A Local Plan is a legal document that all district Councils are required to prepare, which sets out the future land use and planning policies for the area over a set time period. Members of the Cambridge Doughnut Economics Action Group put their heads together to respond to the first proposals for the Greater Cambridge Local Plan – the vision for Cambridge in 2041.
Here’s what was said – do you agree? Drop us a line – we would love to hear from you!
| Section / Policy | Comments |
|---|---|
| Vision and aims | Summary: The stated vision is unrealistic, and it is deceptive to suggest that accelerating growth, jobs, and housebuilding is a path to achieving net zero emissions, or improved wellbeing and social inclusion. The very strong evidence of recent history is that Cambridge economic growth has led to increasingly unaffordable housing and the most unequal city in the UK. The profit motive of those developing housing for investment benefit has led to place-less, community-poor housing. The plan should enforce objective metrics over far more aspects of development quality, which are currently left with vague, qualitative targets. Detailed arguments: The vision and aims are laudable, however it will be obvious to the majority of readers that the best way to achieve them is NOT to build more developments as in the plan, but to focus funding on the enhancement of existing communities, green spaces, places, and infrastructure. Transition to net zero is best achieved by limiting the cause of emission (the consumption economy), not by expanding the consumption economy and then attempting to mitigate the harmful effects. .Quite clearly the aims are better represented as meeting the appetite of the UK for economic growth, and for continued concentration of that economic activity in specific areas, whilst making efforts to mitigate some (but not all) of the negative ecological and social effects. Hence, it is unrealistic to suggest that the primary aims are those stated. A true and honest description of the aims might help citizens give more meaningful feedback, and potentially enable a better-informed political debate around the planning process. If the proposals really aim to improve wellbeing and social inclusion, biodiversity and green spaces and create “great places”, they will need to be much more specific and prescriptive about the determinants of those outcomes, over and above the specification of the homes and locations. Placemaking, for example, involves the structuring of access, facilities, open areas, and activities: not simply the sum of a number of housing units. It is clear to anyone familiar with modern development practice that developers care little for such aspects, since they focus on sales on individual housing units. The same is true for the design of communities which foster wellbeing and social inclusion: these require much more than a minimum house price and access to a play area. In fact existing segregated developments only serve to worsen social inclusivity.Leaving these critically important aspects to the discretion of the developer, to meet policies and targets framed as “should”, “take account of ”, “address”, “enhance” etc, will lead to communities where these aspects either don’t exist or are treated as afterthoughts. The dominant metric for developers is sale value and profit. A core principle of Doughnut Economics is that society will only pay due attention to enhancing quality of life and to reducing harm to the ecosystem if it sets and measures against specific metrics for key aspects and objectives. Many of the policies have no specific metrics, so they simply have no teeth, and are valueless as a result. |
| How much development, and where – general comments | Summary: The jobs are being imposed on the citizens of Cambridge, not needed by them. The inflow of jobs to the area is already causing significant infrastructural and social strain.Endless growth is of course not theoretically possible in a physical world of limited resources. There are always factors which increasingly make further growth more unattractive, costly, and dangerous to the entities living in the growth system. What models does the Planning Service have to determine likely limits to growth of the Cambridge economy? Detailed arguments: The plan is based on job “needs” in the area, translated into housing “needs”. However, these are based mostly on projections of previous growth rates, with insufficient challenge as to whether similar continued growth is either “needed” by the citizens of Cambridge, or indeed feasible without very significant worsening of the following factors that are already acknowledged to be key problems for Cambridge:transport infrastructurehousing affordabilitysocial and economic inequalityaccess to shared civic spaceswater scarcityaccess to green spacesecosystem pollution and the generation of waste productsEndless growth is of course not practically possible in a physical world of limited resources. There are always factors which increasingly make further growth more unattractive, costly, and dangerous to the entities living in the growth system. What models does the Planning Service have to determine likely limits to growth of the Cambridge economy? |
| S/JH: New jobs and homes | Summary: The additional jobs, to be supported by housing, are not necessary: unemployment here is already very low. It is being forced on the area by external actors, including international investors. Cambridge is being exploited for financial gain. Building more homes in an overheated area will only make housing pressure and unaffordability worse: as it has done consistently. Detailed argumentsCambridge city’s unemployment rate, at less than 3%, is significantly below the UK average. How does this mean that Cambridge “needs” jobs? Surely, objectively, most other regions in the UK need jobs more than Cambridge. Under the plan, job growth is around 40%: so very clearly this job growth by far exceeds the current unemployment rate. Even accounting for Cambridge organic growth, it indicates that the jobs are predominantly for people who are not currently residents. This is not “Cambridge” jobs, it is jobs imported/relocated to Cambridge. The conclusion from this growth is that actually someone or something other than Cambridge needs these jobs and this growth. To be clear, we believe this to be external parties: national (not local) government, external investors, and external developers. In fact, these parties are seeking to exploit the residents and the resources and positive reputation of Cambridge for their own financial or political benefit. As residents we resent this, and we resent that the planning system forces the planning service to collude with these exploitative actors in the unhealthy continued growth of Cambridge. Will the plan deliver housing for the residents of Cambridge that currently need housing? No. The current housing market in Cambridge is driven by investment factors, not by housing needs. This is well argued by London academic Deborah Potts in her 2020 book “Broken Cities”. The simplistic view that the solution is to “build more homes” is increasingly being recognised as wrong. Will the plan make Cambridge homes more affordable? No. Despite significant recent home-building, the ratio of house prices to average income has increased from 7x in 2002 to 13x in 2017: clearly the current policies are making homes less affordable, as argued by Dr Potts. Will the plan even make any affordable homes at all? No. The planning criterion of rent “affordability” is 80% of the market rate, and 60% for social rent. Based on the numbers given in the plan, 60% of the average Cambridge rent of £1250 is £750, which is above the average open-market rental price of the rest of England (£700)! Clearly the term “affordable” here is meaningless: the market rate is so high that NO homes are actually affordable. Once again this is a consequence of the market being driven by investment, not housing needs. The Government’s Standard Method is normally used as a default. In going beyond this method we would suggest that the Plan should also: include the total of existing unoccupied dwellings in the ‘already in the pipeline’ figure in calculating the number of dwellings required, and to explore all possible means, by incentive, penalty or otherwise, to ensure that such dwellings are occupied within a reasonable time. adopt a policy that of all new dwellings constructed above the ‘Standard Method’ number, at least 25% should be housing for social rent |
| S/DS: Development strategy | Summary: We believe the plan will deliver exactly the opposite of all of its objectives, except for economic growth. Since the Cambridge housing market is driven by investment demand not housing demand, making further investment opportunities will only make housing more unaffordable, and create more inequality and further damage social wellbeing. The strategy to attract more investment and jobs to the area is the opposite of “levelling up”, it is “beating down” the underprivileged.It is also excessive to add a 10% excess to an estimate that is already much higher than given by the default Standard Method. Detailed arguments: The plan states “Our new development strategy aims to meet our increased need for new homes in a way that minimises our environmental impacts and improves the wellbeing of our communities.” As argued above (in the new jobs and homes section), the primary driving force in the Cambridge housing market is for external investors to profit from the bubble that is the housing market. It is this which should be regulated, as it is so heavily resourced that it will always outpace any feasible increase in housing supply. Understanding this is critical to having a planning strategy that works. The “need” for new homes will be met with higher and higher prices paid by investors, which will push home ownership and even rental out of the reach of an increasing number of Cambridge residents. Additionally, the plan will not improve community wellbeing. The plan will create increased capital growth for landowners, developers, and business owners. As described in the book “The Spirit Level” (2010), this has been conclusively and objectively shown to drive up inequality, and drive down community wellbeing. It is widely publicised that Cambridge is the UK city with the highest level of income inequality. This is a clear and direct consequence of the economic growth strategy which the plan presents as “good” for the city. We also question the strategy, which is already very heavily reliant on new build housing, to allow for 10% more housing than the objectively assessed needs using a high-end estimate. Why should there be a contingency for an under-estimate by the plan (so ask for more), instead of an over-estimate (so ask for fewer), when the strategy is already taking a more optimistic view of growth than the Standard Method? Surely the “contingency” for high growth is already factored in the very use of a jobs-drive model vs the Standard Method? There is no objectively-supportable argument for this extra 10% “contingency”. |
No comments left
| Section/policy | Comments |
|---|---|
| Edge of Cambridge – general comments | Summary: There is no limit in the plan on individual scheme sizes on the edge of town. The plan should set out more clearly the requirements on developers to provide better space access and community area. Detailed arguments: There is no limit in the plan on individual scheme sizes on the edge of town. The plan should set out more clearly the requirements on developers to provide better space access and community areas: lessons should be learned from developments like GB1 and GB2 where there will be over 400 properties with NO facilities for inhabitants and poor access routes for pedestrians and cyclists (ie low-carbon transit). As a result In GB1 and GB2 the Council is now in the invidious position of having to mildly request the developers to improve on this – a request so far ignored by the developers. This is not compatible with the stated aim of the plan to build houses which minimise transport and of building new communities. |
| Section / Policy | Comments |
|---|---|
| Climate change – general comments | Summary: To achieve net zero and still grow the economy we would need to decouple emission quantities completely from growth, not just reduce or mitigate them. Several economic projections including one by the UN Environment Programme indicate that such “ absolute decoupling” cannot occur and “green growth” is simply not possible in practice. https://foreignpolicy.com/2018/09/12/why-growth-cant-be-green/ Detailed arguments: The objective is clearly stated: “Help Greater Cambridge transition to net zero carbon by 2050” . Net zero means reducing total net emissions to zero, not reducing the rate of growth of emissions to zero. To achieve net zero and still grow the economy we would need to decouple emission quantities completely from growth, not just reduce or mitigate them. Several economic projections including one by the UN Environment Programme indicate that such “ absolute decoupling” cannot occur and “green growth” is simply not possible in practice. https://foreignpolicy.com/2018/09/12/why-growth-cant-be-green/ This plan calls for an average growth of the machinery of the economy of around 1.2% per year. The UK economy is currently growing at around 3% per year per capita long-term average, so the plan will grow the local economy by over 4% per year. If we are to believe the plan will “help”, then it needs to demonstrate how it will reduce the emissions in Cambridge by more than 4% per capita per year. Otherwise (as it seems) the plan will simply “make it marginally less hard than it might otherwise be for Greater Cambridge to reach net zero” |
| CC/NZ: Net zero carbon new buildings | Summary: It seems unlikely that the developments can generate enough renewable energy to meet their needs at the required standards. For residential buildings alone, at a conservative average of 50m2 per home, 49,000 homes using 35kWhr/year will need 85 Gigawatt hours per year of new generation capacity paid for within the homes price; far beyond developers construction capabilities, eg. wind turbine farms.If via photovoltaics, this too seems unlikely. An average home of 50m2 would need 1750 kWhr/year. At typical solar efficiencies this would require 17m2 of solar panels, which is all of the South-facing roof capacity, for every single house. Detailed Arguments: It seems hard to believe that the developments can generate enough renewable energy to meet their needs at the required standards. For residential buildings alone, at a conservative average of 50m2 per home, 49,000 homes using 35kWhr/year will need 85 Gigawatt hours per year of new generation capacity paid for within the homes price. This is well beyond the capabilities of developers to construct, for example, in wind turbine farms.If the assumption is that it will be via photovoltaics this too seems unlikely. An average home of 50m2 would need 1750 kWhr/year. At typical solar efficiencies this would require 17m2 of solar panels, which is all of the South-facing roof capacity, for every single house.Does the plan have confidence that developers can design and afford net zero energy homes within the required standards, or does it expect that nearly every development will need “offsetting” measures? What absolute standard is the plan going to apply to for offsetting, or what are the “futureproofing” approaches? |
| CC/WE: Water efficiency in new developments | The policy only sets a water standard per home. This will limit the overall increase in water demand, but the Cambridge area is already in severe water stress. The policy should include a limit based on the absolute water stress of the Cambridge area. If this is intended to be set as a criterion for continued development, this criterion should be included explicitly within this part of the document. Otherwise a developer can claim they have met the standard per home, and that aggregate regional demand is “not their problem”. |
| CC/DC: Designing for a changing climate | The policy does not set any limits for how many homes need to be passively designed and built, just a priority ordering, which will be left up to the developer to choose from with no clear goals to reach. |
| CC/FM: Flooding and integrated water management | The whole plan is proposed despite the knowledge that in the short-, medium-, and long-term ongoing growth will cause further disruption to the chalk aquifer and habitats on which we all depend. Until an approach to dealing with this is found, a massive development on this scale cannot take place without inevitable and irreversible damage to the water ecosystem. |
| CC/RE: Renewable energy projects and infrastructure | As stated in the section on net zero carbon new buildings, the renewable infrastructure needed will need to be large to meet the housing demand, let alone for the infrastructure. A very clear and integrated plan will be needed, rather than leaving it up to individual developers. |
| CC/CE: Reducing waste and supporting the circular economy | There is no absolute standard for achieved performance of the developments. Given that developers are prone to create credible-looking “plans” and then depart from them in practice, we would like to see absolute metrics of waste and circularity applied to new developments. |
| Section / Policy | Comments |
|---|---|
| Biodiversity and green spaces – general comments | There is mounting research to suggest that Biodiversity Net Gain policies and measurement systems are widely unsuccessful in achieving their stated aims, eg https://kar.kent.ac.uk/88387/ |
| BG/BG: Biodiversity and geodiversity | Where BNG is to be achieved offsite, we suggest that developers are required to demonstrate the BNG measures in practice before the housing development itself is occupied. This will provide incentive to start and to finish the BNG work |
| BG/GI: Green infrastructure | There is no absolute standard for measurement or achieved performance of the developments |
| BG/TC: Improving Tree canopy cover and the tree population | There should be an objective measure for tree canopy cover, and a method of measurement. Suitable metrics and targets are not hard to find: the UK’s forestry Commission suggests urban targets of 20% canopy cover in its website :https://www.forestresearch.gov.uk/tools-and-resources/fthr/tree-canopy-cover-leaflet/ |
| BG/RC: River corridors | There should be an objective measure for river corridor health, since the aims of the policy are entirely qualitative so that progress or planning against them cannot be assessed for suitability.A suitable open-source resource for measuring this and other ecological factors is the Natural Capital Project’s InVEST software suite: https://naturalcapitalproject.stanford.edu/software/invest. In addition, we believe that ALL developments should be required to contribute to a fund to be used at the critical development sites, since the river ecosystem and negative effects on it come from much further afield than the footprint immediately around the river |
| BG/EO: Providing and enhancing open spaces | Standards for community facilities like this should not be based simply in proportion to the number of residents: there should be lower limits such that even for smaller developments, the limit allocations must be met. This will prevent deliberate piecemeal developments that escape or make a mockery of open space requirements by reducing them to an infeasible size. Developers should not be permitted to double-count open spaces that are intended to meet two functional and incompatible criteria. An example of this is the play area at Nine Wells in Cambridge which is co-located in a rainwater catchment area, such that the play area is submerged for large portions of the year. |
| Section / Policy | Comments |
|---|---|
| Wellbeing and inclusion – general comments | We challenge the assertion in the First Proposals that “wellbeing and social inclusion … can be encompassed by the concept of ‘good growth’.” This is a fundamental misrepresentation of what we know to be important for the thriving of both individuals and communities, as indicated by the social foundation of the Doughnut. The plan makes the same fundamental error about social equality and social sustainability as it does about ecological and climate sustainability: which is that they can be improved at the same time as traditional economic growth. They cannot: the effects on them can be somewhat mitigated with some measures, but the main drivers making ecological and social sustainability worse are all linked to growth itself. This has become widely recognised for over a decade, and if the Planning Service has a genuine intention to make wellbeing, inclusion, and ecological sustainability important for the region, then it would call for a minimum-growth Plan, not one which specifically encourages growth through a jobs-led strategy |
| WS/IO: Creating inclusive employment and business opportunities through new developments | How will the Plan ensure that the employment opportunities at or enabled by the developments are ones which meet descriptions of being “inclusive” beyond the statutory requirements on protected characteristics. The more pervasive and important need of inclusivity is measured against social and economic status: in particular how, specifically, can low-income family needs or accessibility needs be strongly supported? Since the developments will inevitably be focused on high-growth, high margin, high status businesses, how can the Plan prevent the type of socio-economic exclusion in the local job market, which has so far made Cambridge “the most unequal city in the UK”? |
| Section / Policy | Comments |
|---|---|
| GP/PP: People and place responsive design | The proposals focus mostly on features and characteristics of developments that respond to local context or specific functional needs of minority groups. These are aesthetic or function-specific interpretations of “people-responsive” and place. By contrast, the broader human and psychological needs of communities are much more holistic, and are based on community needs of engagement and political agency: including integrated considerations of life needs, activities, and the promotion of connected, coherent, participatory collective spaces. With the current narrow focus of the proposals, the developments will continue to be heart-less, community-poor, and without a collective spirit of belonging: as most current developments are. |
| GP/GB: Protection and enhancement of the Cambridge Green Belt | The current policies carried over from 2018 seem to have little protective effect: in practice the Green Belt seems to be “protected until someone with economic power wants another piece”, as exemplified by the relentless progress of the Biomedical campus and other nearby developments into the Green Belt. The plan should list specific and very exceptional circumstances that might allow for further destruction of the green belt, and should more clearly demand alternatives of at least equal size and environmental benefit in the area if more land is taken out of Green Belt |
| Section/Policy | Comments |
|---|---|
| H/AH: Affordable housing | The normal “affordability” criteria of 60% and 80% are simply not appropriate in the Cambridge context, and are scaled for more typical UK income inequality levels and house-price/earnings ratios. Due to the long-term emphasis on economic growth, Cambridge now has the highest income inequality in the UK – as evidenced by the house-price/earnings ratios shown in the briefing documents: in the city nearly double the England average. To make houses truly affordable to those in typical UK low-income/ benefit-dependent circumstances it follows that affordability criteria should be closer to 30% and 40% of average house prices in the Cambridge area. Without this, the plan is simply helping those at the bottom of the affluent housing ladder, while leaving those in real income need stranded well below even the first rung of housing affordability. |
| H/MO: Houses in multiple occupation (HMOs) | We would like to see very strongly worded policies to protect existing neighbourhoods from the incremental impact of inappropriate conversions/creation of HMOs. |
| H/GT: Gypsy and Traveller and Travelling Show People sites | There is a national shortage of pitches on Traveller sites (see recent research by Friends Families and Travellers – https://www.gypsy-traveller.org/wp-content/uploads/2021/01/Availability-of-pitches-on-Traveller-sites-in-England_FINAL.pdf). The new local plan should prioritise delivery of sites for Gypsy, Roma and Traveller communities and ensure that they meet their needs, are sufficiently spacious, affordable, and are in locations that are desirable to this community. Gypsy and Traveller people are estimated to have life expectancies of between 10 and 25 years shorter than the general population. Education – Pupils from the Gypsy, Roma and Traveller ethnic groups have the lowest average score in GCSEs of any ethnic group. Accommodation – Gypsies and Travellers are more likely to experience housingdeprivation than any other ethnic group. (reference: https://www.gypsy-traveller.org/wp-content/uploads/2020/12/Friends-Families-and-Travellers-submission-to-the-Commission-on-Race-and-Ethnic-Disparities-Call-for-Evidence-on-Ethnic-Disparities-and-Inequality-in-the-UK-FINAL.pdf). The local plan has the most opportunity to correct the housing aspect of this, via provision of high quality locations with sufficient space and provision and connectivity for the needs of the community. Often sites are in areas of high air pollution or poorly connected. A chronic shortage of sites nationally, and the poor quality of sites provided nationally can be corrected at the local level by local authorities. |
Cambridge Doughnut’s Response to the Greater Cambridge Local Plan
