Greater Cambridge Local Plan Preferred Options

This policy supports employment development in use classes E(g) (office, R&D, light industry), B2 (general industry) and B8 (storage and distribution) particularly in the strategic sites, Areas of Major Change and Opportunity Areas. The department benefits from permitted development rights to change the use of a building/site from a wide range of uses falling in Class E to a state-funded school. While we recognise the intense demand for employment space in Greater Cambridge, we recommend the councils take a pragmatic approach to new employment development which recognises the longer-term ability for E(g) uses to change to education, and the benefits education brings to the local labour market.

CMS will create jobs as well as developing a skills pipeline to higher education and industry, focusing specifically on STEM, so this sort of provision should be explicitly supported in the plan. The councils should recognise the long-term benefits of specialist education provision that produces the next generation of business owners and employees in the fields identified in the Employment Land and Economic Development Evidence Study – life sciences, ICT, professional services and advanced manufacturing. We therefore request some flexibility in the policies and site allocations, recognising the direct and indirect employment benefits of education facilities such as CMS.

The department welcomes the plan’s reference to diversification of uses on high streets potentially improving their appeal to local communities. While education is not necessarily a town centre use, it can lead to significantly increased footfall in struggling retail areas. CMS will have up to 200 students aged 16-19, with a high degree of independence in shopping, eating out and supporting the night-time economy. We recommend that the final policy makes an allowance for education as a use which can support the long-term vibrancy and appeal of town and city centres. This would be consistent with the amended Use Classes Order which allows many town centre uses to be changed to a state-funded school without express planning consent. We recommend that Greater Cambridge policies accept the principles of that legislative framework, rather than attempting to block permitted development rights through Article 4 Directions.

We welcome the proposed policy direction that specialist education facilities will be supported where they make efficient use of land, facilitate active travel, reduce car parking and introduce active frontages at ground floor level.

We recommend that the supporting text with this policy makes a distinction between privately operated and state-funded education, in view of the bearing this can have on changes of use under permitted development rights. The department makes use of permitted development rights when appropriate, but also welcomes the opportunity to work with local planning authorities on comprehensive plans for regeneration and successful place-making, including sustainable transport planning and innovative design. New school buildings will be net zero carbon in operation, as set out in OS21 and referenced elsewhere in this consultation response.

The department supports the policy direction but we request that the councils recognise that some uses are justified and important despite generating trips from a wider sub-regional area. The department will comply with policy requirements regarding Transport Assessments and Travel Plans, to minimise the need to travel by car and ensure that public transport is an accessible and appealing option for all students, staff and visitors to CMS. We request that the plan makes it clear that the principle of education infrastructure will be supported, accepting that specialist and further education can draw students from a wider catchment area than local primary and secondary schools. Close proximity to suitable public transport is therefore essential to meeting the plan’s carbon reduction objectives.

We note that developers will be required to deliver infrastructure directly or contribute through Section 106, CIL or its successor. We welcome the reference to development creating additional demand for infrastructure and services, so it is reasonable for developers to address these needs to make development sustainable. We have published guidance for local authorities on securing developer contributions for education, and you will also be aware of Planning Practice Guidance specifically relating to education in the chapters on viability, planning obligations and safe and healthy communities.

With regard to the emerging Infrastructure Delivery Plan and Viability Assessment, we can offer the following general advice regarding education.

The next version of the Local Plan should seek to identify specific sites (existing or new) which can deliver the school places needed to support growth, based on the latest evidence of identified need and demand in the Infrastructure Delivery Plan. The site allocations should also seek to clarify requirements for the delivery of new schools, including when they should be delivered to support housing growth, the minimum site area required, any preferred site characteristics, and any requirements for safeguarding additional land for future expansion of schools where need and demand indicates this might be necessary. Establishing these requirements within the plan is particularly important for securing sites at an appropriate value when additional land or standalone sites for schools need to be purchased, as DfE ‘Basic Need’ funding allocations do not factor in the costs of site acquisition.

Viability assessment should inform options analysis and site selection, with site typologies reflecting the type and size of developments that are envisaged in the borough/district. This enables an informed judgement about which developments would be able to deliver the range of infrastructure required, including schools, leading to policy requirements that are fair, realistic and evidence-based. In accordance with Planning Practice Guidance, there should be an initial assumption that applicable developments will provide both land and funding for the construction of new schools. The total cumulative cost of complying with all relevant policies should not undermine deliverability of the plan, so it is important that anticipated education needs and costs of provision are incorporated at the outset, to inform local decisions about site selection and infrastructure priorities.

While it is important to provide this clarity and certainty to developers and the communities affected by development, retaining a degree of flexibility about site specific requirements for schools is also necessary given that the need for school places can vary over time due to the many variables affecting it. The department therefore recommends the Council consider highlighting in the next version of the Local Plan that:
- specific requirements for developer contributions to increasing capacity of existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that
- requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use.

One of the tests of soundness is that a Local Plan is ‘effective’, meaning the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the school places required to meet the increase in demand generated by new developments.

The councils should set out education infrastructure requirements additional for the plan period within an Infrastructure Funding Statement . Where additional need for school places will be generated by housing growth, the statement should identify the anticipated CIL and/or Section 106 funding towards this infrastructure. The statement should be reviewed annually to report on the amount of funding received via developer contributions and how it has been used, providing transparency to all stakeholders.

Local authorities have sometimes experienced challenges in funding schools via Section 106 planning obligations due to limitations on the pooling of developer contributions for the same item or type of infrastructure. However, the revised CIL Regulations remove this constraint, allowing unlimited pooling of developer contributions from planning obligations and the use of both Section 106 funding and CIL for the same item of infrastructure. The advantage of using Section 106 relative to CIL for funding schools is that it is clear and transparent to all stakeholders what value of contribution is being allocated by which development to which schools, thereby increasing certainty that developer contributions will be used to fund the new school places that are needed. The department supports the use of planning obligations to secure developer contributions for education wherever there is a need to mitigate the direct impacts of development, consistent with Regulation 122 of the CIL Regulations.
38. We also request a reference within the Local Plan’s policies or supporting text to explain that developer contributions may be secured retrospectively, when it has been necessary to forward fund infrastructure projects in advance of anticipated housing growth. An example of this would be the local authority’s expansion of a secondary school to ensure that places are available in time to support development coming forward. This helps to demonstrate that the plan is positively prepared and deliverable over its period.

The department would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Infrastructure Funding Statement, viability assessment or other evidence relevant to education which may be used to inform local planning policies and CIL charging schedules. As such, please add the department to the database for future consultations on relevant plans and proposals.

In our response to the Area Action Plan consultation for North East Cambridge in 2019, the department suggested that a D1 use (now F1) of the type and specialism described would be complementary to the high tech science park and the university, while fitting well within the proposed residential-led mixed use development. The location close to the new railway station was considered highly suitable for CMS, given the larger-than-local catchment area for the school and the need to encourage sustainable travel choices. We requested that a site be allocated for a school within the larger mixed use allocation.

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.

We note that the proposed policy direction is to direct development to locations that have the least climate impact, where active and public transport is the natural choice, and where green infrastructure can be delivered alongside new development.

The department supports this approach, and would like to emphasise the importance of proactive planning of educational facilities when sites are actively being sought. The Local Plan provides an opportunity to plan strategically for education uses that maximise sustainable transport choices and create an employment pipeline for the Greater Cambridge area.

CMS is an approved specialist maths school for up to 200 16-19 year olds. The government has committed to having a maths school in every region, building upon the success of Exeter, King’s and the University of Liverpool Maths Schools, which have already opened in partnership with their local universities. The University of Cambridge, Isaac Physics and Cambridge Mathematics are strategic partners to CMS. Please see the attached letters of support from the University of Cambridge and Cambridgeshire County Council.

The department has secured a temporary site for CMS at 119 Mill Road, with the intention of opening at reduced capacity until a permanent site can be delivered. This should demonstrate our commitment to opening CMS, and we request that the councils work with us to deliver the permanent school building in the best available location and with minimal delay. The department makes use of permitted development rights where appropriate, but also wishes to explore options for strategic site allocations with the best public transport connectivity, as outlined in our response to the North East Cambridge Area Action Plan consultation. We believe it is in everyone’s best interests to deliver CMS in the most sustainable location.

If CMS is delivered as a freestanding new build, it will require a site of 0.5 acres (minimum 0.2 acres). Ideally there would be an area of external space but as a sixth form college CMS will not need sports provision/playing fields. If the school is delivered in an existing building, there is a space requirement of 2,450 square metres GIFA.

The department notes that the plan’s vision focuses on reducing climate impacts while increasing quality of everyday life for communities. New development must minimise carbon emissions and reliance on the private car, create thriving neighbourhoods, increase green space and safeguard heritage and landscapes. We support the strategic aim to provide infrastructure, including educational facilities, in the right places and built at the right time to serve growing communities.

Consistent with paragraph 94 of the National Planning Policy Framework, we recommend that the plan adopts a positive approach to new state-funded education facilities in order to deliver on this strategic aim and the plan’s overall vision. All new schools delivered by DfE will be net zero carbon in operation, they make an invaluable contribution to new and existing communities, and (depending on the type of facility) create additional sports provision which can be made accessible to the wider community. Cambridge Maths School (CMS) in particular will diversify educational opportunities and create jobs, while also delivering on the Local Plan’s environmental objectives. This school represents a significant public sector infrastructure investment in Cambridge, providing free state education to the most talented pupils aspiring to careers in STEM sectors.