[Members] FeCRA Response to the NPPF Consultation

[Wendy Blythe]

Dear All,





*Update 25 Sept 2024*

*National Planning Policy Framework (NPPF) Consultation*



A big thank you to everyone who shared information and gave advice. Please
share the FECRA response with your members and networks.



*The Federation of Cambridge Residents’ Associations’ (FeCRA) Response to
the National Planning Policy Framework Consultation *

*Copied to Cambridge MP Daniel Zeichner, Defra Farming Minister *



The Federation of Cambridge Residents’ Associations (FeCRA) is a grassroots
civic voice for everyone in Cambridge — and also for its environment.
Residents want a say in shaping Cambridge’s development to ensure that the
city grows in a way that will achieve balanced communities and quality of
life. We welcome the opportunity to contribute to the government’s
consultation on the National Planning Policy Framework. FeCRA’s strength is
in our network of members in all city neighbourhoods, plus our strong
contacts in nearby villages. Membership currently includes 97 Residents
Associations and community and Friends groups, including environmental and
cultural/heritage groups such as Friends of the Earth, CPRE and Friends of
the Cam. We have good channels of communication with key Cambridge interest
groups and we work closely with communities in Greater Cambridge.



Our members are very concerned about the imposition of non-negotiable legal
targets for the numbers of houses that must be planned to be built in an
area. While it is understandable that strategic, cross-border powers may
need to be increased to meet housing targets, it is crucial that local
communities have a real and meaningful role in shaping planning decisions.
We need a planning system that includes consideration of the overall
environmental capacity and climate change impact and the effect on the
historic environment (built and natural) in a holistic way.



While we recognise the value of Design Codes (Question 5) we also believe
that these must reflect local distinctiveness and allow flexibility. It is
essential that design guides do not stifle creative development.



Previously housing targets were a ‘starting point’ and could be modified
due to constraints such as the Green Belt, Areas of Outstanding National
Beauty, flood plains, agricultural value etc. But under these NPPF
proposals this will no longer be the case.



Plans for up to 150,00 new bomes in ‘Greater Cambridge’ have been endorsed
by the chair of the government’s New Towns Taskforce.  Our members object
to this lack of democracy and the way top-down targets have been calculated
and decided. They also highlight the role played in setting these targets
by Cambridge University, and business leaders and developers of Cambridge
Ahead, some of whom stand to benefit from lucrative green belt development
close to London.



The December 2023 changes to the NPPF had started to rebalance the system
away from developers. Now the concern is that these government proposals
will send us further into a developer-driven system where market-led
housing will be prioritised over affordable housing. This is because the
emphasis is on targets and the presumption in favour of development, which
promotes unsustainable development outside local plans and because
viability opt-out clauses will allow developers to wheel and deal their way
their way out of commitments .



To enable this emphasis on targets the next major change being proposed is
to the Green Belt. 'Grey belt’ as a very vague definition could lead to
many applications across much of the Greater Cambridge green belt.
(Question 23)



We object to the omission under *20 Strategic policies* that outcomes
should support beauty and placemaking.



The housing crisis is one of affordability, not supply. When market-led
homes built by Cambridge City Council and Cambridge University did not sell
rather than reducing the prices both of these organisations chose to market
the homes, built with their developer partner Hill, to investors in China.



We are concerned that with the plans for such significant housebuilding in
Cambridge there is no commitment to fund the necessary infrastructure and
the facilities from doctors to roads, schools and sewage treatment that
will be needed to accompany these very large numbers of new homes and new
residents.



Plans for addressing Cambridge’s infrastructure issues include an untried
system of water credits overseen by a shadowy, unnamed Water Scarcity
Group. We are aware that the government is considering plans for a
remodelled PFI scheme involving compulsory purchase and private finance, as
recommended by researchers at Cambridge University's Bennett Institute and
the business interests and developers of Cambridge Ahead, who have been
working with the government and the water companies. Cambridge University’s
Vice Chancellor is on the board of Cambridge Ahead.



However, what hasn’t changed since Michael Gove unveiled the housing
targets for Cambridge last year are the water issues in Greater Cambridge.
Current future supply plans for the next 25 years will not support anywhere
near the level of growth planned. It is still not clear where the extra
water will come from. Can you drink water credits?



*What we need is an evidence-led planning system*



We need evidence of how housing need will be met (including a social
housing target), with local input.



We need an impact test to demonstrate what the policies proposed mean for
developers and what happens if they are not delivered.   And we need
*independent *scrutiny of the ecological, natural capital and food security
impact of policies and what they mean for carbon emissions, air quality and
future food security, not analysis funded by companies with a vested
interest in the outcomes.



Instead of a confusing new ‘grey belt’ definition, we need a robust
hierarchy that plans for use of empty homes and for conversions, then
suitable brownfield, and finally, gentle density/compact transit-oriented
greenfield.  Local Nature Recovery Strategies (LNRS’s ) should be given
maximum support and protections. We also need to factor in protecting urban
green spaces as well as rural. Please do not forget to focus LNRS’s on
undesignated countryside. Undesignated countryside is not given enough
protection in this NPPF. ( Question 27).


Undeliverable promises are not helpful. Viability opt-outs must be
eliminated, and policies that prioritize housebuilder profits over public
good should be revoked.  Food security and the natural world must be the
priority.


Our planning system should prioritise and protect our prime farmland and
natural ecosystems including water supply.  Cambridgeshire County Council's
Farms Estate extends to over 33,000 acres of farmland across the county and
has more than 160 tenants. The Estate is the largest public sector estate
in England and Wales. These NPPF proposals remove the obligation to
consider food security and the importance of agricultural land. We strongly
object to the deletion of 2nd sentence of Footnote 63 in the proposal “The
availability of agricultural land for food production should be considered,
alongside the other policies in this Framework, when deciding what sites
are most appropriate for development.” (Questions 82/83) removal of this
obligation.



The River Cam green belt with its top grade agricultural land is important
for protecting the setting of Cambridge, a world famous heritage city. Cows
famously graze on Cambridge’s Commons (wetland meadows). This grazing is
valuable for healthy river basin management.



We recommend (Question 83 ) amending the definition of best and most
versatile agricultural land in the NPPF Glossary  to read : “Land in grades
1, 2 and 3 of the Agricultural Land Classification” In practice there is
often little difference in productive capacity between 3a and 3b.



We also recommend revising the NPPF paragraph 180 (i) to read: “recognising
the intrinsic character and beauty of the countryside, and the wider
benefits from natural capital and ecosystem services- including the food
and water security benefits of the best and most versatile agricultural
land, and of trees and woodland’.



Solar, batteries and non-linear grid infrastructure must be on brownfield,
rooftops and car parks. The environment must be on an equal footing with
economic growth.



We agree that the current water infrastructure provisions in the Planning
Act 2008 should be improved. ( Question 84) But, we are concerned that
there is an assumption that the Oxford Cambridge Arc Pan regional growth
and nature tourism can fund a system of water management for water-stressed
Cambridge without addressing over-abstraction and sewage in the rivers.



Water security has already been seriously undermined by accelerating the
movement of population and employment over many decades south and eastwards
in England. For a whole range of reasons, economic, social and
environmental, we need regional planning that reverses this trend. At the
moment, simply building a few reservoirs in the south of England is not
going to meet the increased demand caused by the unbalanced regional growth
in housing which will be exacerbated by the uneven levels of rainfall over
long periods guaranteed by climate change (Question 84)



The local sewage system is currently inadequate. The inadequacy of the
sewage system is evidenced by the number of sewage spills by smaller
Anglian Water sewage works into the Cam Valley.



Large areas of Cambridgeshire, including parts of the City of Cambridge,
are subject to continuously increasing flood risk. Not only is sea level
rising, the rate of sea level rise is increasing rapidly.



We share the concerns of many experts that Cambridge will soon run out of
water.



The East of England is low-lying, not only is it subject to flooding, it is
one of the driest places in the UK. Water sources are under pressure
meaning people, plants and animals are competing for the same precious
resources. With climate change, drought is set to become more common amid
hotter, drier summers and intense rainfall events more frequent.



Many residents are very concerned about this and about the impact on the
Cam chalk streams and the wildlife that depends on them. Currently 90% of
Cambridge’s Water supply comes from chalk aquifers and other groundwater
sources in the green belt. Several solutions have been put forward.



   - a new Fenland reservoir – would not be delivered before 2035 and
   vulnerable to flooding because of rising sea levels.
   - water transfer pipelines from Grafham, probably not available before
   2032 if then.
   - water efficiency measures including fixing leaks, reducing demand
   through a hosepipe ban and smart water meters.
   - all major new developments required to achieve the best possible water
   efficiency standards (i.e less than 110 lppd)



These steps are urgently needed in any case to ensure there will be enough
water for existing users and the developments that already have planning
permission.

The Environment Agency has objected to large developments such as Bourn and
Darwin Green on the grounds that they are not sustainable because there is
not enough water.


We support these objections and all the concerns about the level of growth
planned for this region. The government must rethink its housing plans to
prevent harm to the countryside and wildlife. Professor Dieter Helm, Chair
of the National Capital Committee, has stressed the importance of long-term
risk assessment in ensuring net environmental gain, in perpetuity, despite
development.



·       The government must protect wildlife and farmland by enabling
housing in the over a million empty and derelict homes and 165,000
commercial properties.

·       The million unbuilt planning permissions must be built out and
homes constructed on the over a million brownfield sites available.

·       The priority should be a focus on genuinely affordable homes
(social housing) for those in the most need.



We need clear evidence of how meeting housing need will do this and include
a social housing target, with local input. New communities take time to
emerge, if they do at all, but the issue is that many new developments are
injected into places with existing communities that may suffer as a result.
We urge the government to take further steps to ensure that community
involvement remains central to the planning process.



To conclude



   1. Make affordable housing a priority. We want to see a definition of
   ‘affordable’ to reflect average local incomes and targets for affordable
   homes including social rent based on local need.


   2. Put brownfield first. We want to see targets for homes built on
   brownfield land, with central government supporting local authorities to
   use brownfield sites by ensuring brownfield registers are updated.


   3. Protect the Green Belt. We want the 'grey belt' category dropped as
   it creates too much ambiguity and risks land degradation, and to keep the
   current line on boundary changes in Green Belt only in ‘exceptional’
   circumstances.


   4. Transition to renewable energy and protect landscapes. We want
   requirements for solar farms to return land to its original use at the end
   of a licence period and for local authorities to take a rooftop solar-first
   approach in their energy strategies.


   5. Strengthen protection for our best quality land and our rivers
   and chalk streams. We want them protected from development and we want
   increased commitments to support nature recovery.



We hope this response will be useful.



Yours sincerely,



Wendy Blythe,

Chair, FeCRA


Wendy Blythe
Chair, FeCRA

www.fecra.org.uk
www.facebook.com/CambridgeRAs
www.twitter.com/fecra2
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