Greater Cambridge Local Plan Preferred Options

In the second paragraph, it should refer to "This means regenerating or enhancing parts of the city that aren’t fulfilling their potential," not just "This means regenerating parts of the city that aren’t fulfilling their potential,"

The Topic Paper on Biodiversity seeks to provide justification for the proposed minimum 20% biodiversity net gain requirement, above the 10% requirement in the Environment Act. The Topic Paper focusses on the benefits of a 20% requirement rather than its practical deliverability, and it acknowledges that “Given the widespread application of BNG is still emerging, there is clearly further site-specific viability testing required of alternative BNG percentage requirements”. At present, ARU cannot support a requirement in excess of the national requirement of 10%.

The proposed policy direction should begin "Recognising that they make a significant contribution to society, we propose to support new or enhanced faculty and specialist facilities/development in Greater Cambridge which meet the following requirements:... " rather than "We propose to support new faculty and specialist facilities/development in Greater Cambridge which meet the following requirements:..." to explicitly recognise the significant contribution these facilities provide and to recognise that support should be provided to enhanced as well as new facilities.

Under the Why is this policy needed? the third paragraph should state that "ARU provides a significant contribution to the City through promoting access to higher education for a wide breadth of society with the resulting societal and wellbeing benefits. ARU has made significant investment in its East Road sites and it is considered that the broader East Road area will remain a focal point for the University through the plan period, though with innovative schemes for potential shared services or interconnectivity across the City to be supported " rather than "Anglia Ruskin University has made significant investment in its East Road sites which remain the most sustainable location for future investment." in order to reflect ARU's role and plans. Anglian Ruskin University should also be referenced throughout the Local Plan as ARU rather than Anglian Ruskin University.

Under the What consultation have we done on this issue? Anglia Ruskin University should be referenced as ARU and the bullet point text should state that "ARU is developing a new masterplan for their Cambridge campus on East Road. This will focus on consolidation and refurbishment and/or redevelopment of campus buildings with further adaption to provide blended learning/teaching with a mix of on campus and off-site learning and teaching using digital technologies. Opportunities for expansion of the campus through new acquisitions is also being explored." rather than "Anglia Ruskin is developing a new masterplan for their Cambridge campus on East Road. This will focus on consolidation and refurbishment of campus buildings with further adaption to provide blended learning/teaching with a mix of on campus and off-site learning and teaching using digital technologies." This is necessary to recognise that redevelopment as well as consolidation and refurbishment is/will be considered and new acquisitions are also being explored.

Whilst it is accepted that there is a need to manage the general, relative proportions of residential and student accommodation, the statements that “Proposals will not be supported where they involve the loss of existing and planned residential accommodation” and “Existing student accommodation will continue to be protected to avoid increasing demand for housing in the private rental market” are unduly restrictive in that individual sites are effectively required to remain in their current general residential or student use whilst either/both contribute towards delivering the overall housing requirement. More flexibility in relation to individual sites should be included.

ARU supports a Net Zero Carbon policy which aligns with its own Zero Carbon targets. ARU also agree that requirements should be ambitious but also need to be realistic/deliverable. It is though considered that requirements such as these are best set at a national level, with consistent methodologies (and expertise). Any policy also needs to differentiate between new buildings and refurbished buildings, recognising the difficulty in refurbishments meeting the same standards as new buildings.

Notwithstanding these comments, the policy needs to clarify that m2 refers to GIA and clarify that Total Energy Use Intensity (EUI) targets exclude renewable energy contribution. Higher education teaching facilities EUI targets also need amending and disaggregating as follows:
a. General HE teaching space – 65 kWh per m2 per year
b. HE science/lab/medical teaching/research space – 150 kWh per m2 per year
c. HE office space – 55 kWh per m2 per year

In the second paragraph the wording should be revised to state "Alongside this we will plan for the business space, supporting community facilities, green spaces, infrastructure and access to excellent education provision to meet the needs of our growing communities " rather than "Alongside this we will plan for the business space, supporting community facilities, green spaces and infrastructure to meet the needs of our growing communities" to recognise the importance of access to excellent education provision as well.

In the fourth paragraph the wording should be revised to state "This means providing opportunities to regenerate or enhance areas that aren’t yet reaching their potential,..." rather than "This means providing opportunities to regenerate areas that aren’t yet reaching their potential,..." to recognise that areas can/should be improved through regeneration or enhancement.