A special meeting of the City Council takes place this Thursday (13 February) to consider two petitions objecting to aspects of the proposed Local Plan for the area. One of these states that “We call on Cambridge City and South Cambs Councils to withdraw all sites in the Green Belt proposed for development in the draft Local Plan.” The meeting is at 6pm in the Guildhall and the public can attend, although not contribute. It’s a very important event for the Save The Green Belt campaign (and the thousands of supportive residents), whose representative will get five minutes to speak.
In advance of the meeting, Peter Swallowe, Chairman of the Save The Cambridge Green Belt Group, has sent the following “open letter” to Cambridge’s City Councillors. The letter will be admissible to the planning inspector, who will be sent a copy when appointed later this year. It is long, but well worth reading.
This communication is on behalf of all the members of the Save the Cambridge Green Belt campaign, and more than two thousand six hundred people who signed the petition against further destruction of Green Belt as part of the 2011-2031 Cambridge City Council Local Plan.
In February of 2013, Cambridge City Council ended Part 1 of what it described as a Consultation of Development Strategy and Site Options on the Edge of Cambridge as part of its Local Plan development. Consultation with local people is clearly commendable, presuming that the representations are given due consideration. This is, of course, the foundation of the democratic society in which we live. When we are invited to submit our opinions on relevant candidates, the responses of the local population under representation are reflected in the decision outcomes. Unfortunately, although the hundreds of comments that were received were overwhelmingly opposed to idea of including in a list of proposed development sites land which has special Green Belt protection, for some reason the City Council and its Planning organisation chose to oppose the weight of public opinion and selected GB1 and GB2 for declassification. Justifications were attempted at the time with comments such as ‘although they made no representations, we know that most people are in support of the idea’, or ‘those that would have supported are often those without access to the internet to use the Council’s online system’. Forgetting for now that representations could be made by post, the first comment is similar to an incumbent Councillor who has come last in a low-turnout re-election poll claiming that people who didn’t vote were obviously just satisfied with the current offering and claiming all their votes to win. A democratic society doesn’t work that way. Opinions sought should be honoured, not ignored.
In the hundreds of objections, were more than 70 different, specific issues identified in the Consultation document where it was at odds with the Government’s National Planning Policy Framework, and indeed the Council’s own policy criteria on areas such as sustainability, access to services, etc.
In June 2013, at the last full Council meeting, all these significant, critical issues were either dismissed or ignored. Independent Councillor Hipkin argued for removing Green Belt land by permitting an increase in the number of windfall allocation in the Plan, which given that 2011 and 2012 had already delivered 426 or 23% of the 1850 windfall homes in just the first two years, would seem sensible and appropriate. Members of the public voicing objections were repeatedly told that it was too late to go back and reconsider – too late to change the plan – Councillor Hipkin’s amendment proposal was defeated, and the first draft was voted through.
Whilst in the first Consultation, we were advised to consider the quality of the decision making of the Council and its Planning Authority in its Local Plan draft, in the subsequent second Consultation, we were advised that we could only consider the legal and procedural ‘soundness’ of the plan – focus on the process.
The Save the Cambridge Green Belt group identified over 40 examples of procedural issues, conflicts, inconsistencies and even what appeared to be failures to properly execute effective process in the consideration of Green Belt land for inclusion in the 2014 draft of the Local Plan. Issues identified included inconsistency in the application of policy, failure to comply with sustainability criteria, direct conflict with NPPF policy, use of outdated or unreliable evidence, unsound viability assessments and even ineffective co-operation under the legal Duty to Co-operate.
At the full meeting of the City Council to review the Local Plan on 13th February, democracy appears to once again be given an outing. Thanks to the small matter of over 2600 plus signatures on a petition to convince the Council to think again, the Save the Cambridge Green Belt group will once again have an opportunity to express its concerns to the Council as a whole. It will do so in the hope of preventing the assembled Councillors from further undermining a precious resource against the urban sprawl that is becoming a reality in Cambridge, and from endorsing a Local Plan that carries significant risk of being thrown out by the Inspectorate in the June review, which could carry a much greater danger through reduced protection against speculative developers looking to further eradicate the compactness of our city.
Let us review a few of the most serious issues:
Out of date data: Paragraph 158 of the NPPF requires that Local Plans must be ‘based on evidence that is proportionate, adequate, up-to-date and relevant’. The 14,000 housing need figure that it intrinsic and fundamental to the determination of Green Belt inclusion is out of date (2009 EERA review of the East of England Plan in 2009). The 2011 Census downgraded Cambridge’s population significantly. Newer data from the County Research Group shows a need of just 12,700 which removes the need for any Green Belt inclusion.
Sustainability: GB1 and GB2 fail to meet Council measures for sustainability (800m walking distance). Shops and Chemist (1.4km), Bunnybrooke’s Nursery (1.6km), Queen Edith’s Primary School (1.8km), Netherhall Secondary School (1.9km), Supermarket (2km), Post Office (2.2km) and Public House (2.2km). High Quality Public Transport Service should be within 400m – nearest bus stop is Babraham Road at 600m and nearest high quality stop is >900m. Furthermore, neither Worts’ Causeway nor Lime Kiln Road has the width to add cycle paths. This will encourage people away from walking, cycling and public transport and into their cars.
Failure to co-operate effectively: NPPF’s Duty to Cooperate means Cambridge City Council and SCDC should collaborate effectively to create a sound plan ‘to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities…’ Differing methodologies used in discovering and evaluating brownfield land availability, and ineffective communication has meant SCDC’s inadequate brownfield review was compounded by Cambridge City Council’s admission that no specific request was submitted to ask SCDC to accommodate the City’s unmet requirement. Had the Duty to Cooperate been effective, the shortfall would likely have been accommodated and no Green Belt land would have been required.
Biodiversity protection: Despite repeated calls, no evidence has been seen to suggest that the Council has conducted robust biodiversity assessments of the area. The only assessments known to be in existence are those commissioned by members of the Save the Cambridge Green Belt campaign, which both are highly critical of the suggestion to release such ecologically and environmentally valuable land from Green Belt protection.
Lack of Geological Assessment: Bisecting or adjoining the GB1 and GB2 sites are known to be the Bacton gas pipeline and a vast water main dedicated to supplying the Addenbrookes Hospital site. Furthermore previous surveys conducted by the Highways Agency have identified geological issues with the sites through instability resulting from the presence of gravel below the subsoil.
Transport: In Policy 5, paragraph 2.58 – states ‘Development should seek to enhance transport’. Projected journeys derived the number of properties (8.5 x 430 for GB1 & GB2) equals 3,655 daily trips. 2011’s Cambridgeshire Traffic Monitoring Report says approximately 50% will be by car – 1,830 car movements per day – via a single Babraham Road access. The Bell School site (R42d within the Southern Fringe AOMC) will add a further 1,500 car movements (347 homes) onto the same heavily congested road, prior to a roundabout the Council describes as ‘an accident cluster site’ (Site Options report). Given that Babraham Road and the surrounding roads are already gridlocked in the inbound and outbound rush hours, it is entirely unsound to consider these sites for development.
All of which, sadly, brings us to the question of trust and integrity. When asked to consider the detail of the plan, the members of the Save the Green Belt campaign questioned the decision making ability of the Council and its Planning Department, as so many significant issues were identified. Second time around, when reviewing for procedural soundness, even more serious issues have arisen.
Central to the proposition to use the Green Belt land in this Local Plan was the suggestion that no other Brownfield alternatives existed. When defining the Brownfield review, words such as ‘scoured the City’ were used. In the less abusive part of his comments on the Save the Cambridge Green Belt’s website, Councillor Owers stated “The Strategic Housing Land Availability Assessment went over, with a fine toothcomb, every inch of brownfield (and every other type of) land in the city and assessed its likely development potential. Every possible infill and brownfield site has been included in the plan.”
Some of our group’s members began a superficial search themselves, and within very little time identified a brownfield site in the central City area which could possibly deliver over 200 units, wiping out the requirement for GB1, and in all likelihood GB2 as well, given that it was included to contribute just 9 of its 230 homes to help the Council achieve its 14,000 figure. What is most astonishing about this central-City, brownfield site, is that it is actually one that the City Council itself owns, and one which – when questioned – the Head of Planning confessed to know nothing about whatsoever.
If some Queen Edith’s residents managed to discover a site – that the Council itself owns – which somehow managed to evade detection or consideration in this exhaustive assessment of ‘every inch of brownfield land’, what else might have been missed? We have been asked to take on trust that work has been conducted comprehensively, but clearly there are serious questions to be answered, not just from the Save the Cambridge Green Belt group, but the Planning Inspectorate.
So what is the ultimate purpose of this letter? As with all of our past submissions and representations, we would urge the City Council and its elected members to reconsider the proposal to include Green Belt land in the Local Plan. It is unnecessary and unsupportable on a wide range of grounds, from viability, sustainability, transport, infrastructure provision, and will even fail on due process. We believe that by including them in the Local Plan submission to the Planning Inspectorate, you are jeopardising your plan, and risking its outright rejection, which could have extremely damaging consequences for the City.
Please take this final opportunity to reconsider, and right the procedural wrongs before submitting this plan to the Planning Inspectorate. There are over 2,600 people who are urging you to reconsider.