Greater Cambridge Local Plan Preferred Options

Critically important.

Critically important.

Critically important.

Critically important.

GENERAL – SUMMARY
The objections to the currently proposed Local Plan (the Plan) for Greater Cambridge (GC) are in summary:
No recognition of the existing importance of inward commuting under existing conditions, the likelihood this will increase in future and the opportunity this presents for levelling up by sharing housing growth with nearby areas.
Overestimation of the likely jobs growth given the changes in employment, the likely loss of growth and changes in the economy that have occurred in the first 10% of the plan period.
Overestimation of the housing growth needed in the GC area due to the in-combination effect of the above factors
The adverse consequences of the avoidable, extra planned housing growth in GC namely:
a) Requiring an unsustainable inward migration to the area.
b) Further negating the desirable objectives of preserving the unique character of Cambridge as a compact, dynamic city with a thriving historic centre and maintaining and enhancing the quality of its setting
c) Concluding that NE Cambridge is required to include some redevelopment of the existing sewage works area for high density housing within the Plan period which now translates to proposals to destroy part of the Green Belt
d) Excessive strain on the transport systems in Cambridge
e) Excessive concentration of load on the infrastructure, particularly water supply where the Plan states an exceptional intervention would be needed to maintain supplies at the planned rate and concentration of growth in addition to an assumed reduction in household demand. There is an unaddressed threat that supply failures will be overcome by either excessive pumping of Chalk aquifers or supply restrictions, ie drought orders, to prohibit nonessential uses. Sewage treatment is also a major issue with many minor work in GC s causing intermittent pollution as a result of recent increases in population.

A Local Plan key assumption is that all 44, 400 new homes have to be allocated within Greater Cambridge (GC) area (Ref GCLP - PPSE – SEPTEMBER 2021 P21 Medium “Consume Own Smoke”) and the apparent justification given elsewhere is that this in order to minimise the Carbon Footprint of Travel and congestion. Although agreeing that travel footprint is a reasonable concern, the simplistic conclusion may be unsound because:

Objection 1 – In reality, people will continue to travel from out of area:
a) as should be known from data in the current baseline
b) with a decrease in car numbers crossing the Cam bridges measured in 2019 compared to 10 years earlier. Facts that contradict the Plan’s assumptions should be explored not ignored.
c) as needs to be shown in the future baseline
d) increasingly so as working from home becomes more prevalent so journeys into GC are less frequent for some of these workers (2 or 3 days/week?).
e) with lower carbon footprint for average working day due to c) above
f) increasingly but anecdotally, due to some people wishing to take advantage of lower housing costs and more tranquil, rural surroundings. Further evidence for the drivers for growth of in-commuting from out of the GCP area can be inferred from the Housing Market Bulletins which show that prices/m2 are much greater in Cambridge City than other districts and average and lower quartile prices also show a similar ranking but over a narrower spread.
g) increasingly so by sustainable travel as a consequence of CPCA’s plan to improve public transport which may include connections to rural hubs
h) increasingly so in the case of Rail as Network Rail creates improved connections in area at Cambridge South and Waterbeach new town and out of area, eg Soham, Wisbech, Ely capacity improvements and longer range potential such as East -West Rail and Newmarket line improvements to the east.
The Local Plan assumption does not appear to be compatible with or even tested against Network Rail’s forecasts or evidence for travel patterns from out of the area (see Figure 2 attached, ref Cambridge South Station). This is a step the Local Plan needs.
Recognising potential for more rail commuting from Fenland and East Cambridge and encouraging this in housing allocations might do a lot for the levelling up agenda in the County. Some evidence of what other Districts are planning or might aspire to for commuting to GC should be given. The comment on P26 about lack of “asking” in discussion with neighbouring authorities does not inspire confidence that the right questions have been asked.

Objection 2 – In reality, some people will continue to travel to employment out of the area:
a) The long term desire for NECAAP includes the siting of 8000 plus new houses near Cambridge North station is likely to attract such out-commuters. At the very least, the number could be assessed for the Local Plan by first quantifying then comparing the degree of out commuting from existing new developments near Cambridge Station both pre 2020 and more recently.
This is a separate point to that described in the approach to the Local Plan which predicts that some of the proposed housing near Cambridge North would lead to an increase in commuting by rail as a component of the sustainable travel within the GCP area.

ECONOMIC GROWTH AND HOUSING NUMBERS
a. SCDC use 2020 as the base with requirements for housing numbers being additive since the 2011 census. It is not clear how the base number accounts for actual completions in 2020 and 2021. If so, a buffer of 10% should not be added to what has already been built.
b. The 2021 census will give a more accurate base for the actual numbers of houses needed to meet the total need in 2041. The process for inclusion of the true 2021 figure needs to be described if it is not available before the formal consultation.
c. Employment patterns appear to be changing rapidly with a drop off in retail (and, anecdotally, low value day trip tourism) for example. If numbers of persons employed have dropped in addition to the noted drop or low growth in economic output, the overall employment target for 2041 may be too optimistic. For example if employment and output are still at 2019/2020 levels, that would equate to around 10% of the Local Plan period to 2041. The impact should be assessed and announced before the formal consultation on the Local Plan commences.
d. Changes to the planning regulations governing change of use have been announced recently. The application of the new rules should be assessed and the amount of qualifying space should be estimated if is not already known. If the change is between retail/commercial uses then the impact on the high value jobs underpinning the growth aspiration should be assessed prior to the formal consultation. Any potential for conversion of such spaces to housing should also be assessed.
e. Overall, if the jobs growth has been set back by the events of the last two years, noting the recent ONS announcement that the Uk economy is 2.1 % smaller than in Q4 2019. it is necessary to either change the forecast housing need or remove/reduce the 10% buffer.
f. 2021 Census data should also be interrogated to quantify if population growth in GC and surrounding areas has stalled or even gone negative in parallel with the economic slowdown of the last two years. A degree of ex-migration may have occurred compared to the expected inward migration to the areas.
g. The proposed medium growth +10-% strategy is objectionable as it stands because they 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 . Indeed, the impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, a 37% increase beyond 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.
h. The quoted planned average 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. The City already has one of the highest relative levels of deprivation in England and Wales with 3 LSOA’s in bottom 20% ( CN-Oct 2020).