Thank you for your email received on Wednesday. Our comments are
interleaved below.
>
> Dear Sir/Madam,
>
> Thank you for the responses to the Cambridge Local Plan 2014: Proposed Submission
consultation regarding St. Matthew's Piece and the Howard Mallett Centre, development at
Anglia Ruskin University and CBl, Mill Road depot, hotel development at (oldham's Lane and
Policy 22: Eastern Gate Opportunity Area. All copies of this letter received have been registered
on the council's consultation system. However, the council would like to clarify matters in
respect of a number of issues raised in the letter.
>
> With reference to concerns raised about how levels of public open space have been measured
in Petersfield ward, protected open space can be defined as either public or private. Only land
which is publically accessible was defined as public, including state school sites. As such,
Fenners Cricket Ground was not defined in the council's Open Space and Recreation Strategy
2011 as being public open space, wh ilst a number of other open spaces including St Matthew's
Piece, a number of play areas and Mill Road Cemetery were considered to fall within the
category of publically accessible protected open space.
>
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Thank you for clarifying this. However, your response does not
address the issue of the LACK of public open space within this area,
which is the crux of the matter; and the resulting desperate need for
more.
> Regarding the future of the Howard Mallett Centre and its potential use as 3-storey
residential or office development as referred to in the letter, the Cambridge Local Plan 2014
does not propose the allocation of the Howard Mallett Centre site for any specific use.
legislation (and indeed history) tells us that anything that goes into
the Local Plan becomes the MINIMUM that developers are allowed
to do. The Local Plan proposal clearly shows three-storey buildings
(whether residential or office) on the site: therefore claiming that it
does not yet propose any SPECIFIC use I allocation utterly ignores
the point of the FACT that it shows (&therefore gives the go-ahead
to) unacceptable development on the site. The sole development
acceptable for the site would be a new community centre, although
given the lack of public green open space already acknowledged, it
would be far more appropriate to return t he site to parkland, and to
provide a community centre nearby as per Policy 73 of your Local
Plan .
The Howard Mallett Centre site is included within the Eastern Gate Opportunity Area, the same
area defined in the Eastern Gate Area Development Framework Supplementary Planning
Document (SPD).
Irrelevant. It should not be. The Framework may incorporate it
within the general area of the Eastern Gate Opportunity Area: it
does NOT suggest that it should be developed as it appears in the
Local Plan. Therefore t he designation & inclusion of the site within
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the area of opportunity for major change needs to be changed.
The SPD makes refere nce to the possibility of redevelopment of the building, but also refers to
the potential to enhance and increase the size of St. Matthew's Piece through t he promotion of
a reduced building footprint (Page 47 of the SPD).
This is good news. BUT there is absolutely NO reference to this
possibility in the Local Plan itself, which trumps and outweighs the
SPD. NOR is there ANY reference to restoring the entire site to the
desperately needed public open green space, despite the history of
the successful planning application for this a few years ago. If you
claim that the Local Plan makes allowance for this option, then it
must be clearly and specifically stated within the Local Plan.
Meanwhile, ALL plans, designs, and proposals within the Local Plan
showing three-storey buildings developed on the site MUST be
removed before the Local Plan is finalised. Otherwise, according to
recent national legislation, those become the MINIMUM that
developers are allowed to do on the site.
As Paul Saunders, Councillor and Mayor of Cambridge, stated on the
4 September at the Guildhall meeting of the Planning Committee:
history tells us that any approved plan - such as the Outline Plan a
few years ago - becomes HUGELY important and relevant, and
CANNOT be glossed over and fobbed off with the excuse that "oh,
don't worry, there will be room for discussion later." Whatever goes
into the Local Plan - and this is even more the case given recent
legislation- becomes set in stone as the MINIMUM that developers
can do. Any assurance to the contrary is therefore naive at best, and
a jaw-dropping inversion of truth at worst.
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Any planning application co ming forward for the Howard Mallett Centre site would need to
adhere to planning policy in relation to loss of community facilities as set out in the existing and
emerging local plans and the National Planning Policy Framework.
Please see above. Please cease trying to fob us off.
>
> Anglia Ruskin University and its emerging masterplanning proposals for 6,000sq m of
teaching floorspace are also discussed in the letter. It should be noted that the Cambridge Local
Plan 2014 does not refer to any homes being demolished to allow for the further development
of Anglia Ruskin University.
Irrelevant. The fact that it does not make specific reference to HOW
such a vast area would be created does not in any way diminish the
FACT that such a vast area is completely unacceptable within the
context of t his densely populated area. Nor does it in any way deny
that the only WAY to find (a MINIMUM!) additional 6000sq m is by
squeezing land by hook or by crook .. .. How else but by squeezing
residents out?
The fact that it includes this Masterplan at all in t he Local Plan is the
issue under discussion: this Masterplan is simply NOT appropriate
and must be removed from the Local Plan. The Masterplan was
created with no democratic mandate. It has already accrued over
9000 sq m of space in this area, and filled it with ugly and
insensitive carbuncles: for them to demand a further 6000 sq m and counting (''implementation of the masterplan has left a shortfall
in
teaching space[. ..] This will require the masterplan for Anglia Ruskin
University to be revisited') (5.26) - is simply unacceptable.
Furthermore, the plan does not refer to any proposals for 600 student units for Anglia Ruskin
Page 5 of8
University.
The Local Plan gets around this by referring to "revisiting" the
Masterplan and building accordingly (5.27 clearly states that "The
East Road site and area remain the most sustainable location for
Anglia Ruskin University during the next plan period, and any future
needs for this institution should, in the first instance, be met close
to this site': and Table 2.1 states that ARU "require land for student
hostels'). Moreover, your statement blithely ignores the fact that
ARU boasts in its own literature that it intends to build 600 student
dwellings IN THIS AREA IN THE NEXT 18 MONTHS.
> With reference to development in Station Road, the council can confirm that the level of
affordable housing being delivered within t he CBl development is policy compliant with
requirements set out in the Cambridge Local Plan 2006. Furthermore, in relation to both
community faci lities and open space, a proportion of provision for both types of facility is being
made on-site with commuted payments made towards enhancement of provision within the
surrounding area. Again, this is compliant with the current policy approach in the Cambridge
Local Plan 2006.
Not according to information received by PACT at its recent AGM,
attended by Councillor Blencowe and
among
others. On the contrary, we heard how the developers claimed
bankruptcy, landing the Council with all the bills... and then were
allowed to be reincorporated as a new company and to minimise
and largely ignore all the previous commitments to community
facilities/ open space /affordable housing on the basis of "not having
sufficient money." While there may be SOME provision for
community facilities and open space (we note that you make no
mention of affordable housing), there is quite clearly LESS provision
than was originally vowed. Moreover, despite ov~r £2 million being
already allocated to the station square and cycle provisions (from
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Network Rail and Ibis Hotel etc) developers are threatening t hat if
they not be allowed to proceed with Wilton Terrace, money for both
these would be at risk. In any other context, such behaviour would
be recognised with a rather ugly definition.
> The Mill Road depot is referred to in the letter. There is discussion of the depot site and its
indicative capacity of 167 dwellings in tandem with discussion of lower density sites elsewhere.
It should be noted that each site within the plan ha s been assessed individually in re lation to its
capacity for development, given the specific site constra ints.
This does not justify in any way, shape or form the high density
proposed. Who has assessed it as appropriate for such density? The
developers themselves - the same ones who own it, ie the City
cou ncil. This is a clear conflict of interest.
The proposed density
1) is DOUBLE local density and is therefore clearly inappropriate.
2) does NOT incorporate as guaranteed a specified PROPORTION of
open space. Nor of com munity facilit ies. I ndeed, at such high
density there is no ROOM for any significant open space or
community facilities
3) as previously mentioned, recent legislation means that any
figures appearing in t he Local Plan become the MINIMUM that
developers can do.
Furthermore, the reference to 30 dwellings per hectare as the Government's standard density is
incorrect as t his refers to guidance in the cancelled Planning Policy Statement 3: Housing (2006).
The current National Planning Policy Framework requires councils to set out their own approach
to housing density to reflect local ci rcumst ances (paragraph 47) and does not refer to specific
densities. The council has chosen not to define a specific dwelling per hectare based density
approach in the Cambridge Loca l Plan 2014, as Cambridge has a mix of dwelling types and sizes
spread out across t he city and it is considered
Page 7 of8
> important to be contextually appropriate, rather than setting an figure which wou ld not be
suitable across all areas of the city.
The proposed density quite simply is NOT contextually appropriate.
It has been proposed with zero accountability or democratic
mandate and this HAS to change. The Local Plan affects everyone in
Cambridge: it cannot simply be a plan hatched up between
developers and rubberstamped by a tiny unelected group who are
caught up in the joyful frenzy of such power. Public consultations
have to be more than simply ticking a box to show that you have
invited opinions: unless those opinions are given as much or greater
weight than those of the developers, such "consultation" is simply a
cynical mockery of democracy.
>
> I hope th is information is of assistance.
>
Thank you. We hope that our response is of assistance in turn.