Greater Cambridge Local Plan Preferred Options

There is mounting research to suggest that Biodiversity Net Gain policies and measurement systems are widely unsuccessful in achieving their stated aims, eg https://kar.kent.ac.uk/88387/

Where BNG is to be achieved offsite, we suggest that developers are required to demonstrate the BNG measures in practice before the housing development itself is occupied. This will provide incentive to start and to finish the BNG work

There is no absolute standard for measurement or achieved performance of the developments

There should be an objective measure for tree canopy cover, and a method of measurement. Suitable metrics and targets are not hard to find: the UK’s forestry Commission suggests urban targets of 20% canopy cover in its website :https://www.forestresearch.gov.uk/tools-and-resources/fthr/tree-canopy-cover-leaflet/

Standards for community facilities like this should not be based simply in proportion to the number of residents: there should be lower limits so that smaller developments also meet the limit allocations. This will prevent deliberate piecemeal developments that escape or make a mockery of open space requirements by reducing them to an infeasible size.
Developers should not be permitted to double-count open spaces that are intended to meet two functional and incompatible criteria. Eg. the play area at Nine Wells, Cambridge, is co-located in a rainwater catchment area, the play area is submerged for large portions of the year.

How will the Plan ensure that employment opportunities at or enabled by the developments are ones which meet descriptions of being “inclusive” beyond the statutory requirements on protected characteristics. The more pervasive and important need of inclusivity is measured against social and economic status: in particular how, specifically, can low-income family needs or accessibility needs be strongly supported?

Since the developments will inevitably be focused on high-growth, high margin, high status businesses, how can the Plan prevent the type of socio-economic exclusion in the local job market, which has so far made Cambridge “the most unequal city in the UK”?

The proposals focus mostly on features and characteristics of developments that respond to local context or specific functional needs of minority groups. These are aesthetic or function-specific interpretations of “people-responsive” and place.

By contrast, the broader human and psychological needs of communities are much more holistic, and are based on community needs of engagement and political agency: including integrated considerations of life needs, activities, and promotion of connected, coherent, participatory collective spaces.

With the current narrow focus of the proposals, the developments will continue to be heart-less, community-poor, and without a collective spirit of belonging: as most current developments are.

The current policies carried over from 2018 seem to have little protective effect: in practice the Green Belt seems to be “protected until someone with economic power wants another piece”, as exemplified by the relentless progress of the Biomedical campus and other nearby developments into the Green Belt.

The plan should list specific and very exceptional circumstances that might allow for further destruction of the green belt, and should more clearly demand alternatives of at least equal size and environmental benefit in the area if more land is taken out of Green Belt

We would like to see very strongly worded policies to protect existing neighbourhoods from the incremental impact of inappropriate conversions/creation of HMOs

The plan states “Our new development strategy aims to meet our increased need for new homes in a way that minimises our environmental impacts and improves the wellbeing of our communities.”

As argued above (in the new jobs and homes section), the primary driving force in the Cambridge housing market is for external investors to profit from the bubble that is the housing market. It is this which should be regulated, as it is so heavily resourced that it will always outpace any feasible increase in housing supply. Understanding this is critical to having a planning strategy that works. The “need” for new homes will be met with higher and higher prices paid by investors, which will push home ownership and even rental out of the reach of an increasing number of Cambridge residents.

Additionally, the plan will not improve community wellbeing. The plan will create increased capital growth for landowners, developers, and business owners. As described in the book “The Spirit Level” (2010), this has been conclusively and objectively shown to drive up inequality, and drive down community wellbeing. It is widely publicised that Cambridge is the UK city with the highest level of income inequality. This is a clear and direct consequence of the economic growth strategy which the plan presents as “good” for the city.


We also question the strategy, which is already very heavily reliant on new build housing, to allow for 10% more housing than the objectively assessed needs using a high-end estimate. Why should there be a contingency for an under-estimate by the plan (so ask for more), instead of an over-estimate (so ask for fewer), when the strategy is already taking a more optimistic view of growth than the Standard Method? Surely the “contingency” for high growth is already factored in the very use of a jobs-drive model vs the Standard Method? There is no objectively-supportable argument for this extra 10% “contingency”.