Below is a letter sent by local resident Jeremy Jones to Queen Edith’s city councillor Jean Swanson and her colleague George Pippas. You will remember that in her recent “Local Plan Update” communication to residents, Ms Swanson said that she is “disappointed” that the council planning department has decided the Wort’s Causeway development is necessary to meet the identified need for housing, and that she had “really hoped it wouldn’t be necessary.”
The letter is reproduced here with permission of Mr Jones. I think it needs no commentary from me, other than to say that no responsible council officers or councillors should continue on their present course unless they can unequivocally contradict the arguments being made.
Dear Ms Swanson,
Thank you for your recent flyer regarding the Local Plan Consultation, which I read with interest. I also received a copy of the email thread you shared with Patrick O’Farrell, via the local residents’ association.
Both communications raised a number of concerns, which I should like to share with you:
1) The ‘Identified Need’ is not reliable
The first issue is with the Planning Department’s ‘identified need’ calculations. I wholeheartedly support the Council’s desire to improve the social and economic outlook for Cambridge, but I am not in favour of building properties where no genuine need exists. Your suggestion that there is any shortfall at all is only acceptable if the needs analysis itself is concrete in the reliability of its estimations. I would argue strongly that it is not.
Let me explain: when calculating the number of homes required in any Local Plan, the employment target is intrinsic and fundamental to that calculation, and indeed the expectation of significant jobs growth has been the cornerstone of the Council’s argument for the 14,000 homes for which it proposes to make land available.
I hope that you have already thoroughly examined the numbers involved – I certainly did, by ensuring that I had requested from the Council copies of the documents that were used for the needs determination. One of the key documents that I was directed towards was the ‘Housing and Employment Provision in Cambridge Draft Technical Background Paper’, published by the Council very recently, in May 2012. It is available online.
In paragraph 3.2 of the document, in commenting on the current employment target for Cambridge, it quotes the East of England Plan’s indicative target of 75,000 jobs for Cambridgeshire (3,750/year) during the plan period (2001 to 2021). It states:
“The Cambridge and South Cambridgeshire Employment Land Review 2008 split that down for Cambridge and South Cambridgeshire to 31,780 new jobs and 17,610 new jobs respectively. This represents an annual rate of 1,589 new jobs a year within Cambridge.”
Cambridgeshire then conducted its own review, and the document continues:
“Revised job growth projections from the Cambridgeshire Development Strategy 2009, suggest that fewer than 2,000 new jobs will be created per annum up to 2030 compared to the 3,750 per annum indicated in the current East of England plan.”
Using the same proportions for the regional splits from the Cambridge and South Cambridgeshire Employment Land Review 2008, the annual rate drops from 1,589 new jobs per year to just 847 jobs per year for Cambridge specifically.
Why is this important? The East of England Plan set a target for the construction of 19,000 homes in Cambridge within its 20-year plan period, at a rate of 950 per year. The document notes (in paragraph 2.3) that the Council objected to the level of provision because it was considered unachievable by 2021. The 19,000 figure was based on an employment target of 3,750 new jobs per year for Cambridgeshire of which 1,589 were directly for Cambridge. If – as the Council itself states – the number is only 2,000 for Cambridgeshire (847 specifically for Cambridge) then proportionally the need should be reduced to just 10,133 homes over the plan period to 2021. Should we believe that the employment requirements between 2001-2021 and 2011-2031 should be so significantly higher as to require an uplift to 14,000 homes for the period?
Thankfully, the Council has provided the answer itself. The Technical Background Paper continues, in paragraph 3.3 thus:
“A review of the East of England Plan was initiated in 2008, and a draft version of the Plan, approved by the Regional Assembly in March 2010, included an indicative target of 20,000 new jobs in Cambridge between 2011 and 2031 (subject to testing). This represents an annual rate of 1,000 new jobs a year within Cambridge.”
The reduction from 1,589 per annum from the East of England Plan down to 1,000 per annum from the new approved plan should see a corresponding reduction in requirements from 19,000 down to 11,957 over the 20 year period.
In paragraph 5.4 of the Paper, the Council admits that the Government’s own predictions, based upon assessments made by the prestigious Office for National Statistics, are for just 9,000 homes during the period. Indeed, the Government’s calculations – as is noted in paragraph 5.6 – do not take into account factors such as the economic downturn, which could in fact mean that significantly fewer than 9,000 would be needed.
All of these figures (10,133, 11,957 and 9,000) are already accommodated by the Council’s existing planning approvals (12,700 as noted in paragraph 9.4 of the Paper) meaning that there is no need to release any Green Belt Land at all.
You might feel that all these forecasts are possibly ‘finger-in-the-air’ assessments anyway. The Council admits as such when it states (in paragraph 5.2) that:
“It is important to note that the County Council’s population and dwelling forecasts should be considered provisional” and that “there is considerable uncertainty over future housing targets and likely trajectories, which are used to compile the forecasts.”
One thing is for certain – in your place I would not want to give up protected Green Belt land on the basis of highly questionable calculations.
2) ‘Identified Need’ is not ‘Exceptional Circumstances’
If you were to ignore the fact that the needs analysis appears to be flawed, there is still the issue of the fact that the National Planning Policy Framework (NPPF) vehemently supports the protection of Green Belts. (I am assuming that you have read the NPPF in its entirety, but if you have not done so, I would highly recommend you do – it is extremely clear in its support.) Paragraph 83 of the NPPF states that at the time of preparing or reviewing a Local Plan (i.e. exactly where we are currently in the process):
“…authorities should consider the Green Belt boundaries having regard to their intended permanence. Once established, Green Belt boundaries should only be altered in exceptional circumstances.”
Furthermore, Paragraph 89 goes on to say:
“A local planning authority should regard the construction of new building as inappropriate in Green Belt.”
Exceptional circumstances is an extreme qualifier. It is not sufficient to simply say that the Council have been unable to identify suitable sites to reach their (clearly rather arbitrary) target. That does not constitute exceptional circumstances – maybe merely a lack of thoroughness or creativity. As our local Councillor, we need to rely on you to make that case.
My recent discussions have shown that there is some confusion as to this requirement for ‘exceptional circumstances’ – citing the less stringent ‘very special circumstances’ instead. Do not be misled – this refers not to Green Belt land (it does not appear in Section 9 of the document focusing on Green Belt) but instead to the designation of ‘Local Green Space’, a lesser designation of protection, and should not bear any relevance to discussion of GB1, GB2 or any of the other pockets of Green Belt land under discussion.
Some media sources have attempted to suggest that Central Government has changed its mind on Green Belts and that the Framework’s requirements have been loosened. I would draw your attention to the Government’s Green Belt Standard Note SN/SC/934, from 14th January 2013 which it issued in response to such press speculation, in which it states:
“The Government has not announced any proposals to change Green Belt protection.”
Don’t get me wrong – I accept that planning isn’t easy – if it was anyone could do it and there certainly would not be degree courses in it. But equally we need to remember that the reason protections such as Green Belt designations with tight restrictions were put in place was specifically so that Council Planning Departments who were struggling to meet demand could not simply grasp the low-hanging fruit of open green space. The answer is not to build upon Green Belt land because that is simply not sustainable – once it has gone, it is gone forever. Midsummer Common is green open space – should we consider that ripe for development? Or Parker’s Piece? If as a city community we are prepared to give up on the protected green space that is fundamental to the character of the city, then we might as well put planning applications in for Jesus Green now.
3) Speculation is even less reliable than forecasting
In your Local Plan Update, you suggest that there is a direct correlation between the exclusion of GB1 and GB2 and developers ‘successfully pushing’ for the 4,000 homes proposed in CC911. There is no such direct correlation and to suggest so does you a disservice. Indeed, the Council’s willingness to give up Green Belt land so readily and easily may indeed inspire the developers to reignite their efforts as a clear precedent would be set that the Green Belt land in that location is considered appropriate. Legal precedent is a powerful argument and I would counsel you and your fellow Councillors not to provide such ammunition.
Regarding the Planning Inspectorate’s likely actions – again, it is foolhardy of any of us to speculate on their decisions, aside from the belief that as a Government body it would follow due process. The current process utilises the National Planning Policy Framework, and that specifically states that Green Belt land is to be protected.
In your email to Patrick O’Farrell, your wording becomes even stronger, when you state:
“If the land can’t be found by the council then the government will listen to developers and impose it.”
I am sorry but I do not believe that you can allocate such certainty to any speculation of this sort. Unfortunately, in this light, my feeling is that your suggestions smack somewhat of scaremongering. I do hope that wasn’t the intention.
4) Delay is no relief
Your suggestion in your Local Plan Update that other sites are “likely to come forward first” is no concession. Once the land is approved for development, it is extremely unlikely that any subsequent authority would overturn its declassification, and therefore there is no benefit to the delay. In fact, the limbo that is created by a 5-10 year planning process would mean that – should the need ever arise – it is likely that no-one in the immediate vicinity would be able to sell their property whilst such a planning ‘Sword of Damocles’ hung over them.
5) Removing Green Belt protection risks all Green Belt land
You also state in your Local Plan Update that you ‘won the following concession’:
“It will be made very clear that the new green belt line will be held.”
Forgive me if I withhold my confidence in such an outcome. The very fact that the Council continues to erode the Green Belt in areas across the city shows the fundamental disregard for the permanence which should embody the very essence of Green Belt land. To quote the Technical Paper above (in its Option 2 – Disadvantages section):
“The NPPF advises that Green Belt boundaries should only be reviewed every 20 years and continued nibbling away of the Green Belt is not considered acceptable.”
Such ‘nibbling away’ is evidently occurring in Cambridge regularly (far more regularly than every 20 years) and it is a shame that our locally-elected officials appear to be supporting such continued erosion, rather than holding the Council’s Planning body accountable.
6) A reminder of your manifesto
If you considered none of the above to be sufficiently compelling to reinvigorate you to support your local community, perhaps a reminder of your party’s manifesto from the 2012 city elections might help? In the manifesto, there was the claim that the party would “continue to promote building on suitable locations adjacent to the city and close to jobs.” Green Belt, as indicated by the NPPF, should not be considered a suitable location for development.
Similarly, I find it somewhat surprising to find that a party that was sufficiently proud of a commitment to plant only 60 trees in city centre parks would countenance the environmental damage that would be caused if the land at GB1 and GB2 were concreted over.
Finally – and most at odds with your support for the proposals – is the stated commitment to “invest in our nature reserves to improve bio-diversity.” Surely it is the antithesis of such a commitment to consider supporting the unnecessary pillaging of the wonderful natural resource that is Green Belt, wherever it is located.
Thank you for reading to the end of this email. I hope the above has provided sufficient inspiration – and ammunition – to take to the Council meetings and rebuild opposition to the proposals to release Green Belt land across Cambridge – and GB1 and GB2 in particular. Once our Green Belt land is gone, it is lost forever. With it will go a significant percentage of the character of Cambridge, and in its place will be a dangerous legal precedent for any developer to take advantage of.