Question 51: Generic Question
9. Biodiversity Comment from a Parish Councillor: “I would have liked to see a mention of supporting and promoting allotments and particularly of finding ways to link schools and the allotment movement. Learning how to grow our own and import less has an impact on food miles, plus the health benefits of exercise and connecting with the natural world”.
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10. Community Engagement One parish councillor commented on difficulty navigating “the labyrinthine structure of the document on the web site”. If the Greater Cambridge team is genuinely seeking meaningful community engagement and consensus in producing this plan we strongly recommend reconsidering how best to engage with the public and local communities with written materials and face to face exchanges of information. It was a disappointment that there were no public exhibitions in this far South East corner of “Greater Cambridge”. The team needs to work harder to develop relationships with communities.
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Response to Question 2 The land at Beach Road in Cottenham was promoted to the call for sites process in March 2019 on behalf of Manor Oak Homes Ltd. The representations to the Issues & Options consultation document will refer to that promoted site where relevant.
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As requested by Hannah re: my comment on Twitter about none of my answers saving on the consultation please find below a summary of my feedback. In my opinion, environmental protection and conservation should be the utmost priority and the most important factor in every single decision made with regard to the Local Plan and I have taken an hour or so to summarise my comments on the issues which are most important to me. Katie, I don't know whether you saw my tweet re: my answers not saving on the consultation document, so I am copying you into my comments on the Local Plan Consultation. I am copying in others for information, as the areas I have commented on are relevant to you and Wendy, so that you know that I have been able to submit some comment on the Local Plan.
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Reducing emissions from vehicles which will also assist with reducing air pollution This should be achieved by 1. Encouraging cycling and walking for journeys of short distances. To do so cycling infrastructure and pavements must be improved and cyclists and investment in this prioritised. 2. Employ traffic wardens to fine motorists of all kinds, car, van, lorry etc parking on cycle lanes and pavements which is creating a huge hazard to both cyclists and pedestrians and must be stopped. 3. Make Cambridge city centre car-free except for disabled access by improving cycle access and public transport to the city centre. Remove car parks except for some disabled parking and build secure bike parks. Congestion charges are unfair as they do not affect everyone equally as the wealthier will be able to pay, if they wish. An outright ban except for disabled access will improve air quality for everyone (long-term exposure to air pollution is the cause of 1 in 19 deaths according to recent report, Cities Outlook by the Centre for Cities https://airqualitynews.com/2020/01/27/air-pollution-linked-to-one-in-19-uk-deaths/) and make the city centre a pleasant and people-centred environment to relax in and enjoy. 4. Introduce at work parking levies,except for disabled access, to discourage driving to work, and introduce regular, low-cost park and ride facilities on the outskirts of the city e.g. of shuttle buses to businesses. Provide regular and improved public transport links to business areas. 5.Discourage parents driving children to schools, particularly private schools in the centre of Cambridge, by insisting that private schools who obviously have no defined catchement organise buses, with a variety of routes and stops, as St. Bedes does, so that children going to these schools can take the bus, rather than be driven. 6. Make cycle parks at Cambridge Railway Station and Cambridge North station secure to encourage people to cycle there. At present bike theft is rife, due to a) lack of security, b) bike racks at Cambridge North not concreted in, c) police refusing to even look at CCTV footage, let alone investigate. Cyclists are being put off and many, including me, will not leave their bikes at the stations for fear of theft even when using two very high quality bike locks. All of these issues need to addressed and rectified so that cyclists may park securely at Cambridge train stations. 7. Do not build or widen any more roads, as this will lead to more traffic, more emissions and more air pollution, but instead ensure that every transport and development decision prioritises, integrates and incentivises cycling, walking and the use of public transport. .
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Water Water is necessary for life - human, animal and plant. We cannot keep taking from the chalk aquifer when it is already clear that current consumption is having a huge detrimental impact on the health of our chalk rivers and streams and their fragile ecosystems. According to Environment Agency data, for the majority of the last year the flow of the river Cam has been at exceptionally low. It has very occasionally reached below normal or normal and last week, has only just reached above normal, after sustained rainfall in the recent storms reached above normal. However, due to heavy demands for domestic water removing water from the groundwater, I expect that it will not stay at this improved level of flow for long. The Environment Agency's Rainfall and River Flow summary may be checked weekly for more information. It is clear that the current domestic water requirement of the current inhabitants of this area cannot be met by the chalk aquifer, from which Cambridge Water provides our water, without serious harm to the river Cam and all our chalk streams and rivers. This is unacceptable. Reducing current consumption should be promoted amongst current residents in order to improve the health of our precious chalk streams and rivers and their ecosystems, but this will NOT provide more water for new development. New development, therefore, should not take place at all, until a secure water supply may be found which will not cause further environmental harm to our already greatly damaged chalk streams/rivers.
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Biodiversity All efforts must be made to protect nature in terms of habitats, wildlife and biodiversity in our area. The recent State of Nature Report was very clear that 1 in 7 British species is facing extinction, including 1 in 4 British mammals. It is therefore unacceptable to consider any development which would put any important wildlife habitat at risk with a promise to "build more" in a new development. Wildlife-rich habitats evolve over a long time and no decision should be made which would put our already extremely fragile wildlife more at risk. In addition, every effort must be made to protect pollinating insects and bees. Toxic pesticides and weedkillers which are harmful to insects and bees must not be used at all on public land and should be strongly discouraged on private land. With regard to tree-planting and any kind of conservation efforts, sites must be properly assessed and planted with great care to avoid this kind of scenario where saplings were planted in a meadow of rare wildflowers: https://www.telegraph.co.uk/news/2020/02/19/nestle-forced-apologise-rip-trees-planted-part-eco-drive-destroyed/
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Housing and Land Use I am very unhappy to learn of the proposals to use green belt land for development. Perhaps, instead we need to take a leaf our of Spanish neighbours' book and build upwards, i.e. flats. Flats should obviously have appropriate and safe cladding and each flat owner should own a part of the land on which the flat is built and therefore a part of the freehold giving them greater security as a home-owner. Building flats could provide high quality homes, with energy and water saving or even recycling measures introduced throughout, and would crucially use less land. Due to the high population density in an area which can be achieved with flats, it would also be easier to integrate high quality, cycling and walking facilities and regular public transport with such developments.
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Closing comments contained within email: Thank you for reading through these comments and adding them to the consultation survey in the appropriate places. May I suggest that for future consultations, the survey is set to automatically save every answer inputted to prevent my and many other respondents' answers, which require considerable thought and time to provide, being lost.
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Response to Question 2 As set out previously, both development options have been submitted as part of the ‘Call for Sites’ during the Issues and Options consultation. Both options are being promoted for allocation in the Local Plan, as either a standalone allocation or as part of a larger extension to the south-east of Cottenham in conjunction with adjoining land which is also being promoted through the Local Plan process. Land off Beach Road, Cottenham could accommodate a landscape design-led residential development, comprising market and affordable housing, landscaping, vehicular and pedestrian access and formal and informal open space. It is considered that the Phase A option could accommodate up to 70 dwellings with the Phase B option accommodating up to an additional 100 dwellings. The development proposals could deliver numerous tangible social, economic and environmental benefits to the local area, including: ● The opportunity to deliver a valuable amount of affordable housing to help meet the needs of Cottenham and the wider District; ● Locating residential development within one of the District’s largest and most sustainable villages. The site is located approximately 800m from the village centre and is well placed for future residents to be able to walk and cycle, rather than travel by private car, to these facilities; ● Supporting Cottenham’s local economy, including shops and services; and ● Enhancing biodiversity levels across the site and delivering on-site green infrastructure, creating a recreation and ecological asset for the village.
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Response to Question 2 - ADDITIONAL INFORMATION Claremont Planning are instructed on behalf of Southern and Regional Developments (Swavesey) to promote the Dairy Farm site at Boxworth End, Swavesey for residential development to the Greater Cambridge Issues and Options Consultation. Although the site was previously submitted to the Councils March 2019 Call for Sites exercise, Southern and Regional Developments (Swavesey) are now promoting the site so provide an update on site details to establish that the site as available, suitable and viable for residential development. Notwithstanding the promotion of the site through the Issues and Options Consultation, the site is also submitted to the Call for Sites exercise alongside this consultation. This is to ensure that the availability and suitability of the site is made as clear as possible to the Councils. THE SITE The Dairy Farm site is located towards the south of the village of Swavesey, within an area locally known as Boxworth End. Although the site is technically identified as outside the current village development framework it is located at the fringes of the settlement where development has been recently consented on the opposite side of the road. As such, it is considered that the site's context is already heavily influenced by existing built form to the north and south, demonstrating the location as being an edge of settlement site. New residential development has been approved on the opposite side of the road, which will further enclose the context. The site is situated in a highly accessible location, within walking distance of a number of amenities available in the village, including a medical clinic, secondary school, post office and village shop. It is considered that this service base reinforces the suitability of the site for residential development and demonstrates that Swavesey is a sustainable location to accommodate new levels of growth into the new Plan period. Extending over an area of approximately 4ha in size, the site is currently used for pastural farming purposes with a number of agricultural buildings (one of which has been converted to residential use), alongside the original farmhouse. The farmhouse and converted barn establish a residential presence on the site already, reinforcing the suitability of the site for consieration of a senstively designed development. To the north, the site's boundary is partly formed by residential curtilages of properties fronting Ramper Road, with the highway delineating the rest of the boundary. To the south, the site abuts Pine Grove and further residential properties along the Grove, which accomodates permanent static caravans and their related gardens. The easter boundary is open to pasture fields with clearly defined limits formed by mature hedgerows. Given the existing built form located to the north along Ramper Road and to the south at Pine Grove, it is considered that the site is well enclosed by development and so should be considered to provide a natural development extension at Boxworth End. The site would reflect the linear built pattern of Swavesey and deliver new built form coherently, which would be positioned sympathetically within the village. Although it is recognised that views along Boxworth End and Bucking Way Road offer glimpses across the site towards the Fens, it is maintained that through a considered layout and comprehensive landscaping scheme, such views could be preserved and enhanced. DEVELOPMENT POTENTIAL Southern and Regional Developments (Swavesey) maintain that the site represents an appropriate location for development. It is recognised that the western aspect of the site has been recognised locally as providing open views across the countryside, and although these are not identified by any statutory designation or development plan allocation they will be taken into account through the delivery of the site by providing a considered and sympathetic layout, incorporating green corridors and landscape zones to retain these visual aspects of the site. Planning permission S/1531/15/FL was granted at the dairy farm for the conversion of a number of the existing barns to a large dwelling with contemporary styling. This permission has been implemented on site and helps to establish the suitability of the location for further housing development. Demonstration of this is also established through the approval of two residential developments at Boxworth End, on the opposite side of Bucking Way Road to the site. These consents (S/1605/16/OL and S/1605/16/OL) identify the suitability of Swavesey to accommodate growth and the sustainability of the Boxworth End area. The related appeal decisions described the Boxworth End location as being within only a short distance of Swavesey’s facilities, whilst development would not give rise to notable harm to the countryside when the presumption in favour of sustainable development is applied. Planning permission S/3391/16/OL was also considered for residential development of the site, through which the location was assessed as being suitable to accommodate residential development with a sensitive layout capable of being achieved without an adverse impact on the character of the surrounding landscape, with the site’s suitable for housing considered to outweigh the limited harm that would arise in relation to the Important Countryside Frontage designation along the roadside frontage. No technical concerns were identified through this proposal’s consideration, with the Highway Authority, Ecology Officer, Environment Agency, Lead Local Flood Authority, Urban Design. District Landscape Officer and Planning Department considering the site as suitable to accommodate new homes. In relation to secondary school provision, an extension to increase capacity at the Village College by 150 pupils has been completed, as a result of an identified shortfall in capacity in 2012. Following other residential consents at Swavesey any development at the village would enable the expansion of the Village College further, which would assist in ensuring capacity over the extended plan period. It is Southern and Regional Developments (Swavesey) position that the approach to be taken by Greater Cambridge Councils should identify a spatial strategy that is comprehensive across all of the sustainable settlement tiers; considering a number of avenues to achieve the requisite levels of housing development. Swavesey’s settlement status as a Minor Rural Centre should be recognised through the allocation of further housing growth proportionate to the facilities it provides. Previous consideration of development proposals on the Dairy Farm site by South Cambs Council Planning Authority considered that the site was suitable for housing development. The Council considered that it was possible for an illustrative layout for 90 dwellings could be achieved without having an adverse impact on the character of the surrounding landscape, with the need for housing and site suitbaility considered to outweigh the limited harm that would arise in relation to the Important Countryside Frontage designation along the roadside frontage. Southern & Regional Developments (Swavesey) consdier that a lower density and scale of development is more appropriate, with a development of 50 dwellings considered most suited to addressing local affordable housing needs whilst refletingt the significance of Swavesey in the settlement hierarchy. None of the disbenefits arising through the site's development would result in significant and demonstrable harm and therefore, the site should be considered as a location that would acheive sustainable development as set out in the NPPF. Southern & Regional's proposals for the site will also involve a revised scale of density at a lower density than the previously considered scheme, further mitigating the impacts of built form on the local landscape setting. The lack of objection of the Council's Landscape Design Officer to the previous proposal and the pricniple of the site's development is demonstration of this. Any development of the site will incorproate design themes that are advanced by the Swavesey Design SPD, relating to the landscaping of the resulting residential development and the appearance of the dwellings. Summary of Comments: The Dairy Farm site , Swavesey is suitable and appropriate to extend a sustainable settlement that is appropriate for residential allocation.
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Response to Question 2 - ADDITIONAL INFORMATION Proposed Employment Allocation 4.2 This submission, sits alongside and expands upon the ‘Brickyard Farm, Boxworth- Strategic Housing and Economic Land Availability Assessment Call for Site and Broad Locations, Supplementary Statement, December 2019’, prepared by Turley (a copy of which is provided at Appendix 2). 4.3 As highlighted within that submission, it is considered that the site provides a unique opportunity to deliver employment floorspace adjacent to A14. 4.4 The site has the capacity to deliver circa 251,000 sq. m of employment floorspace (achieving less than 30% site coverage) set within extensive landscaping, including the creation of a Country Park on the broad location of the existing Highways England compound area. 4.5 The masterplan has been formulated first and foremost against the backdrop of advice from Bidwells (please refer to Appendix 3 for full details) indicating a serious shortage of good quality industrial stock across Cambridgeshire and limited deliverable land for development, with live enquiries from occupiers seeking a presence in the area of 29,000 sq. of B2 space and 33,000 sq. of B8 floorspace. Market Assessment and Need 4.6 The aforementioned masterplan and proposed site allocation has been formulated following advice from Bidwells and supported by an employment ‘Needs’ Report, prepared by Turley Economics (Appendix 4). 4.7 These show a clear shortfall in suitable space to meet operator requirements. The shortfalls and opportunities are considered in detail within the aforementioned assessment and our responses to questions 24 to 28 in the preceding section of this report. Access and Highways 4.8 In terms of access, ADC Infrastructure Limited have been instructed from an early stage to inform and address access requirements for the site, including capacity assessments based on circa 251,000 sq. of employment floorspace. 4.9 The capacity assessment results confirm that a roundabout would be the appropriate access solution from a safety and capacity point of view given the HGV movements turning in and out of the site associated with employment uses. The roundabout would ensure no queuing and only minor delays of only a few seconds. 4.10 Moreover, the masterplan (Appendix 1) shows the roundabout is located to also provide the appropriate forward visibility splays of 215m. The masterplan also shows the section of Boxworth Road between the Cambridge Services roundabout and the site access widened to provide a 7.3 m wide carriageway and a 3 m wide shared use footway/cycleway on the northern side of the road. 4.11 In terms of accessibility, the nature of employment use and the location of the site mean that travel by car will be unavoidable. Notwithstanding this, consideration has been given to the accessibility of the site for employees by alternative means of travel to the private car. 4.12 One feasibility options is the provision of a shuttle bus from the site to Longstanton Park and Ride. Busway routes A, B and D provide buses up to every 7 minutes linking with Cambridge, and every 15 minutes linking with Huntingdon. The Park and Ride site would be a 15 minutes shuttle bus link from the site, using the B1050 and A14. The Park and Ride site is already set up to accommodate buses and it is staffed during the day, provides an office, waiting area and toilets. 4.13 In terms of timetable, combined, the A, B and D routes provide a frequent weekday and Saturday service, between 0700 to 2030 hours, with hourly frequency through to around 2345 hours. 4.14 In addition to the shuttle bus link, options will be explored in respect of cycling and cycleways and a host of measures, including car sharing which can be borne out through Travel Plans. 4.15 In terms of sustainability credentials, these are set out in more detail in response to Questions 8, 9 and 10 below. 4.16 Nevertheless, Newlands Developments take their sustainability credentials very seriously, taking a holistic approach including, as a minimum, energy and water efficient construction, maximising accessibility (such as the shuttle bus option), enhancing biodiversity and taking a responsible approach to the ongoing occupation and operation of their buildings.
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Response to Question 3 4.17 Given the masterplan provides substantial landscape buffers and the potential to create a Country Park on the broad site of the current Highways England compound site, it is considered that the site can deliver biodiversity benefits through the provision of green spaces and wildlife habitats.
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Opening Comments: Thank you for consulting Historic England on the Greater Cambridge Local Plan Issues and Options stage and Sustainability Appraisal Scoping. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. Therefore we welcome the opportunity to comment on the Issues and Options consultation and Call for Sites. Further Guidance on Local Plans and the Historic Environment We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review the following as part of your plan preparation process: The Historic Environment in Local Plan - Good Practice Advice in Planning 1 https://historicengland.org.uk/images-books/publications/gpa1-historic-environmentlocal-plans/ The Setting of Heritage Assets 2nd ed. - Good Practice Advice in Planning 3 https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritageassets/ The Historic Environment and Site Allocations and Local Plans - Advice Note 3 https://historicengland.org.uk/images-books/publications/historic-environment-andsite-allocations-in-local-plans/
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Question 2: Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Q2 response: Whilst Historic England does not advocate particular sites, we can provide advice on how to take account of the historic environment as you evaluate submissions and sites brought forward from elsewhere. Site Allocations Historic England advocates a wide definition of the historic environment which includes not only those areas and buildings with statutory designated protection but also those which are locally valued and important, as well as the landscape and townscape components of the historic environment. The importance and extent of below ground archaeology is often unknown, although information in the Historic Environment Record (HER) will indicate areas of known interest, or high potential where further assessment is required before decisions or allocations are made. Conservation and archaeology staff within the relevant councils should be consulted on matters relating to archaeology, landscape/townscape and the historic environment generally. Assessing sites Our advice note 3 on site allocations in local plans sets out a suggested approach to assessing sites and their impact on heritage assets. It advocates a number of steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This could be applied to the assessment and selecting of sites within a plan. In essence, it is important that you: a) Identify any heritage assets that may be affected by the potential site allocation. b) Understand what contribution the site makes to the significance of the asset c) Identify what impact the allocation might have on that significance d) Consider maximising enhancements and avoiding harm e) Determine whether the proposed allocation is appropriate in light of the NPPFs tests of soundness In assessing sites it is important to identify those sites which are inappropriate for development and also to assess the potential capacity of the site in the light of any historic environment (and other) factors. This should be more than a distance based criteria but rather a more holistic process which seeks to understand their significance and value including setting. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. If a site is allocated, we would expect to see reference in the policy and supporting text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk. Paragraph16 of the National Planning Framework requires Local Plans to ‘contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals’. Planning Practice Guidance states, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development’ (PPG Paragraph: 027 Reference ID: 61-02720180913Revision date: 13 09 2018). Protection and enhancement of the historic environment is part of the environment objective of the planning system (Paragraph 8 of the NPPF) and Local Plans should set out a positive strategy in this respect (Paragraph 185). General comments on policy wording for site allocations It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal. To that end we make the following suggestions for consideration when drafting site allocation policies. a) The policy and supporting text should refer to the designated assets and their settings both on site and nearby. By using the word ‘including’ this avoids the risk of missing any assets off the list. b) The policy should use the appropriate wording from the list below depending on the type of asset e.g. conservation area or listed building or combination of heritage assets c) The policy and supporting text should refer to specific appropriate mitigation measures e.g. landscaping or careful design or maintaining key views or buffer/set back/breathing space etc. d) The NPPF is very clear on the importance of setting of all assets – further advice about settings is given in our advice note and also in the PPG. However, settings are not protected in and of themselves. It is the harm to significance that may be caused by development within the setting of an asset which is key. Try to work this into the policy or at least supporting text. e) The NPPF uses the words ‘conserve and enhance’ and ‘sustain and enhance’. f) PPG explains in more detail what is meant by conservation and enhancement of the historic environment. Here the wording is ‘conserved and where appropriate enhanced. g) The NPPF is newer than the legislation. h) Local Plans need to be consistent with the policies in the Framework Where a site has the potential to affect a heritage asset, we would expect to see the following typical wording within the policy: combination of heritage assets - ‘Development should conserve/sustain or where appropriate enhance the significance of heritage assets (noting that significance may be harmed by development within the setting of an asset).’ This is based on the wording in the NPPF and Planning Practice Guidance Paragraph: 002 Reference ID: 18a-002-20190723 Revision date: 23 07 2019 listed building ‘Development should preserve the significance of the listed building (noting that significance may be harmed by development within the setting of an asset).’. This is based on the wording in Part 1, Chapter 1, paragraph 1 (3) (b) of the Planning (Listed Buildings and Conservation Areas) Act 1990. conservation area ‘Development should preserve, or where opportunities arise, enhance the character or appearance of the Conservation Area and its setting’. This is based on the wording in Part 2, paragraph 69 (a) of the Planning (Listed Buildings and Conservation Areas) Act 1990 and paragraph 200 of the NPPF. Note that if you refer to character …appearance, use the word ‘or’ not ‘and’ registered park and garden - ‘Development should conserve or enhance the significance of the registered park and garden assets (noting that significance may be harmed by development within the setting of an asset).’ scheduled monument ‘Development should conserve or enhance the significance of the scheduled monument (noting that significance may be harmed by development within the setting of an asset).’ Or instead of the words in brackets you could add the following sentence ‘This includes any contribution made to its significance by its setting.’
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3.4 How we are developing the Plan? 3.4.1 Gathering the Evidence We note the wide range of evidence based documents that you are proposing as part of the plan preparation process Green Belt Evidence We note the commitment to prepare evidence in relation the green belt. One of the five purposes of the Green Belt is to preserve the setting and special character of historic towns. Historic towns and former towns are situated across the region and should form a consideration in any review of Green Belt. Without an appreciation of the history of the region’s historic settlements and their close relationship to their surrounding landscapes, it is not possible to properly ascribe a value to the openness of the Green Belt land around them. Consideration of the value of the Green Belt requires understanding the historic significance of this open landscape and how this contributes to the significance of the historic environment. Whilst Green Belt reviews often divide the area into parcels of land to make the assessment exercise manageable, parcels should not be solely reviewed individually within their immediate context. It also is important to understand how collectively they achieve the strategic aims of the Green Belt. We consider the question of the Green Belt in more detail under question 39, including whether a further review and/or additional evidence in needed. Historic Environment Evidence Any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base for the historic environment. Sources include: National Heritage List for England. www.historicengland.org.uk/the-list/ Heritage Gateway. www.heritagegateway.org.uk Historic Environment Record. National and local heritage at risk registers. www.historicengland.org.uk/advice/heritage-at-risk Non-designated or locally listed heritage assets (buildings, monuments, parks and gardens, areas) Conservation area appraisals and management plans Historic characterisation assessments e.g. the Extensive Urban Surveys and Historic Landscape Characterisation Programme or more local documents. www.archaeologydataservice.ac.uk/archives/view/EUS/ Whilst there is some landscape character assessment of the area we understand that there is a lack of Historic Landscape Characterisation for the county of Cambridgeshire. Ideally this work would be completed to inform the decisions regarding development in the area. We recommend early discussion with the County Council and MHCLG in this regard. Environmental capacity studies for historic towns and cities or for historic areas e.g. the Craven Conservation Areas Assessment Project. www.cravendc.gov.uk/CHttpHandler.ashx?id=11207&p=0 Detailed historic characterisation work assessing impact of specific proposals. Heritage Impact Assessments looking into significance and setting – more on this below. Visual impact assessments. Archaeological assessment Topic papers - We advocate the preparation of a Historic Environment topic paper in which you can catalogue the evidence you have gathered and to show how that has translated into the policy choices you have made. Do this from the start, as a working document, that you add to throughout the plan preparation process, not just before EiP. This should form part of the evidence base for your Plan. Heritage Impact Assessment In order to help refine which growth allocations to take forward, we would suggest that a Heritage Impact Assessment is undertaken of each of these sites. We would refer you to our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans. All potential sites will need to be appraised against potential historic environment impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or intervisibility with, a potential site. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable. Cumulative effects of site options on the historic environment should be considered too. The following broad steps might be of assistance in terms of assessing sites: • Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale • Assess the contribution of the site to the significance of heritage assets on or within its vicinity • Identify the potential impacts of development upon the significance of heritage asset • Consider how any harm might be removed or reduced, including reasonable alternatives sites • Consider how any enhancements could be achieved and maximised • Consider and set out the public benefits where harm cannot be removed or reduced The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form. Tall Buildings evidence We also consider that it would be helpful to undertake a tall buildings study to update the evidence base and contribute towards the development of an appropriate tall buildings policy for the Plan. We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. We suggest that the work for the North East Area Action Plan in relation to taller buildings is consistent with and co-ordinated with that for the Plan area as a whole. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.
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About Greater Cambridge We welcome the references to the vision for Cambridge being a ‘compact, dynamic city, located within the high-quality landscape setting provided by the Cambridge Green Belt. The city has an iconic historic core, heritage assets, river and structural green corridors, with generous, accessible and biodiverse open spaces and well-designed architecture. South Cambridgeshire’s villagesvary greatly in size, with each having a unique character.’ It is crucial that plans for the future development of Cambridge ensure that the city remains compact, and the setting of the city within a high quality landscape is retained by the Cambridge Green Belt. The iconic historic core, heritage assets and the river and structural green corridors (wedges and fingers) are intrinsic to the distinct quality of the City. The unique character, based on the individual settlement morphology, place within the landscape and individual heritage must also be maintained. Cambridge City Council Vision We broadly welcome the Cambridge City Council vision for the area and references for the historic iconic core although we recognise the heritage is not just confined to the core of the city. The wider setting of the city within the landscape is an important consideration in planning for future development. We suggest that this is included in a revised vision. South Cambridgeshire District Council Vision Although many of the aims and objectives within the vision are laudable, there is no mention of the historic environment. This is a disappointing omission. The historic environment of the district is one of the aspects of the district that makes it such a great place to live and work, and yet without suitable protection and enhancement and a recognition of the role of the unique heritage of the district in shaping existing settlement pattern and form as well as future growth this represents a striking omission. We suggest that this is included in a revised vision. Local Plan Vision We strongly suggest that any vision for the Plan itself recognises not only the importance of the historic environment in the Core of Cambridge but also throughout the two districts. The Plan should describe the historic environment of all of the Plan area and capture what is special and distinctive about each part of the area as well as highlighting the importance of the wider setting of the City.
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Conclusion In preparation of the forthcoming Local Plan we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups. Please note that absence of a comment on a question or document in this letter does not mean that Historic England is content that the proposal or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We hope that the above comments of assistance.
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The following responses are informed by nearly 40 years’ knowledge of the area, and my work as a conservation professional for South Cambs, the County Council, and the City Council (23 years). My suggestions regarding climate change and retrofit are informed by work as Heritage Chair of the Sustainable Traditional Buildings Alliance.
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Conclusion: This whole consultation is dangerously premature, pending agreement on the requirements for baseline research – with Environmental Capacity and Historic Environment at the forefront.
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Q7 - additional text to support rankning ADD: how to resolve conflicts between growth pressures / demands and the environmental capacity of Greater Cambridge? Ranking the themes (whether 4 or 5) is a meaningless exercise that trivialises a highly complex multi-dimensional analysis. The Sustainability Assessment is the document that should present a suite of criteria for prioritising conflicting themes in trade-off situations – but does it do so? The Sustainability Assessment for the draft 2018 Local Plan did not tackle key issues including environmental capacity. It is vital that the Sustainability Assessment for the new Local Plan actually gives these issues tangible and effective consideration. The SA and Scoping Report in their present form do not do this (see my comments on them).
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Generally The impetus of this plan is growth. I'm not alone in believing this is incompatible with climate change, reduction of water supply in our rivers, flood mitigation, air and noise pollution, increasing biodiversity, doubling green space, improving well being and completely altering Cambridge's historic character forever and irreparably. The green belt should not be encroached upon. 'However, the Green Belt also restricts growth on the edge of Cambridge, a location that has sustainability advantages in terms of access to jobs and services and reducing trips by the private car that could help mitigate our climate impacts.' The above statement is worrying and shocking. We must respect the Green Belt over growth. How will building on the Green Belt mitigate climate impact or improve our depleted water supply?! This also assumes everyone can cycle, walk and the bus company will have a sufficient service. Biodiversity and Green Spaces I am concerned about green space in the north of the city. Arbury is a ward of high density building. According to 2009 figures in the Open Space and Recreation Strategy 2011, the ward has the second highest population of 9,280 and only 7.55 hectares total protected open space, 0.81 hectares per 1,000 people. By comparison Abbey ward has 9,360 population and 116.39 hectares, over 15 times the space Arbury possesses, 12.4 hectares per 1,000 people. Arbury ward has the lowest amount of total protected green space in Cambridge city. At present residents are campaigning to retain 2 hectares of St Albans Road recreation ground as building free and not have buildings looming over it. It is clearly inequitable to residents and users of the recreation ground to consider building on Arbury's very limited space. Residents and I would very much want our space protected in perpetuity. Both the Cambridge Local Plan 2018 and the South Cambs Local Plan 2018 state recreation grounds are protected from building. I would like the new Greater Cambridge Local Plan to adopt a robust attitude to full retention of green space in wards with high populations, limited green space and high need as Arbury demonstrates. Failing to do so is discriminatory to residents and their need to self actualise in terms of physical and mental well being. Arbury residents use and value their green space and given the small amount are loathe to lose it. It is very worrying to read the intention 'planning applications for housing may have to be approved on sites that are in conflict with policies in the Local Plan.' I presume this would mean building on green space. This would be against the National Planning Policy Framework, completely negate the intention to mitigate against flooding and certainly not fulfill the intention for well-being and social inclusion. This also assumes green space has a lower value in terms of community need, human physical and mental health, biodiversity, and climate crisis than building. Surely the point at which using green space for building has a strong implication that building space has reached saturation and an alternative to new building must be sought. In terms of biodiversity our green spaces in Arbury and I suspect the rest of the city would be more varied if the council's maintenance and management policy wasn't so draconian. I welcome the discontinuation of weed killer. However mowing of open space is indiscriminate and tree and hedge cutting extreme. Part of St Albans Road recreation ground was allotments before the building of the Kings Meadows estate. White campion grew on the allotments and seed migrated to the recreation ground. This year residents/users of the recreation ground were looking forward to a range of insects and cinnabar moths on the flowering ragwort. They were disappointed as the mower destroyed all the ragwort and the potential for insect life and biodiversity lost. There are also blackthorn bushes which encourage nesting birds and insect life but these are drastically hacked down. In autumn there is a range of different fungi growing in different habitats on the recreation ground: in grassland and at the foot of different trees. For children in a city our parks an recreation grounds offer important access to nature. The destruction of healthy, mature trees when building or constructing roads is another concern. How is this compatible with the programme of increasing trees?! Mature trees take at least a decade before they begin to offer shade and be of value to the environment. Every effort should be made to maintain mature trees rather than consider them an obstacle to be destroyed in this crucial time of climate crisis. They should be awarded the same status and value in environmental and ecological terms as an old building is to the historic character of our towns and cities. Infrastructure I was very surprised to see that neither Camcycle or Stagecoach bus company had been invited to the Greater Cambridge Local Plan - The Big Debate at the Cambridge Corn Exchange on Tuesday 18 February 2020. If the intention is to get the public out of their cars and use alternative non- or less polluting modes of transport surely both these groups have to contribute to the debate. I am concerned that current efforts under the 'management' of the Greater Cambridge Partnership of restructuring Histon Road, Milton Road and seeking a transport link from Cambridge to Cambourne are for a private bus company of Stagecoach. A huge investment is being directed towards a private bus company which - please correct if I'm wrong - has given no formal guarantee that a bus service on Histon Road will be continued or in the case of Milton Road, provide adequate bus service and stops on Milton Road itself. I'm sure many residents/bus users would have welcomed their input and the opportunity to ask questions. It is also of great concern that Cambridgeshire rivers are severely depleted. More growth places a huge strain on and depletes water supply further. We cannot 'create' water. Growth and climate crisis is not going to mitigate this situation. Homes I'm concerned that the term 'suburban' seems to have been eradicated. The suburbs of Cambridge are referred to as urban. Suburbs of 2-storey/bungalow housing stock are having proposals of blocks of 4-storeys and even 6-storeys looming over existing homes. This is against the National Planning Policy Framework. This alters the harmonious character of suburban neighbourhoods and poses an an unnatural feature on the skyline. It's an aggressive push by developers on residents and neighbourhoods. From recent experience residents are concerned that building proposals are presented as a fait accompli. Residents are expected to welcome proposals which are far out of scale with surrounding existing dwellings. Honest, open community engagement is seriously flawed from a limited distribution of consultation cards particularly when an open space used by a wide population is involved, to submission for planning being restricted to yet another different geographic circulation rather than keeping to the same geographic circulation throughout. Residents care about their neighbourhoods and want to engage with proposed changes. Limiting information to residents engenders mistrust. I think sensitively designed building outside Cambridge city in keeping with immediate surroundings and not attempting to cram maximum dwellings or business into small areas is possible. It's been achieved aesthetically in Marmalade Lane and in Goldsmith Street in Norwich. It would be a good idea to find different developers who have such vision, aesthetic awareness, sensitivity and care for communities rather than the current incumbents who have a building monopoly and appear to be guided more by profit and an unwillingness to honestly engage with community.
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I am a resident of Cambridge of close to 40 years, and have therefore witnessed at first hand substantial part of the change that underlies the move to create a new Local Plan. Having witnessed so much change in our built space, I am completely unconvinced that a substantial part of what has taken place is for the betterment of the life of those of work and live in Cambridge and its surrounding area. Certainly, some developments and some buildings are worthy of this place, but a very considerable number fall far below the standards that must be maintained if the things that make Cambridge a special, successful and pleasant place to live and work. Sadly many of these are a direct result of poor policies and interventions by planners and politicians, and most of the least satisfactory buildings have appeared in the past 15 years. I therefore welcome a new plan, with a process of full engagement with residents in particular. Previous local plans have failed completely to take residents’ views into account, and the efforts being made in this current process are to be applauded. However, they way in which the issues and options are being presented is overly complex, and most people without specialist understanding will find it very difficult to unravel the main themes and respond. There are many other consultations taking place at present and this one will add to a sense of indigestion, saturation and dizziness. The web-based system for responses is not easy to use, and so I am resorting to an essay. I have attended meetings and discussions, and read the Issues and Options document. The plan needs to identify those aspects of Cambridge that contribute to its success and towards the pleasures of living here, and needs to identify measures and new policies that will allow these positive features to be a central part of the City’s foreseeable future. Cambridge is generally a low-rise low-density City with large areas of formal and informal, public and private green space. Cambridge has a very distinctive skyline that responds sympathetically to the generally flat surrounding countryside. Whilst its location is not of equivalent beauty to Oxfordshire, for example, it does nevertheless have very attractive features deriving from the river and fen system and from the hills that lie to the south and north west of the city. Views of the city and the way that the city looks from these higher points must be conserved, and equally views out from the higher points within the city across the city towards the countryside must be preserved without the clutter of encroaching tall buildings which would be both unwelcome and destructive. So, the starting point should be to agree a set of specific policies and rules that will prevent the destruction of the delicate relationship between Cambridge and its surroundings, and preserve the identity and relative scale of the villages. We badly need a landscape strategy, and to give the fullest possible protection to the green belt. In order to ensure that the rhythm of urban areas punctuated by meaningful green space is maintained there must be new rules that can be enforced against greedy developers to ensure that the failures in that regard of CB1 are not repeated. New areas of green space now need to be identified and designated. Existing regimes could be used to preserve existing riverine spaces, such as the commons and streams. One way would be by giving them conservation area status. Indeed it would make sense to designate most of Cambridge City a conservation area, and set out the exceptions, rather than the other way round. A vision for substantial future parks and commons needs to be placed on a footing of legal force, so that when areas are developed in future the volume of accessible park and recreational space is not what can be levered out of developers, but a previously defined set of parameters that they either accept, or take their money elsewhere. This is particularly relevant for the North East Cambridge area, where the fields between the railway line and the river should be designated as a country park – an extension to Milton Country Park, and the airport, should that be developed, where extensions to Coldham’s Common should be specified up to a relevant percentage – perhaps 30% of the total area of the current airfield to be developed. Steps such as these will allow the existing rhythm to be retained and would set rules at the outset, and would safeguard, for example the setting of Coldham’s Brook, and the setting of the River Cam opposite Fen Ditton. They would also serve to counterbalance increasing density of building on new development sites. Green space must be adequately sized and easily accessible. The designation needs to be made in the plan and be mandatory. Cambridge politicians and planners have been far too willing to accept crumbs from developers. What is needed is a very explicit set of challenging requirements for green space that will be enforced and respected. Otherwise we will see an accelerating slide into mediocrity and abuse such as that characterised by the Marque and developments around the station generally known as CB1 where green areas are either completely absent or whittled down until they become a mockery and virtually useless. Developers such as Brookgate need to be shown a ‘red card’, and sent a formal warning that where they have further plans they will have to show more respect to the setting and residents than they have in the past. Even overtly successful developments such as most of those around Trumpington suffer from process of whittling away of green space, double claiming, etc. The new local plan should focus on ways to achieve overt and specific rules, so that standards achieved at Eddington are the norm and mandatory not the exception. The target for improving biodiversity is to be applauded, but two elements are required. One is outlined above. The other is a vital question, which so far has not been given the prominence it deserves and needs. This is the question of water supply. It has been understood since ancient times, and even before urban life became such a feature of human existence, that an adequate and sustainable supply of good drinking water is the sine qua non for human life. In the context of a temperate island, such as Great Britain, it is also the sine qua non for biodiversity. The River Cam and its tributary streams are presently in a state of crisis. This is far more of an immediate, real and present danger to human and all other life in Cambridge than the much talk-about climate emergency. We here have a ground water emergency, and that is being caused by over-abstraction of water from the chalk aquifer. Cllr Katie Thornburrow’s recent meeting at the Guildhall on the subject of the water crisis is highly relevant. Cambridge has, since 1610 with the construction of Hobson’s Conduit from Nine Wells, been reliant the chalk aquifer, principally to the south and east of the City for its supply of good drinking water. In the mid 19th century the Cambridge Water Company started pumping much larger volumes from the aquifer to meet supply and this has continued increasing for a century and a half. Other water companies, notably Affinity, take their water from the same chalk aquifer, but their abstraction is of no benefit to Cambridge. On the contrary. The levels in the aquifer and the flows in the streams and rivers, and the River Cam itself, are dangerously low, and several tributaries and springs dried up completely last summer. So unless and until Cambridge Water, and Affinity can find alternative sources of supply, the only way forward that is consistent with improving the environment is to curtail new development in the Cambridge area that is supplied by Cambridge Water. Cambridge Water have no substantial reservoirs or connections to other suppliers. Some dramatic and costly changes to their supply system are urgently needed right now. The currently preferred coping measures of exhortation, reducing leakage from the system and metering will not solve the problem. Assuming 40,000 additional homes with an average of 2.5 occupants, each using 100 litres per day (below the current target of 137 litres per day by 2024/5) that is an additional 36.5 million litres of water per year. This represents an increase of one quarter above current levels, but before having to meet such growth in demand, current levels of abstraction are already killing the chalk streams which are unique and a vital part of our environment. Cambridge Water in its plan looks towards 44,000 additional homes, but no more, by 2045 in its supply area, which is very closely aligned with the Greater Cambridge area. Cambridge Water’s current plan for 2020-2045 says:- ‘We forecast that our household population will increase by 79,000, with 44,000 new household properties being connected between the base year and 2045. This is an increase of roughly 34% in connected household properties. We have a number of measures that we can use to manage our water resources. These include: - working with customers to encourage them to use less water; - more leakage detection and repair; - increasing the amount of water we take from existing water sources; - developing new sources of water; - trading water with third parties; and - working with regional groups such as Water Resources East (WRE). By implementing this programme of work, we will be able to balance water supply and demand in our region up to and beyond 2045.’ Housing growth to be supplied by Cambridge Water, which reflects only the required level of growth in housing identified by the Government, has no sustainable water supply attached to it. As seen in the quote above, they plan to increase the amount of water taken from existing sources, and develop new sources of water. This is certain to have a further deleterious effect on the environment, and is therefore unsustainable. Still less sustainable would be increasing the figure for housing growth by 50% to 66,000 as has been postulated. Such an idea should be rejected immediately as being completely incompatible with the positive green objectives being focused on. Standards of water use, rainfall harness and sustainable drainage such as those achieved in Eddington should be the norm, and all developments should be obliged to adhere to these ‘Eddington’ principles and standards, reducing planned use to 80 litres of mains water per person per day. As outlined above we urgently need policies that will prevent the pursuit of building heights above six storeys. Other cities have such policies and there is no reason why Cambridge should not. Most of Cambridge is between two and four storeys high. Heights above eight storeys are completely incompatible with the existing townscape and skyline. Developers such as Brookgate have shown no willingness voluntarily to limit height, or indeed to observe building lines, or to produce well-mannered buildings that sit well with their neighbours. It would be unacceptable for new developments such the North East Cambridge site to go to levels above eight storeys, and a blanket rule duly enforced to prevent this would be welcome. The quality of new buildings in Cambridge is not universally good. Certainly there have been some successes, such as the Mathematics Faculty, but there have been too many occasions where no effective control has been exercised. In the case of the much-despised Marque building, and the adjoining Cattle Market site, including the Travelodge, Cambridge City’s planners and their advisors were instrumental in producing a truly hideous result. In the case of the Marque, one of the most egregious examples of such failure, the development that was proposed in the first place and rejected in favour of a ‘competition’ was of far higher quality than what was built. Many people wish to see the Marque demolished. So something is seriously amiss in the planning process. There is a lack of transparency and public access. Densification is in general not an approach that I consider acceptable in the city centre. We have no evidence that this can be done successfully in Cambridge. Whilst Eddington shows features that are worthy of being made mandatory, the general impression is bleak and unwelcoming. The Varsity Hotel is an example of a building that is at least two storeys too tall and is inappropriate for its location. So, until suitable building height and green space rules are set, densification of Cambridge must be avoided. The Science Park and Harston, and flats in Trumpington offer further examples of how attempting to build too tall, too densely and with too much bulk destroys the sense of place. Rules need to be worked out and enforced. Denser should not mean bulkier or taller. Cambridge has many examples of nineteenth century dense terraces, and Marmalade Lane offers at last a suitable positive example in the twenty-first century. Another good recent example is to be found in Norwich, where however, an unacceptable replacement for the dreadful 1960s Anglia Square is proposed. Ipswich harbour offers a perfect worked example of how very badly things go wrong when building height and bulk are not contained. Where it comes into play, for example in the North East area, denser building must be matched with formal initial allocation of matched green space and strict rules limiting building height. Turning briefly to transport, there is too little recognition of the part that rail will play. With three Cambridge stations, two of them new and now one to be built in Cambourne, the question should be how many other stations should be built and where should they be. For example, Harston, Coldham’s Lane next to Sainsbury’s, in Cherry Hinton, and/or Fulbourn, near to Sawton etc. These are relatively easily and cheaply deliverable, and will complement the CAM if that is constructed. Reliance on buses cannot be a solution, but a good rail provision will take the pressure off Cambridge itself, and assist movement from other more affordable places, and attractive places such as Ely. The part that rail will play is ignored, and I noted with dismay the emphasis on the proposed but possibly no longer in prospect Oxford – Cambridge Expressway. The more significant and worthwhile connection which is in prospect is East West Rail. That should be given prominence, not another piece of road building, based on massive housing growth. But before any of this work on the Local Plan proceeds any further, the first question to be answered is where will the sustainable supply of water be found? That is the most pressing question, and one to which a sustainable solution must be found before any more growth in housing takes place.
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We act for The Crown Estate, the owners of Cambridge Business Park, Milton Road, Cambridge (“the Site”). The Crown Estate supports the principle of the regeneration and potential redevelopment of Cambridge Business Park for high quality sustainable development. The Crown Estate is a long term investor/developer and is keen to work with Cambridge City Council and South Cambridge District Council to realise its objectives. The Crown Estate is already taking an active role in the North East Cambridge Area Action Plan, within which the Site has a strategic position, and intends to be an active participant in the Local Plan process. On behalf of our client, we submit representations to the Regulation 18: Issues and Options consultation version of the Greater Cambridge Local Plan. At this stage, the Councils are looking to explore the principal themes that will influence how homes, jobs and infrastructure are planned. It also looks at how engagement with communities, neighbouring local authorities and other important groups will be coordinated. The contribution the Site can make to achieve these overarching objectives is already recognised by the Council through its allocation in the adopted development plan and in the emerging North East Cambridge Area Action Plan. The Crown Estate and Cambridge Business Park The Crown Estate is a £14.3 billion UK real estate business with a portfolio unlike any other. In everything The Crown Estate does, they are driven by a clear purpose: brilliant places through conscious commercialism. This means taking a long-term view, considering what they do from every perspective, and working in partnership with local authorities, communities and partners to deliver positive outcomes for all. The Crown Estate is the freehold owners of Cambridge Business Park as shown on Plan below. 2 Plan 1: Site Location Pan The site totals approximately 9.5 hectares and currently comprises 12 two and three storey buildings with a total floorspace of more than 30,000 sqm. It provides a high quality flexible office and r&d space in an attractive landscape setting. The Business Park was developed in phases from the 1980’s and is home to companies including Qualcomm, BBC and Redgate Software. The main access to the Business Park is from Milton Road (A1134) with a pedestrian access to Cambridge North Station via a controlled gate. It provides circa 1,200 car parking spaces and over 500 cycle spaces. The Business Park is located between Cambridge North Station (approximately 250m to the east), Cambridge Science Park to the west of Milton Road and the Anglian Water Treatment Works. The northern boundary of the Business Park comprises Cycle Network with Cowley Road beyond. The southern boundary is the Cambridge Guided Bus way. The ‘Big Themes’ Our client is supportive of the four “Big Themes” which will guide development across the Greater Cambridge Local Plan area as set out in the Consultation draft: Climate change – how the plan should contribute to achieving net zero carbon, and the mitigation and adaptation measures that should be required through developments Biodiversity and green spaces – how the plan can contribute to our ‘doubling nature’ vision, the improvement of existing and creation of new green spaces Wellbeing and social inclusion – how the plan can help spread the benefts of growth, helping to create healthy and inclusive communities Great places – how the plan can protect what is already great about the area, and design new developments to create special places and spaces Whilst the Local Plan sets out these concepts in high level spatial terms only at this stage, it is important that the proposed options for positive place making and continued economic growth align with wider strategic opportunities, especially in respect of key infrastructure such as highways and public transport. Therefore, the Consultation Draft then looks to identify options to deliver growth. This sets out 6 options for delivering growth: 1) Densification of existing urban areas, 2) Edge of Cambridge:outside of Green Belt 3) Edge of Cambridge: within Green Belt 4) Dispersal: New Settlement 5) Dispersal: Villages; and 6) Public transport “corridors” In our opinion, the regeneration, including the potential redevelopment, of Cambridge Business Park would fall within 1), of the above (but also play to the objectives underpinning 2) and 6)) and therefore contribute to delivering the Plans “Big Themes”. North East Cambridge AAP The Crown Estate is actively involved as a key stakeholder in the North East Cambridge AAP process. North East Cambridge is a key site that will feed into the new development strategy of the emerging Local Plan. It is brownfield site in the built-up area of Cambridge and includes the Site, the area around Cambridge North Station, the Anglian Water site where funding has been secured through the Housing Infrastructure Fund to support redevelopment, and other land (e.g. St Johns Innovation Park, Cambridge Science Park, etc). The AAP will show how significant levels of jobs and homes can be created here in accordance with the four “Big Themes” of the emerging Local Plan. The Crown Estate supports the vision stated for the AAP which sets community, sustainability and innovation as key principles. The Crown Estate supports the references to North East Cambridge throughout the emerging Local Plan (e.g. 5.2.1 and Figure 24-Existing Planned growth in the adopted 2018 Local Plan). Employment Land The emerging Local Plan identifies the need to ensure sufficient land for business uses, in the right place and to suit all business types and specific business clusters (para 4.5.3). The document considers the unique employment opportunities in Cambridge, including traditional office, industrial and warehouse space, alongside education, technology, innovation and small ‘start-up’ businesses. The Crown Estate supports a flexible approach to the provision of employment space including the type of space, its long term adaptability to meet changing occupier needs and where it is located. With regards the latter, the potential to cluster uses and, where compatible, integrate them with a wider range of uses, such as residential, should be encouraged. Whilst The Crown Estate supports the continued identification of existing allocations such as the Site, they consider that these should be re-evaluated in the context of the potential to create longer term mixed use developments where people can live and work thereby maximising the limited opportunities available. This is the approach being promoted through the AAP. Housing The Issues and Options document identifies a need for 40,900 homes over the Plan period (to 2040). However, it is expected that these numbers will need to be updated when further data is available. An alternative approach based on employment growth suggests around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,700 homes over the Plan period. The target housing figure is therefore likely to be subject to change as the Plan preparation progresses. We consider that the Councils should utilise the most up to date evidence base to determine the number of homes required. Should this demonstrate that significantly more dwellings are required over the Plan period, the Councils need to carefully identify the potential for further intensification of allocated sites or additional sites at an early stage, which are available and deliverable so as to avoid the need for an early review of the Plan. This could include further opportunities in the AAP area. Approach to Locating Development The Councils historic approach has been to focus development on previously developed land and sustainable locations on the edge of Cambridge. As part of the Issues and Options consultation, Section 5.3 looks at options for growth and identifies 6 opportunities. The Crown Estate supports an approach which prioritises the most sustainable options but acknowledging other issues key considerations in the decision making process (i.e. impact on heritage and townscape assets, ecology, flooding, landscape and accessibility criteria by way of example). In this respect, The Crown Estate consider that densification of existing urban areas, and development on the edge of Cambridge and on public transport corridors, offer the best potential to deliver development in accordance with the four “Big Themes”. The Site, particularly in the context of the wider AAP development strategy, provides an opportunity to deliver the densification of an existing urban site with excellent public transport infrastructure and as part of a comprehensive mixed use scheme. Closings These representations made on behalf of The Crown Estate seek to assist the Councils in the formulation of the Greater Cambridge Local Plan and aligns with the significant work and stakeholder consultation being progressed in relation to the AAP and delivers an appropriate and effective strategy for delivering new development over the Plan period. Our primary points are: We support the four “Big Themes” and the Council’s approach to place-making. We support the principle of densification of existing urban areas. We would propose the identification of the Site for development in line with the emerging North East Cambridge AAP. We recommend that the principles of the AAP are cross referenced in the emerging Local Plan to ensure consistency. We support the Councils intent to encourage a range of employment opportunities and the need to respond to fast-changing working practices. In respect of housing numbers, we encourage the Council to complete further evidence based assessments on housing numbers, which plan appropriately for the future, taking into account the Government’s standard methodology and planning beyond this where supported by the evidence base. We trust that the above comments are of use in the formulation of the Local Plan preparation. Please ensure that we are on the Council’s consultation register. We note that the Council’s will be gathering additional up to date evidence to support the Local Plan process. The Crown Estate reserves its position to make further representations as and when this information becomes available.
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Response to Question 2 Marshall has previously submitted details relating to the land at Cambridge East as part of the Call for Sites in March 2019. GCPS should refer to Marshall's completed Call for Sites form, Covering Letter, Supporting Report (prepared by Quod), Glossy 'Overview' Document (prepared by Allies & Morrison) and Letter of Collaboration from Cambridgeshire County Council. Note the Call for Sites document has been resubmitted as part of this response, to ensure references to ‘Cambridge East’ are consistent with the wider response.
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Response to Question 3 As set out in the accompanying Sustainability Vision Statement, Marshall have begun to shape their vision for biodiversity and green infrastructure at Cambridge East. We are considering ways to meet the 10% net biodiversity gain metric and to create green infrastructure that connects the project site to existing natural corridors and nature qualities. Marshall would therefore like to engage with the Councils going forward about their vision for Cambridge East and surrounding land, working in partnership with other nature conservation bodies.
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Response to Question 2 - ADDITIONAL INFORMATION A site access drawing and a topographical survey were submitted with the Call for Sites form for this site in March 2019. There are agreements with landowners in place. The site could become available now and all of housing built-out within 2 years. Additional work has been undertaken on this site since the Call for Sites submission. Consultation has taken place with Council Development Management Officers regarding possible residential development on this site and the community will be consulted in the planning and design process. The scheme will address emerging policy and design guidance. Careful consideration will be given to the density and mix of housing. Residential space standards would be met. The required level of affordable housing would be provided. A landscape buffer would be provided along the boundary of the site to provide a soft green village edge. A play area would be provided. An assessment of the sustainability of the site and the proposed development has been undertaken. The site and future development would have good access to services and facilities available in Gamlingay. These include public houses, restaurant, café, convenience stores, hairdressers, barbers, pharmacy, dental practice, churches, primary school, preschools and nursery. There is also access to public transport. The site would be in a sustainable location. The Infrastructure Technical Note that accompanies this summary confirms that the utility apparatus in the area will be sufficient to serve the proposed development. There are no constraints relating to drainage and flood risk. A suitable and safe access to the development can be achieved. Available The site is currently available. The promoter has an option with the landowners to develop the site for housing. There are no current legal, financial, or physical constraints that would affect the availability of the land for housing development. Deliverable An Infrastructure Report has been produced by Woods Hardwick and this accompanies this Planning Summary. There would be no infrastructure constraints or abnormal costs involved in the development of the site that would adversely affect delivery. The site is in an area of low flood risk. Viable Development costs associated with the site have been calculated. The site is currently viable for the proposed development.
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New Form submitted for residential use
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Question 3. Please submit any sites for green space and wildlife habitats you wish to suggest for consideration through the Local Plan. Provide as much information and supporting evidence as possible. The Cambridge Green Belt must be protected and further attrition must not be contemplated at any price. This was the first Green Belt outside of London and it is the smallest. It is therefore of historic value in its own right and furthermore provides the unique setting for the City, its collegiate buildings and its academic character and inheritance. Green Belts were an invention of one of our county’s foremost citizens, Octavia Hill. It would be obscene if our county City were to further damage its own Green Belt.
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Q42 We will address this question on a site by site basis when proposals come forward.
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