Greater Cambridge Local Plan Preferred Options
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Greater Cambridge Local Plan Preferred Options
STRATEGY
Representation ID: 57474
Received: 10/12/2021
Respondent: ESFA (Department for Education)
Please see attached letter.
Please see attached letter.
Comment
Greater Cambridge Local Plan Preferred Options
S/NEC: North east Cambridge
Representation ID: 57476
Received: 10/12/2021
Respondent: ESFA (Department for Education)
We note that the proposed policy direction for Policy S/NEC includes schools among the necessary infrastructure to be provided. As well as providing new
school places directly linked to the need from housing growth, the councils should have regard to the NPPF requirement to allow for sufficient choice of school
places, giving great weight to the need to widen choice in education (para 94). CMS would be instrumental in diversifying educational opportunities for this new
community, the rest of Cambridge and the wider sub-region. The local education authority, Cambridgeshire County Council, has provided the attached letter of
support, and confirmed they would also consider supporting alternative sites for CMS provided they are equally accessible by public transport and offer equally
good connectivity for students travelling from a wide area. If a site for CMS within the NEC allocation were secured, the department would work closely with the councils to ensure the development accorded with the NEC Trip Budget, making sustainable transport the most attractive option for students and staff.
Please see attached letter.
Comment
Greater Cambridge Local Plan Preferred Options
S/DS: Development strategy
Representation ID: 57477
Received: 10/12/2021
Respondent: ESFA (Department for Education)
Please see attached letter.
Please see attached letter.
Comment
Greater Cambridge Local Plan Preferred Options
S/AMC: Areas of major change
Representation ID: 57478
Received: 10/12/2021
Respondent: ESFA (Department for Education)
While we are interested in delivering the permanent Cambridge Maths School site within the North East Cambridge site if possible, the department is also considering alternative options. Our response to the previous Local Plan consultation requested reference within the site allocation policies for Areas of Major Change to the potential inclusion and acceptability of D1 (now F1) uses. Express support for education use within these policies would create a more positive policy context for education provision.
While we are interested in delivering the permanent Cambridge Maths School site within the North East Cambridge site if possible, the department is also considering alternative options. Our response to the previous Local Plan consultation requested reference within the site allocation policies for Areas of Major Change to the potential inclusion and acceptability of D1 (now F1) uses. Express support for education use within these policies would create a more positive policy context for education provision.
Comment
Greater Cambridge Local Plan Preferred Options
S/OA: Opportunity areas in Cambridge
Representation ID: 57479
Received: 10/12/2021
Respondent: ESFA (Department for Education)
The department notes that existing opportunity areas are being carried forward from the existing local plans and two new ones are being created at Newmarket Retail Park and the Beehive Centre. We welcome the recognition that the urban retail landscape is changing and these sites present an opportunity to reimagine these places close to the heart of Cambridge. Please consider education among the potential suitable uses within these areas, subject to other criteria such as active and sustainable travel. Education development can be a complementary use which increases footfall in retail areas that may be struggling to remain viable.
The department notes that existing opportunity areas are being carried forward from the existing local plans and two new ones are being created at Newmarket Retail Park and the Beehive Centre. We welcome the recognition that the urban retail landscape is changing and these sites present an opportunity to reimagine these places close to the heart of Cambridge. Please consider education among the potential suitable uses within these areas, subject to other criteria such as active and sustainable travel. Education development can be a complementary use which increases footfall in retail areas that may be struggling to remain viable.
Comment
Greater Cambridge Local Plan Preferred Options
CC/NZ: Net zero carbon new buildings
Representation ID: 57481
Received: 10/12/2021
Respondent: ESFA (Department for Education)
Welcome ambitions to deliver net zero carbon buildings. We published new Output Specification (OS21), outlining how all school buildings will be net zero carbon in operation. Unclear whether policy will require whole-life net zero carbon (considerably higher bar than net zero in operation) or only consideration/calculation of embodied carbon.
OS21 is broadly aligned with proposed net zero requirements and other climate change policies, exceeding requirements in several areas. Need further detail and clarity on some requirements. Request flexibility on assessment methodologies used to demonstrate whole-life carbon and the energy performance gap. To ensure development is not unnecessarily burdened or delayed, recommend flexibility on application of requirements so measures which exceed requirements in some areas may be balanced against marginal under-provision in others, to demonstrate overall compliance. Requiring absolute adherence to each criterion without any holistic consideration of the merits of development would undermine sound professional and balanced judgement.
The department welcomes the councils’ ambitions to deliver net zero carbon buildings. In November 2021 we published a new Output Specification (OS21), outlining how all our school buildings will be net zero carbon in operation. It is unclear at present whether the Local Plan policy will require whole-life net zero carbon (a considerably higher bar than net zero in operation) or only consideration/calculation of embodied carbon.
OS21 is broadly aligned with the proposed net zero requirements and other climate change policies, exceeding the requirements in several areas. There will need to be further detail and clarity on some of the requirements. We request flexibility on the assessment methodologies that may be used to demonstrate whole-life carbon and the energy performance gap. To ensure that development is not unnecessarily burdened or delayed, we also recommend flexibility on the application of the requirements so that measures which exceed requirements in some areas may be balanced against marginal under-provision in others, to demonstrate overall compliance. Requiring absolute adherence to each criterion without any holistic consideration of the merits of development would undermine sound professional and balanced judgement.
Comment
Greater Cambridge Local Plan Preferred Options
BG/BG: Biodiversity and geodiversity
Representation ID: 57482
Received: 10/12/2021
Respondent: ESFA (Department for Education)
It appears that this policy will be more specific and onerous than OS21, so there would be an additional cost to compliance which the councils should carefully consider, both in terms of cost to public purse and knock-on effect on requests for developer contributions to reflect higher cost of education provision.
May be opportunities for strategic planning of biodiversity net gain on existing education sites, to facilitate new school development and new housing elsewhere in the Greater Cambridge area. Recommend you work with Cambridgeshire County Council, further/higher education providers and other partners to explore how the education estate might deliver biodiversity net gain and support sustainable development.
It appears that this policy will be more specific and onerous than OS21, so there would be an additional cost to compliance which the councils should carefully consider, both in terms of the cost to the public purse and the knock-on effect on requests for developer contributions to reflect the higher cost of education provision.
There may be opportunities for strategic planning of biodiversity net gain on existing education sites, to facilitate new school development and also new housing elsewhere in the Greater Cambridge area. We recommend that you work with Cambridgeshire County Council, further/higher education providers and other partners to explore how the education estate might deliver biodiversity net gain and support sustainable development.
Comment
Greater Cambridge Local Plan Preferred Options
BG/GI: Green infrastructure
Representation ID: 57483
Received: 10/12/2021
Respondent: ESFA (Department for Education)
As with Policy BG/BG, this policy appears more specific and onerous than OS21, but the strategic outcomes are the same. We request a degree of flexibility and pragmatism in the final drafting of this policy.
As with Policy BG/BG, this policy appears more specific and onerous than OS21, but the strategic outcomes are the same. We request a degree of flexibility and pragmatism in the final drafting of this policy.
Comment
Greater Cambridge Local Plan Preferred Options
BG/PO: Protecting open spaces
Representation ID: 57484
Received: 10/12/2021
Respondent: ESFA (Department for Education)
This policy does not distinguish between public open space and open space on education sites that in most cases is not accessible to the wider community. The plan recognises that in some cases development on open space may be appropriate if it has limited qualities and the development would lead to an overall improvement in quality or quantity. The department welcomes this approach, and recommends that on education sites, the loss of open space is considered on the basis of whether it is still needed (as demonstrated by the applicant) and what mitigations are proposed, such as enhanced quality of remaining open space or more inclusive accessibility.
This policy does not distinguish between public open space and open space on education sites that in most cases is not accessible to the wider community. The plan recognises that in some cases development on open space may be appropriate if it has limited qualities and the development would lead to an overall improvement in quality or quantity. The department welcomes this approach, and recommends that on education sites, the loss of open space is considered on the basis of whether it is still needed (as demonstrated by the applicant) and what mitigations are proposed, such as enhanced quality of remaining open space or more inclusive accessibility.
Comment
Greater Cambridge Local Plan Preferred Options
WS/CF: Community, sports and leisure facilities
Representation ID: 57485
Received: 10/12/2021
Respondent: ESFA (Department for Education)
Difficulty (with following the national policy sequential approach) is that education would not normally be considered a main town centre use, and new school or college serving a city-wide or sub-regional area (such as CMS) might be pushed towards city centre location without genuine justification in national policy. Request policy makes clear that education facilities serving a wider catchment area will not be considered a town centre use requiring sequential approach to be applied, but that any such facilities must be located in sustainable, accessible locations.
Welcome recognition that easy access to good quality educational provision is important for supporting economic growth, developing strong sustainable communities, promoting economic prosperity and sustaining quality of life. Plan states that new and replacement facilities should facilitate the growth of the area by providing sufficient capacity to accommodate community need and demand. Request an addition, explaining that in some cases this will include wider sub-regional community demand, and for educational facilities there is a national policy requirement to provide a sufficient choice of school places, which is not necessarily same as meeting a capacity need within a specific pupil place planning area.
This policy specifically includes educational facilities. The proposed policy direction is to support development of new facilities in appropriate locations where there is a local need for the facilities, and they are in close proximity to the people they will serve. New or replacement major facilities serving the city, or where appropriate the sub-region, would need to follow the sequential approach to main town centre uses established by national policy, and be located in sustainable, accessible locations.
The difficulty with this is that education would not normally be considered a main town centre use, and a new school or college serving a city-wide or sub-regional area (such as CMS) might be pushed towards a city centre location without a genuine justification in national policy. We request that the final policy makes it clear that education facilities serving a wider catchment area will not be considered a town centre use requiring the sequential approach to be applied, but that any such facilities must be located in sustainable, accessible locations.
The department welcomes the plan’s recognition that easy access to good quality educational provision is important for supporting economic growth, developing strong sustainable communities, promoting economic prosperity and sustaining quality of life. The plan states that new and replacement facilities should facilitate the growth of the area by providing sufficient capacity to accommodate community need and demand. We request an addition to this, explaining that in some cases this will include wider sub-regional community demand, and that for educational facilities there is a national policy requirement to provide a sufficient choice of school places, which is not necessarily the same as meeting a capacity need within a specific pupil place planning area.
