Greater Cambridge Local Plan Preferred Options

New jobs and homes:
Our view is that the number of planned new homes should be significantly lower. The 31,500 homes already provided for in the adopted Local Plans are more than sufficient for a 5-year housing supply according to objectively assessed needs (see notes below). Given the exceptional circumstances we are living through, it makes sense to keep housing demand under review rather than committing to build according to high forecast growth.

We note the statement made by the Planning Authority during the webinars that “If we don’t have enough certainty about water supply, we will have to look at a stepped trajectory or reducing the amount of housing we plan for”. Officers also noted that “Quick and decisive action [is] required by central government and the water industry – this is out of our hands as a Local Planning Authority”. We agree and would support the Planning Authority in any attempt to reduce or at least delay house building from the central government allocation. Based on conversations we have had with Cambridge Water, we believe that while there might be ideas on supplying more water in the future we can see no achievable commitment. We note Natural England’s Position Statement for Applications [1] within the Sussex North Water Supply issued in September, which states that, "Developments within Sussex North must therefore must not add to this impact and one way of achieving this is to demonstrate water neutrality … As it cannot be concluded that the existing abstraction within Sussex North Water Supply Zone is not having an impact on the Arun Valley site, we advise that developments within this zone must not add to this impact.”

Notes: For an objective assessment we quote household projections by the Office for National Statistics. We note that the more recent the assessment the lower the number projected (Table 1). In the most recent projections (2018 based) the projected increase between 2020 to 2041 is 7,900. Since this projection was calculated there have been two hugely significant events: Brexit and COVID-19. The National Planning Policy Framework allows that “any other method [other than use of 2014 based projections] will be used only in exceptional circumstances”. We hold the view that leaving the EU, COVID, together with climate change are exceptional circumstances and would welcome a plan based on these.

It is worth noting that the 2014-based household projection for 2020 for Greater Cambridge was 119,400 households. In the 2018 based projections the estimate for 2020 is 108,500, so in four years the 2014-based projections have over-projected by around 10,000 households.
Table 1: Projected household change, Cambridge and South Cambridgeshire, 2020-2041
Projection Number of households 2020-2041
CLG 2014 based c. 23,600
ONS 2016 based 12,200
ONS 2018 based 7,900
Source: CLG and ONS household projections. 2014 based ends at 2039, so the 2041 figure is from a simple assumption of continuing change.

The number of houses built over the last five years (2015/16 to 2019/20) averages 1,750 a year. While need is not as simple as applying that to the future, 31,500 homes would last for more than 15 years at that rate.

[1] https://www.horsham.gov.uk/__data/assets/pdf_file/0019/106552/Natural-Englands-Position-Statement-for-Applications-within-the-Sussex-North-Water-Supply-Zone-September-2021.pdf

We broadly support the proposed policy direction in terms of where development should be focused (where it has the least climate impact etc). Our main concern, as detailed in previous sections, is the amount of development proposed.
We do however wish to raise concern over the amount of Green Belt that is likely to be destroyed through these plans. In particular, the NE Cambridge development is referred to as being on brownfield land, but this is only made possible by displacing Cambridge Wastewater Treatment works to Honey Hill, which is in the Green Belt.
As a general point, existing buildings should be re-used wherever possible before new building is considered (“The Greenest building is the one that already exists”– Carl Elefante [1]).
We have commented on some of the specific area proposals under the relevant sections.
[1] https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists

North East Cambridge:
We have previously commented in detail on the plans for NE Cambridge [1]. We welcome some of the changes made to the Area Action Plan following the consultation, notably the increase in green space provision, reduction in building heights, and the rebalancing of jobs and homes which has been achieved through a reduction in the area of commercial office space. However, we remain essentially opposed to this development on the following grounds: a) although on a brownfield site, the development will directly cause the destruction of Green Belt land by displacing the Waste Water Treatment Works to Honey Hill. There is no operational need for the works to move; the proposal is purely to create development opportunity. b) As set out in our response to S/JH, we believe that the number of new houses already committed in the adopted Local Plans is sufficient to meet objectively assessed need: therefore we do not agree with bringing additional large developments forward at this point.
[1] https://southcambs.greenparty.org.uk/assets/images/local_parties/southcambridgeshire/NE%20Cambridge%20Development%20Sep2020.pdf

Opportunity Areas in Cambridge:
S/OA/NR and S/OA/BC (Newmarket Road Retail Park and Beehive Centre)
We agree that Newmarket Road Retail Park and the Beehive Centre are not the best use of this land. The retail park model places great emphasis on access by car, disadvantages small independent businesses, and contributes to the decline of high streets. We would welcome proposals to redevelop these areas to meet identified needs.
S/OA/AS (Abbey Stadium)
Abbey Stadium provides community support to a number of individuals and organisations in and around Cambridge, and is popular with local residents. Currently the stadium's location and associated infrastructure results in significant impact to local residents through parking in and around surrounding streets during Men's Football games on Football Match days. Any proposed change of use should take into account the entire local impact of the new proposed change of use, specifically how visitors are likely to travel to the site, and how public transport use can be integrated into any change of use.

S/C/SCL (Land south of Coldham’s Lane):
We have previously objected to the planning application for land south of Coldham’s Lane [1]. Our concerns related to an absence of proper accounting for the predictable and significant short-term impacts of the proposed development (increased traffic, type of traffic (i.e lorries) and congestion; high likelihood of pollution and flooding; negative impact on biodiversity). We also felt there was insufficient analysis of management and funding implications for the proposed urban country park in this application. We would want to see these issues fully addressed in future policy.
[1] https://cambridge.greenparty.org.uk/site/Cambridge/files/Green%20Party%20response_ColdhamsLanePlanningAp_2102326FUL.pdf

Edge of Cambridge - general comments:
We are very concerned at the apparent lack of consideration for Cambridge’s historic environment. For example, the Green Belt assessment omits consideration of historic environment designations and landscape character constraints. We agree with Cambridge Past, Present and Future’s policy statement that “preventing urban sprawl so as to protect the setting of the historic city is irreconcilable with continued city fringe development.” [1]
[1] https://www.cambridgeppf.org/cambridgeppf-green-belt-policy

Cambridge East:
Any development at Cambridge East must first and foremost benefit local people. This is a deprived area within our affluent city which is in desperate need of good quality green and community spaces. We have previously shared a radical alternative proposal for the land at Marshalls [1].
[1] https://greens4abbey.org.uk/true-green-project/

How much development, and where – general comments:
We accept that development has a part to play in ensuring the people of Greater Cambridge have suitable homes and employment, and recognise that our area hosts jobs with national and international significance. However, we think that the specific number of jobs needs to be revised to take account of the potentially huge repercussions of Brexit and COVID. These are likely to have implications for the amount, type and location of land needed. Specifically, we strongly believe that the ‘predict and provide’ approach being taken to determine “how much development” is flawed and will lead to highly negative outcomes.
● This approach fails to take environmental constraints as its starting point. The carbon budget referred to previously is one such constraint. Water supply, and the ability to process wastewater, is another. The Planning Authority has emphasised that “delivery of the proposals in the plan is contingent on water supply being adequate without causing further environmental harm”. They have said that the planned reservoirs and improvements to supply will likely be delivered too late in the planned period to meet the preferred development trajectory. Interim measures are being investigated by the water industry but there are no firm plans yet. The Draft Regional Water Plan for Eastern England is not expected until next year. Given these considerations, it is clearly premature to proceed on the assumption that it will be possible to deliver the ‘desired’ level of development. We understand that the ambitious new standards set out in the First Proposals (for example on energy and water efficiency) cannot be applied to the major developments that have already been granted outline permissions. Furthermore, building that takes place under Permitted Development Rights cannot be required to comply with these policies. This only serves to strengthen the point that the level of development planned for our region will have massive environmental consequences which cannot be fully mitigated through efficiency standards, however ambitious.
● The justifications for seeking continued high growth of the Greater Cambridge economy are flawed. The language used, suggesting the Greater Cambridge economy is special or unique, echoes the government’s rhetoric about the OxCam Arc, which has been pulled apart by commentators including Smart Growth UK [1]. Furthermore, as the Planning Authority acknowledges, our booming economy has come at the cost of a huge housing affordability problem. We do not see evidence that any attempt is being made to learn from the failures of previous policies. For example, how will the Local Plan ensure that new developments are for local people, not dormitories for London commuters or merely opportunities for investors? What evidence is there that the proposed growth will address the problems faced by the poorest people in our society or reduce inequality within the region? Furthermore Cambridge is a city with the highest level of inequality in the UK. So our present high growth has not been good for all Cambridge citizens.
● The approach places too much emphasis on modelled growth in employment. The high uncertainty levels involved in making such forecasts, particularly in light of Brexit and COVID-19, are acknowledged. It therefore seems inappropriate that the Local Authority is using these figures to argue for a higher housing allocation than that calculated by central government. Furthermore, given environmental constraints, the most likely growth forecast is not necessarily the most desirable. The Planning Authority should be looking to manage growth, not anticipate and stoke it.
● The approach does not take account of the changing national policy context. Current Local Authority housing allocations were calculated using an algorithm that measures housing demand based on market growth, prioritising house building in areas that are already booming. New Secretary of State Michael Gove has expressed his intention to review this approach with a view to achieving “a fairer and more equitable distribution of need across the country” [2].
During the First Proposal webinars, the Planning Authority indicated that the proposed levels of growth are necessary, and that their aim with the Local Plan is to deliver this growth in as sustainable a way as possible. Based on the above points, we contend that the proposed level of growth is neither necessary nor desirable.

[1] https://smartgrowthuk.org/wp-content/uploads/2021/09/The_Overheated_Arc_Part_3_September_2021.pdf
[2] https://www.planningresource.co.uk/article/1734830/we-want-fairer-distribution-housing-need-across-country-says-gove

We broadly support the vision and aims as set out in the First Proposals. However, as explained in later sections of our response, we do not believe this plan can achieve them.
For example, “We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities.” This very laudable aim would only be achieved through a strategy that took as its starting point the challenges experienced in our existing built environment - for example energy inefficient buildings and congestion in Cambridge city centre. It is nonsensical to claim that “a big decrease in our climate impacts” can be achieved through building thousands of new homes.

Cambridge urban area - general comments:
Our city has massive environmental capacity issues, with inadequate space in the streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth considered only if they can be resolved.
We agree that “development must also be carefully designed to respect the historic character of the city” but are concerned that this aspiration does not appear to be backed up by detailed plans or evidence. For example, the analysis of Green Belt areas and their characteristics does not include historic environment designations (even though the Green Belt was set up to protect the setting of the historic University city). The claim in the Strategic Heritage Impact Assessment that “future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity" is not supported by evidence.