended to not support large scale regional and national distribution proposals. However, USS requests that the proposed policy makes clear that small to medium sized warehousing and distribution will be supported to meet the identified need. It should also be made clear that co-location is an acceptable way to help meet both the warehousing and distribution and housing needs in the area. This should also be reflected in the Clifton Road Industrial Estate site allocation, which should be flexible enough to allow for some small to medium sized warehousing and distribution uses on the redeveloped site.
Comment
Greater Cambridge Local Plan Preferred Options
J/PB: Protecting existing business space
Representation ID: 57278
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS understands and supports the ambition to protect existing business space, Policy J/Al is intended to state that where loss is proposed, it will need to be justified by evidence it is no longer needed.
USS notes that an effective way of better utilising land is to redevelop brownfield land and re-provide existing uses alongside co-located residential uses. Proven way of addressing both housing shortage and need for other uses.
Policy J/PB should ensure it does not restrict ongoing operation of existing uses in interim period before redevelopment. USS intends to bring forward Clifton Road Industrial Estate for re-development within plan period; however, prior to its redevelopment it is critical that existing tenants are not restricted in the operation of their businesses.
USS understands and supports the ambition to protect existing business space. USS notes that the proposed policy J/Al is intended to state that where loss is proposed, it will need to be justified by evidence that it is no longer needed which USS supports.
USS notes that an effective way of better utilising land is to redevelop brownfield land and re-provide
the existing uses alongside co-located residential uses. This is a proven way of addressing both the housing shortage and the need for other uses.
Proposed policy J/PB should ensure it does not restrict the ongoing operation of existing uses in the interim period before redevelopment. USS intends to bring forward its asset at Clifton Road Industrial Estate for re-development within the plan period; however, prior to its redevelopment it is critical that the existing tenants are not restricted in the operation of their businesses.
Comment
Greater Cambridge Local Plan Preferred Options
J/AW: Affordable workspace and creative industries
Representation ID: 57279
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS notes the ambitions of proposed policy J/AW to provide affordable workspace. USS recognises that this is not always appropriate on-site and supports the proposal to allow flexibility for financial contributions for equivalent off-site provision. USS also recommends that affordable workspace requirements are subject to viability to ensure otherwise marginals schemes are not unnecessarily restricted from coming forward.
USS notes the ambitions of proposed policy J/AW to provide affordable workspace. USS recognises that this is not always appropriate on-site and supports the proposal to allow flexibility for financial contributions for equivalent off-site provision. USS also recommends that affordable workspace requirements are subject to viability to ensure otherwise marginals schemes are not unnecessarily restricted from coming forward.
Comment
Greater Cambridge Local Plan Preferred Options
J/RC: Retail and centres
Representation ID: 57280
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS supports the proposed approach to support retail within new mixed use developments which are located outside of district centres. This will be important to ensure new residents have local everyday facilities that can be accessed sustainably, for example by walking or cycling.
USS supports the proposed approach to support retail within new mixed use developments which are located outside of district centres. This will be important to ensure new residents have local everyday facilities that can be accessed sustainably, for example by walking or cycling.
Comment
Greater Cambridge Local Plan Preferred Options
J/VA: Visitor accommodation, attractions and facilities
Representation ID: 57281
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS notes that visitor accommodation, attractions and facilities can complement commercial uses. USS therefore requests that the proposed policy J/VA sets out that these uses will be appropriate in existing commercial areas.
USS notes that visitor accommodation, attractions and facilities can complement commercial uses. USS therefore requests that the proposed policy J/VA sets out that these uses will be appropriate in existing commercial areas.
Comment
Greater Cambridge Local Plan Preferred Options
Homes
Representation ID: 57282
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS notes the housing targets for the Local Plan and is supportive of appropriate brownfield sites being redeveloped to help contribute towards the housing need across Greater Cambridge.
USS notes the housing targets for the Local Plan and is supportive of appropriate brownfield sites being redeveloped to help contribute towards the housing need across Greater Cambridge.
Comment
Greater Cambridge Local Plan Preferred Options
H/AH: Affordable housing
Representation ID: 57283
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS notes that proposed policy H/AH proposes that affordable homes should be provided on-site except for in the circumstances set out in paragraph 63 of the National Planning Policy Framework 2021. USS supports this approach which is in line with national policy.
USS notes that it is proposed that where the development is solely for Build to Rent, there could be a proportionate reduction in affordable housing. USS recommends that this also applies for developments where part of the residential uses are Build to Rent. This will ensure that it is viable for the most suitable residential mix to come forward on sites.
USS notes that proposed policy H/AH proposes that affordable homes should be provided on-site except for in the circumstances set out in paragraph 63 of the National Planning Policy Framework 2021. USS supports this approach which is in line with national policy.
USS notes that it is proposed that where the development is solely for Build to Rent, there could be a proportionate reduction in affordable housing. USS recommends that this also applies for developments where part of the residential uses are Build to Rent. This will ensure that it is viable for the most suitable residential mix to come forward on sites.
Comment
Greater Cambridge Local Plan Preferred Options
H/HM: Housing mix
Representation ID: 57284
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS notes that proposed policy H/HM states that exceptions to the specified housing mix will be allowed where an alternative housing mix is justified by site specific circumstances, such as local character, the built form of the new development, affordable housing demand on the councils’ housing registers, and the existing housing mix in the surrounding area. USS supports this caveat as individual sites often have very different circumstances, which can impact the most appropriate mix of uses.
USS notes that proposed policy H/HM states that exceptions to the specified housing mix will be allowed where an alternative housing mix is justified by site specific circumstances, such as local character, the built form of the new development, affordable housing demand on the councils’ housing registers, and the existing housing mix in the surrounding area. USS supports this caveat as individual sites often have very different circumstances, which can impact the most appropriate mix of uses.
Comment
Greater Cambridge Local Plan Preferred Options
H/HD: Housing density
Representation ID: 57285
Received: 10/12/2021
Respondent: Universities Superannuation Scheme (Commercial)
Agent: Deloitte
USS is supportive of the ambitions of proposed policy H/HD to deliver site specific appropriate net densities across Greater Cambridge, taking advantage of opportunities to deliver higher densities on sites with good accessibility subject to local character considerations. It is important that sites in the most sustainable locations are used in the most efficient way.
USS is supportive of the ambitions of proposed policy H/HD to deliver site specific appropriate net densities across Greater Cambridge, taking advantage of opportunities to deliver higher densities on sites with good accessibility subject to local character considerations. It is important that sites in the most sustainable locations are used in the most efficient way.
