Closing date for submission to Cambridge City Council: 30th Sept 2013
Closing date for submission to South Cambs District Council: 15 Oct 2013
If you are a Cambridge resident, or a resident in one of the SCDC villages, it is important to make your specific objections known to the official consultation process. The key steps:
- Read the “How-to” guide showing how to use the council web site to make your submission
- Read the Key Objections for Cambridge. This contains a list of specific weaknesses in the draft plan.
Objections carry weight if they point out specific flaws in the Draft Plans. We have compiled a list of key issues that the plan fails to address. You can use the list below to help you prepare your objection.
Cambridge City Draft Plan Objections
Note: all comments are entered against policy numbers (sites GB1-4 are Policy 26)
According to (Section 1, paragraph) 1.7, submitted comments needs to ‘formally support or object to the plan in terms of its compliance with legal and national policy (soundness) tests.’ Comments must refer to failure to abide by NPPF and the Council’s own policy guidelines.
Point 1: Predictive housing numbers
The 2011 census downgraded the population of the city significantly, leading to a County technical forecast of 12,700 homes needed in the City (The ‘joint spatial approach published in May 2013) yet the forecasted need in the Local Plan is for housing remaining unchanged at 14,000. This is inconsistent, as the NPPF document requires all data used to be the latest available.
Additional note – gathered from the South Cambs SHLAA – “[in] paragraph 158 [of the NPPF] it emphasises that Local Plans must be based on evidence that is proportionate, adequate, up-to-date and relevant”. Clearly the evidence used in the City Council’s determination of need is not up-to-date, does not take into account the updated modelling represented by Cambridgeshire Insights (and consequently is not proportionate), and relies on determinations of need that were subjectively determined in 2006, affecting its real relevance.
2.45 – The housing target is 700 additional dwellings per year between 2011 and 2031. In the 12 years from 2001 to 2012, there were a total of 3904 windfall homes, at an average annual rate of 325.33 per year. The Council is making an allowance of 92.5 per year in its forecast plan. Even if we take the years already included in the plan period (2011 and 2012 with 235 and 191 respectively), this has already contributed 426, or 23% of the total windfall allowance in just 5% of the time period. Even if we made no further allocation for the remaining 8 years of the first ten of the plan, and using the average of only these two years as a guide (213 as opposed to 325.33), over the second half of the period this would still equate to an additional 2130, bringing the total to 2556, or 706 more than the windfall allowance made by the Council, which would wipe out the need for any Green Belt loss for homes at all. Based on the historic evidence, it would actually be exceptional if Cambridge failed to achieve more than 4,000 windfall homes over the period.
Points 2 & 3: Need to preserve Green Belt & Wildlife
2.3 – The Vision for Cambridge to 2031 suggests that one of the objectives is for the Council to ‘ensure that the high environmental quality of the city is protected and enhanced’. This is at odds with any policy that promotes Green Belt development.
The NPPF specifically states that the primary characteristic of Green Belts should be their permanence, and that development in those areas should be restricted.
1.14 the indeterminate nature of the proposed 14,000 is insufficiently precise to justify the exceptional circumstances required for Green Belt release. If GB1 alone were removed from the Local Plan the shortfall would be a mere 9 homes short, less than one home per year over the period.
2.3 – Strategic objectives – the Council is at odds with its own policy point 4: ‘protecting, enhancing and maintaining the unique qualities and character of Cambridge, including…the city’s wider landscape and setting’. Green Belt development sacrifices part of that character and setting through the destruction, not protection of the environment.
7.39- Section 7 of the Plan – Protecting & Enhancing the Character of Cambridge, states that ‘Development proposals will not be permitted which would harm the character of, or lead to the loss of, open space of environmental and/or recreational importance unless:
a) the open space uses can be satisfactorily replaced in terms of quality, quantity and access with an equal or better standard than that which is proposed to be lost; and
b) the re-provision is located within a short walk (400m) of the original site.’
7.40 and 7.41 continue, saying respectively: ‘Open spaces, regardless of ownership, make a significant contribution to the character of Cambridge…It is therefore essential that these spaces be protected while allowing improvements to their recreational capacity and/or environmental value.’ In defining Open Spaces, 7.41 states ‘Open spaces protected under this policy are:
- areas designated protected open space (POS) on the policies map; and
- undesignated areas that fulfil at least one of the criteria to assess open space included in the plan (see Appendix I). This has separate criteria for environmental and recreational importance.’
When we review Appendix I, we find the following:
‘Criteria for environmental importance
a) Does the site make a major contribution to the setting, character, structure and the environmental quality of the city?
- Does it make a major contribution to the setting of Cambridge?
- Does it have positive landscape features and/or a sense of place sufficient for it to make a major contribution to the character of the city?
- Is the site an important green break in the urban framework?
- Does it have significant historical, cultural or known archaeological interest?
b. Does the site make a major contribution to the character and environmental quality of the local area?
- Does it have positive features such as streams, trees, hedgerows or meadowlands which give it a sense of place sufficient to make a major contribution to the character of the local area?
- Is it an important green break in the framework of the local area?
- Does it form part of a network of open spaces in the local area?
- Is it enjoyed visually on a daily basis from public places (e.g. footpaths, vantage points)?
- Does it have local historical or cultural interest?
c. Does the site contribute to the wildlife value and biodiversity of the city?
- Does it have any nature conservation designation?
- Is it adjacent to or an important link to sites with nature conservation designation?
- Does it contain important habitats or species sufficient to make it worthy of consideration for any nature conservation designation?
- Is it an important wildlife oasis in an area with limited wildlife value?
2.3 point 7 stipulates an objective to ‘protect and enhance the city’s biodiversity, network of habitats and geo-diversity’. The surveys by John Meed, which have been accepted and supported by Cambridge City Council’s Environmental team, highlight the wide range of red list species and strategically important wildlife habitats that exist on the Green Belt sites of GB1 and GB2 that should preclude any development there. Green Belt development also conflicts with objective 12 which claims that the Council is focused on ‘enhancing provision for open space’.
3.108 – point f – the proposal to create an ‘ecological corridor’ between sites GB1 and GB2 is not sound. According to ecology website, Yale Environment 360, Dan Simberloff, an ecologist at the University of Tennessee at Knoxville, thinks ‘ecological corridors’ do not work, they are a compromise that avoids the real problem, and diverts critical funds:
“A general concern I’ve had with the corridor bandwagon is that it perpetuates the notion that we can somehow have conservation on the cheap by providing a technological solution to the problem of habitat destruction and fragmentation,” he said. “It’s seductive, but unlikely to work in many cases. Unfortunately to conserve biodiversity we have to conserve habitat.”
The site also quotes Dov Sax, assistant professor of biology in the Department of Ecology and Evolutionary Biology at Brown University who agrees, saying “habitat corridors will be ineffective for many species.”
– It is not sound logic to propose that biodiversity of a Green Belt space with protected meadow could have its biodiversity enhanced by the building of 430 houses and the associated infrastructure concreting
Points 4 & 5: Impact on City transport and local travel
Policy states that ‘without an integrated approach to the planning of development and transport, the significant achievements in shifting towards sustainable transport…in recent years will be undermined.’ The Council has not demonstrated ‘an integrated approach’ in the course of the Local Plan Consultation as it failed to provide a Strategic Transport plan during the I&O stage 1 or 2 consultation, which inevitably meant that residents were unable to properly assess the impact of more housing construction on the ‘pressure’ that the Council admits is impacting upon the city’s transport infrastructure.
Everyone agrees that the roads around the hospital are already nearing crisis point. I ti inconceivable that GB1 and 2, together with the Bell School site and development of the Addenbrooke’s site will greatly compound that. Neither Wort’s Causeway nor Lime Kiln Road are wide enough to take cycle paths.
(Under Policy 26) Proposed sites GB1 and GB2 contradict City Council policy governing distance (from the centre) of new developments to amenities such as shops, schools and clinics. These sits fail on every criterion.