Question 11 - General comments

Introduction Support These representations relate to a site at 127-136 Cambridge Science Park. The site is currently occupied by a single storey building. The existing building is used for Class B1 business use, and has a floor area of approximately 1,000sqm. A planning application has been submitted on behalf of GCR Camprop Nine Ltd for the redevelopment of the site to provide a new office/research and development building (App Ref. 20/03444/FUL); a number of technical reports have been prepared in support of the proposed development and the application is currently pending. The proposed new building would be 5 storeys and provide approximately 4,600sqm GIA of new floor space. The proposed building is of passive led design, leading to reduced need for mechanical cooling and proposes the use of Cross Laminated Timber as primary construction material (a 100% renewable resource and a first in the Science Park). The CLT construction proposed means reduced groundworks and environmental impact and a shorter construction programme and reduced site traffic during the construction period. As set out in these representations, GCR Camprop Nine Ltd supports the North East Cambridge AAP in terms of the policies that relate to the proposed redevelopment of the building at 127 – 136 Cambridge Science Park. As demonstrated in these representations, the proposed redevelopment of the site, and promoted in the current planning application, is consistent with the relevant policies and aspirations for Cambridge Science Park as set out in the emerging AAP. The owner of Cambridge Science Park – Trinity College – is in the process of preparing a masterplan for the whole area, and the proposed redevelopment of the site would be consistent with the landowner’s masterplan.

Thank you for the opportunity to comment on the North East Cambridge Area Action Plan as the Local Transport Authority. We agree that the AAP is right to identify the significant risks to the transport network if the North East Cambridge Development were to generate extra car trips, and therefore to aim not to increase traffic levels on the Milton or King’s Hedges Roads. We note that the proposed policies to manage this risk include the following: i. provision of walking and cycling infrastructure, including connectivity though new bridges and underpasses; ii. provision of innovative public transport, including MRT/MAAS models and safeguarding land for a CAM stop and portal iii. a car trip budget that requires existing developments on the site and elsewhere to reduce car use from current levels in absolute terms iv. parking standards within the AAP area that would potentially allow up to 4,000 spaces for residents’ cars v. measures to deter car use including the avoidance of through routes and speed restrictions vi. last mile delivery options. Overall, these ambitions are consistent with the Local Transport Plan’s aim of promoting attractive alternatives to private car use in order to reduce congestion and contribute to achieving net zero carbon emissions by 2050. The measures to achieve the AAP’s aims are, however, described in very general terms. In particular, it is not yet clear: a) what the measures to reduce car use by existing businesses and residents, including those outside the AAP area, would be and therefore how likely they are to be effective; b) how the proposed infrastructure and public transport provision would be funded; c) what the degree of confidence in achieving the trip budget is; and d) what contingencies would need to be built into the eventual development consent for the AAP area if the trip budget were to go off trajectory once development had begun. Clearly, if the aim of keeping to zero the net traffic impact on the Milton and Kings Hedges Roads is not met, wider LTP objectives for congestion in Cambridge, and the road network, particularly around the Milton Roundabout and the A10, may be called into question. The Combined Authority also has a statutory responsibility for planning, and subsidising where appropriate, public transport to serve the AAP area. We would therefore be grateful if the Greater Cambridge Planning Service would engage with the Combined Authority to explore these issues further as the AAP is further developed.

I write in order to provide Network Rail’s consultation response in relation to Greater Cambridge Shared Planning’s (GCSP) Draft North East Cambridge Area Action Plan (AAP) Regulation 18 consultation. Thank you for giving Network Rail the opportunity to submit representation in relation to this policy document. Network Rail’s feedback to the draft North East Cambridge AAP is detailed below. Site L - Land at Cambridge North As detailed within Figure 6 of the Draft North East Cambridge AAP, Network Rail is the freehold owner of the Land at Cambridge North. Network Rail, together with Brookgate Land Ltd and DB Cargo UK (and through them Freightliner and Tarmac) form the Chesterton Partnership. The Chesterton Partnership is promoting the rationalisation and redevelopment of the former Chesterton Sidings site (referred to as Site L within Figure 6). Please note that in relation to the Land at Cambridge North, a separate consultation response has been prepared by Bidwells LLP on behalf of Brookgate Land Limited. Fen Road (Chesterton Junction) Level Crossing Page 195 of the Draft North East Cambridge AAP states that, ‘Any move to close the crossing will need to be initiated by Network Rail and go through due processes. The authorities will need to work together to form a view on where any alternative access route should go to deliver the best outcomes, should this situation arise; more certainty will be given as the plan process advances.’ Whilst it is acknowledged that Fen Road Level Crossing is located outside the Draft North East Cambridge AAP boundary, Network Rail welcomes further discussion with GCSP, Cambridgeshire County Council and other stakeholders in relation to the crossing and potential opportunities for alternative access routes.

Cambridge North Station (Various Policies) The Draft North East Cambridge AAP recognizes the important role that Cambridge North Station has in supporting the proposed regeneration of the surrounding area. It is vital that proposed developments on the approach to the station / surrounding the station, consider how they interact with the station environment and its operation. GCSP and Developers should engage with Network Rail at an early stage in relation to proposed developments.

Developments adjacent to operational railway land and infrastructure The proposed Draft North East Cambridge AAP proposes potential development on land located adjacent to Network Rail’s operational railway and infrastructure. GCSP and potential Developers should be aware of and consider Network Rail’s standard guidelines and requirements when developing sites located adjacent to or in close proximity to Network Rail’s land, assets and operational railway infrastructure. For more information please visit https://www.networkrail.co.uk/running-the-railway/looking-after-the-railway/asset-protection- and-optimisation/. Future developers will need to engage with Network Rail’s Asset Protection Anglia team (AngliaASPROLandClearance@networkrail.co.uk) at an early stage to ensure that any proposed development does not have a detrimental impact on the safety and operation of the railway network. Thank you again for providing Network Rail with the opportunity to comment on this consultation. I trust that the comments above are clear, but if you require any further information or have any queries do not hesitate to contact me.

Part C - Comments on specific policies and supporting documents: Object Introduction These representations relate to the site occupied by Ridgeons off Nuffield Road. Ridgeons has a long leasehold interest in the land. The Ridgeons site is located within the AAP boundary to the south and falls within the Nuffield Road Industrial Estate. The site is identified for ‘Housing Led’ redevelopment within the draft AAP on the ‘Proposed land uses’ plan at Figure 11.Ridgeons operate a builders merchant from the site, which serves Cambridge and the surrounding area, and intends to continue operating from the site to meet the needs of its customers. As set out in these representations, Ridgeons intends to remain on site and therefore want to ensure that the proposed use and form of development identified in the AAP would not affect its existing or future operations. However, if they are to relocate, the site needs to generate a high use value to make the land viable and to fund the purchase, development and move to another relocation site. Therefore, the proposed use of the Ridgeons site for housing led redevelopment uses are supported. If it is not possible to avoid potential conflicts between surrounding residential uses and the existing builders merchant operations at the Ridgeons site, then, a suitable alternative should be identified within the AAP area to enable Ridgeons (if required) to relocate its existing operations. If this is not possible, the relocation of Ridgeons operation to another site needs to be viable and acceptable to the company from an operational perspective.

Thank you for seeking Natural England’s views on the above in your email of 20 July 2020. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. You will be aware that Natural England provided detailed comments in response to consultations on the Issues and Options consultation, in our letter dated 25 March 2019 (ref. 273507), and the draft Habitats Regulations Assessment (HRA), in our letter dated 7 May 2020 (ref. 315290). Natural England Summary Advice Based on the information provided in the AAP, and the findings of the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA), Natural England’s overarching advice is that further evidence is required to demonstrate that there is sufficient greenspace provision and water supply / waste water treatment capacity to meet the demands of this scale of development without adverse impact to the natural environment. Our advice is made in the context of the adverse environmental impacts already occurring to meet the recreational and water / waste water needs of the existing population. As indicated previously Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. We support the aim of the AAP to create an inclusive, walkable, integrated, low- carbon new city district within this 182 ha brownfield site located within 15 minutes cycling distance of Cambridge. However, as indicated through the HRA and SA, significant uncertainties remain regarding the potential for NEC development to adversely affect the natural environment, including a number of European and nationally designated sites, through changes in air quality, recreational pressure and water-related impacts. In light of existing environmental pressures the proposed scale of development, in combination with wider growth including Ox Cam Arc and Waterbeach New Town, is likely to require implementation of significant measures to address these issues. Further assessment is required, for example through the Local Plan Water Cycle Study and through traffic modelling and Air Quality Assessment, to inform the recommendations of the HRA and SA and further development of the AAP. Mitigation measures identified as being necessary to avoid adverse harm to the natural environment should not be deferred to developers through high regarding the delivery of essential mitigation measures the AAP will need to specify how and where these measures will be delivered. Robust require ance with these plans should be set in AAP policy. With regard to accessible natural greenspace the AAP, with reference to the findings of the HRA/SA and the Greater Cambridge Local Plan Green Infrastructure and Biodiversity Opportunity Mapping project, should identify the quantum and quality of required provision for development, in- combination with wider growth, to avoid adverse impact on the natural environment. Viable opportunity areas for delivering the required level of greenspace, through expansion and enhancement of the existing GI network, should be identified and mapped, as a Green Infrastructure Framework, or similar, within the AAP. Robust policy requirements should ensure delivery of the framework through each phase of development. Ideally this should be combined ework, identifying similar viable opportunity areas for delivery of biodiversity mitigation and AAP enhancement targets.

Support: Introduction These representations on behalf of Hawkswren Ltd relate to the site occupied by Barr Tech at 90 - 92 Cowley Road. Barr Tech provides vehicle servicing and repairs within the existing building, and intends to relocate elsewhere in Greater Cambridge to enable the redevelopment of the existing site. A De Simone Investments Ltd has an option on the site and would seek to redevelop the site for a mix use development. As set out in these representations, A De Simone Investments Ltd broadly supports the policies for redevelopment of the site and the surrounding area, but it is requested that more flexibility is allowed in terms of the mix of uses and the building heights at the site. Policy 1: A comprehensive approach at North East Cambridge The comprehensive approach towards development and regeneration at North East Cambridge is broadly supported. Policy 1 expects the criteria in Policy 23 (Comprehensive and Coordinated Development) to be addressed for development proposals. It is noted that Policy 23 requires applications for major development to successfully integrate with the surrounding area. However, as set out in the response to Policy 9, it is noted that the development parcel that includes the Barr Tech site is proposed for buildings of 4 to 5 storeys and maximum of 6 storeys, when taller buildings are proposed for adjacent development parcels. It is requested that similar building heights are specified for the development parcel that includes the Barr Tech site as those for adjacent parcels, in order to deliver a comprehensive and coordinated approach to development. Policy 6a: Distinctive design for North East Cambridge The aspiration for development at North East Cambridge to provide distinctive, high quality and contemporary design is broadly supported. A De Simone Investments Ltd has an option on the site occupied by Barr Tech and would deliver the redevelopment of this site. The design criteria identified in Policy 6a are supported, and could be achieved for the redevelopment of the site. Policy 6b: Design of mixed-use buildings Policy 6b identifies general criteria for the design of mixed-use buildings, all of which are supported. The criteria requiring the design and construction of buildings to be adaptable and flexible is particularly supported. As set out in the responses to Policies 12a, 13a and 13f, the redevelopment of the Barr Tech site could accommodate a more flexible mix of uses including short term serviced accommodation. Policy 7: Legible streets and spaces The aspiration to create high quality, inclusive and attractive streets and spaces within North East Cambridge is broadly supported. Policy 8: Open spaces for recreation and sport Policy 8 expects major new development to provide for open space and recreation facilities. Figure 19 shows a linear park along the frontage of Cowley Road, which includes the proposed development parcel where the Barr Tech site is located. The delivery of open space and recreation facilities in North East Cambridge is broadly supported because it contributes towards high quality spaces and meets health and wellbeing needs. Policy 9: Density, heights, scale and massing Figure 21 shows proposed building heights and Figure 23 shows proposed densities for the different development parcels within the AAP area. The development parcel that includes the Barr Tech site indicates building heights of 4 to 5 storeys and a maximum of 6 storeys, and a density of 225 dwellings per hectare. In contrast the adjacent development parcels show taller building heights and higher densities, but there is no evidence provided to explain the differing building heights or densities. For example, the development parcels to the west, north and south show building heights of between 5 to 6 storeys and 6 to 8 storeys (maximums of 8 to 10 storeys) and densities of between 260 and 300 dwellings per hectare. It is requested that the building heights and densities for the development parcel that includes the Barr Tech site are increased to be consistent with adjacent parcels; a building height of 6 to 8 storeys and a density of 300 dwellings per hectare would be appropriate. The development parcel that includes the Barr Tech site is located within close proximity to a proposed mobility hub, it would be accessible by walking, cycling and public transport including Cambridge Guided Busway and Cambridge North Station, and it would be well related to the proposed District Centre. The location and future accessibility of the Barr Tech site supports additional development at this parcel in the form of taller buildings. Policy 10b: District Centre Figure 24 shows the proposed location of new centres for North East Cambridge, which includes a new District Centre on Cowley Road which would be located opposite the development parcel that includes the Barr Tech site. The location and mix of uses included within the proposed District Centre are supported. Policy 11: Housing design standards Policy 11 sets out the housing design standards for residential development within North East Cambridge. Those standards are supported and can be met for the proposed redevelopment of the existing Barr Tech site. 12a: Business The proposed development parcel containing the Barr Tech site is identified for business (B1) and housing uses. Policy 12a sets out the approach to the delivery of business uses in North East Cambridge. It is noted that Policy 12a proposes a flexible approach including for business types and sizes, other types of uses to provide an appropriate mix, and adaptable buildings that can be reused for other uses. It is considered that this flexible approach is appropriate at this stage because it is likely that market demand and economics for different types of uses will change during the lifetime of AAP. The redevelopment of the Barr Tech site could accommodate a more flexible mix of uses including business, housing and short term serviced accommodation. This mix of uses would be consistent with the proposed mix of uses for the Cambridge Business Park area as defined in Policy 12a. Policy 13a: Housing Policy 13a seeks to deliver a mix of housing types and tenures across North East Cambridge, including housing in the Cambridge Business Park area which is where the Barr Tech site is located. The housing strategy is broadly supported. The redevelopment of the Barr Tech site would include a mix of housing types and tenures alongside business (B1) uses, and could include short term serviced accommodation because of its close proximity to proposed business, community and retail uses and its proposed accessibility by sustainable modes of transport. Policy 13f: Short term/corporate lets and visitor accommodation Policy 13f includes criteria for new short term serviced/visitor accommodation. It is noted that the criteria include requirements for such accommodation to demonstrate need, to be located within district centres or business parks, and to be accessible by sustainable modes of transport. The approach towards short term serviced accommodation is supported. The redevelopment of the Barr Tech site could include short term serviced accommodation, and it is located within the Cambridge Business Park area, close to the proposed District Centre, and it would be accessible my sustainable modes of transport including Cambridge Guided Busway and Cambridge North Station. Policy 14: Social, community and cultural infrastructure The inclusion of additional social, community and cultural facilities within the North East Cambridge area is supported. Policy 15: Shops and local services The inclusion of additional shops and local services, including within the proposed District Centre on Cowley Road, is supported. Policy 16: Sustainable Connectivity Figure 36 shows proposed strategic walking and cycling routes in the North East Cambridge area, including new routes along Nuffield Road and Cowley Road. The proposed development parcel that includes the Barr Tech site would be located on these strategic walking and cycling routes, and also in close proximity to the proposed mobility hub at the Cambridge Guided Busway/Cowley Road intersection. The aspirations for sustainable connectivity across the North East Cambridge area is supported. Policy 17: Connecting to the wider network Figure 37 shows proposed connections for non-motorised transport within the AAP area and to neighbouring areas. The creation of new connections is broadly supported. The proposed crossing of the Cambridge Guided Busway from Cowley Road to Nuffield Road is supported because it would improve connectivity between neighbouring areas. Policy 19: Safeguarding for Cambridge Autonomous Metro and Public Transport Policy 19 seeks to improve public transport and refers to the delivery of mobility hubs in key locations across North East Cambridge. The proposed development parcel that includes the Barr Tech site would be located in close proximity to the proposed mobility hub at the Cambridge Guided Busway/Cowley Road intersection, which is supported. Policy 22: Managing motorised vehicles Policy 22 seeks to define a maximum vehicle trip budget for motorised vehicles across the North East Cambridge area, in order to reduce travel by private car. The proposed development parcel that includes the Barr Tech site would be located in highly sustainable location, making it possible for businesses, residents and visitors to the proposed uses to travel by non-car modes of transport. However, motorised vehicles will still need access the area, and it is requested that the monitoring system for the trip budget should be designed to exclude delivery vehicles to businesses. Policy 23: Comprehensive and Coordinated Development Policy 23 seeks to ensure a comprehensive and coordinated approach to development and regeneration at North East Cambridge, which is broadly supported. Policy 24a: Land Assembly As set out in the Introduction, A De Simone Investments Ltd has an option on the Bart Tech site, and intends to deliver development that is consistent with the mix of uses and policy requirements specified for this development parcel, subject to requested amendments on building heights and flexibility to include short term serviced accommodation. Policy 24b: Relocation As set out in the Introduction, Barr Tech intend to relocate their existing vehicle servicing and repairs business elsewhere, and A De Simone Investments Ltd has an option to redevelop the site. This relocation will only take place if a high use class value is generated on the site. Policy 24b sets out the process and criteria for assessing options for the relocation of existing businesses, and it is acknowledged that these steps might be appropriate for most circumstances where an existing business could be accommodated within the redeveloped AAP area. However, it is requested that Policy 24b also refers to the situation – as is the case with Barr Tech - where a willing landowner who operates an existing business has agreed to sell their land for redevelopment and relocate elsewhere, and in these circumstances the requirement for a relocation strategy to be prepared for a planning application should not be necessary. It is requested that a relocation strategy is specifically not required where a willing landowner or business has agreed to the redevelopment of their site. Policy 27: Planning Contributions Policy 27 sets out the purpose and approach to planning contributions for development within the North East Cambridge Area. It is acknowledged that the policy contains some flexibility, in that contributions will be assessed on a site by site basis and that viability will be assessed where relevant. It is requested that the level of planning contributions and viability matters should also take into account whether the successful delivery of a development parcel is related to the relocation of an existing business e.g. Barr Tech will need to find an alternative building for their existing business operations. Policy 28: Meanwhile uses The grant of temporary consent for ‘meanwhile’ uses within North East Cambridge is broadly supported. The ‘meanwhile’ uses could temporarily add to the range of facilities within the area, and could reuse empty or underused land and buildings. Policy 29: Employment and Training The employment, skills and training initiatives associated with development within North East Cambridge are supported.

Object: Introduction These representations relate to the site occupied by Tarmac off Cowley Road and are submitted on behalf of Turnstone Estates Ltd. Tarmac has a long leasehold interest in the land and it is current used for the batching of concrete. It is anticipated in the North East Cambridge AAP that the land currently occupied by Tarmac would be redeveloped for business (B1) and housing uses within tall buildings of between 4 to 5 storeys in height (up to a maximum of 6 storeys). Therefore, it is assumed in the AAP that Tarmac would relocate, but at this stage no alternative site has been identified. As set out in these representations, Tarmac intends to continue to operate from its existing site off Cowley Road until a suitable alternative site has been identified and approved. If Tarmac is able to relocate to a suitable alternative site then the proposed redevelopment of the site for business and housing uses is supported. It should be noted that funding has been provided to enable the relocation of the Cambridge Waste Water Treatment Works, but no funding is available for the viable relocation of other existing businesses including Tarmac. The site needs to generate a high use value to make the land viable and to fund the purchase, development and move to another relocation site. Therefore the proposed use of the Tarmac site for business (B1) and housing uses are supported. Policy 1: A comprehensive approach at North East Cambridge The comprehensive approach towards development and regeneration at North East Cambridge is broadly supported. However, a comprehensive approach must include the appropriate phasing of redevelopment sites to ensure that existing and proposed uses are compatible, and the successful relocation of existing businesses to suitable alternative sites Policy 6a: Distinctive design for North East Cambridge The aspiration for development at North East Cambridge to provide distinctive, high quality and contemporary design is broadly supported. The design criteria identified in Policy 6a are supported, and could be achieved for the redevelopment of the Tarmac site provided if the existing operations can be successfully relocated. Policy 6b: Design of mixed-use buildings Policy 6b identifies general criteria for the design of mixed-use buildings, all of which are supported. The criteria requiring the design and construction of buildings to be adaptable and flexible is particularly supported. The Tarmac site is identified within a development parcel for business and housing uses. The exact mix of these uses would be determined once the relocation strategy for the Tarmac site is known. Policy 7: Legible streets and spaces The aspiration to create high quality, inclusive and attractive streets and spaces within North East Cambridge is broadly supported. Policy 8: Open spaces for recreation and sport Policy 8 expects major new development to provide for open space and recreation facilities. Figure 19 shows a linear park along the frontage of Cowley Road, which includes the proposed development parcel where Tarmac site is located. The delivery of open space and recreation facilities in North East Cambridge is broadly supported Policy 9: Density, heights, scale and massing Figure 21 shows proposed building heights and Figure 23 shows proposed densities for the different development parcels within the AAP area. The development parcel that includes the Tarmac site indicates building heights of 4 to 5 storeys and a maximum of 6 storeys, and a density of 225 dwellings per hectare. In contrast the adjacent development parcels show taller building heights and higher densities, but there is no evidence provided to explain the differing building heights or densities. For example, the development parcels to the west, north and south show building heights of between 5 to 6 storeys and 6 to 8 storeys (with maximum building heights of 8 to 10 storeys) and densities of between 260 and 300 dwellings per hectare. It is requested that the building heights and densities for the development parcel that includes the Tarmac site are increased to be consistent with adjacent parcels; a building height of 6 to 8 storeys and a density of 300 dwellings per hectare would be appropriate. The development parcel that includes the Tarmac site is located within close proximity to a proposed mobility hub, it would be accessible by walking, cycling and public transport including Cambridge Guided Busway and Cambridge North Station, and it would be well related to the proposed District Centre. The location and future accessibility of the Tarmac site supports additional development at this parcel in the form of taller buildings. Policy 10b: District Centre Figure 24 shows the proposed location of new centres for North East Cambridge, which includes a new District Centre on Cowley Road which would be located opposite the development parcel that includes the Tarmac site. The location and mix of uses included within the proposed District Centre are supported. 12a: Business The proposed development parcel containing the Tarmac site is identified for business (B1) and housing uses. Policy 12a sets out the approach to the delivery of business uses in North East Cambridge. It is noted that Policy 12a proposes a flexible approach including for business types and sizes, other types of uses to provide an appropriate mix, and adaptable buildings that can be reused for other uses. It is considered that this flexible approach is appropriate at this stage because it is likely that market demand and economics for different types of uses will change during the lifetime of AAP. The redevelopment of the Tarmac site could accommodate a mix of types of business and housing uses consistent with those identified for the Cambridge Business Park area as defined in Policy 12a, but the exact mix of these uses would be determined once the relocation strategy for the Tarmac site is known. Policy 14: Social, community and cultural infrastructure The inclusion of additional social, community and cultural facilities within the North East Cambridge area is supported. Policy 15: Shops and local services The inclusion of additional shops and local services, including within the proposed District Centre on Cowley Road, is supported. Policy 16: Sustainable Connectivity Figure 36 shows proposed strategic walking and cycling routes in the North East Cambridge area, including new routes along Nuffield Road and Cowley Road. The proposed development parcel that includes the Tarmac site would be located on these strategic walking and cycling routes, and also in close proximity to the proposed mobility hub at the Cambridge Guided Busway/Cowley Road intersection. The aspirations for sustainable connectivity across the North East Cambridge area is supported. Policy 17: Connecting to the wider network Figure 37 shows proposed connections for non-motorised transport within the AAP area and to neighbouring areas. The creation of new connections is broadly supported. The proposed crossing of the Cambridge Guided Busway from Cowley Road to Nuffield Road is supported because it would improve connectivity between neighbouring areas. Policy 19: Safeguarding for Cambridge Autonomous Metro and Public Transport Policy 19 seeks to improve public transport and refers to the delivery of mobility hubs in key locations across North East Cambridge. The proposed development parcel that includes the Tarmac site would be located in close proximity to the proposed mobility hub at the Cambridge Guided Busway/Cowley Road intersection, which is supported. Policy 23: Comprehensive and Coordinated Development Policy 23 seeks to ensure a comprehensive and coordinated approach to development and regeneration at North East Cambridge, which is broadly supported. Policy 24a: Land Assembly It is anticipated in the North East Cambridge AAP that the existing Tarmac operations off Cowley Road would be relocated and the site redeveloped for business and housing uses – see Figure 11. It should not be necessary for compulsory purchase to be used because the Tarmac site could be redeveloped in conjunction with Cambridge City Council for the proposed business and housing uses, and designed to meet the policy requirements specified in the AAP. Policy 24b: Relocation It is anticipated in the North East Cambridge AAP that the existing Tarmac operations off Cowley Road would be relocated and the site redeveloped for business and housing uses. Tarmac intends to remain operating from its existing site until a suitable alterative relocation site has been identified and approved. At this stage no suitable alternative relocation site is identified for Tarmac. Criteria (b) of Policy 24b requires engagement with affected occupiers and tenants where relocation of existing businesses is proposed as part of development at North East Cambridge. Tarmac would be affected by the redevelopment of its existing site, and would welcome discussions with the Council to find a suitable alternative site from which it can operate. Criteria (c) of Policy 24b sets out a sequential approach to the re-provision of existing uses. Tarmac is an existing established business, and a replacement facility should be located within or close to Cambridge in order to avoid the unnecessary transportation of aggregates and materials. The assistance and support of the Council will be required to enable Tarmac to relocate its existing operations in a viable manner. Policy 27: Planning Contributions Policy 27 sets out the purpose and approach to planning contributions for development within the North East Cambridge Area. It is acknowledged that the policy contains some flexibility, in that contributions will be assessed on a site by site basis and that viability will be assessed where relevant. The Tarmac site is proposed to be redeveloped for business and housing uses, however, there will be costs associated with the relocation of the existing operations to an alternative site including the purchase of land. If the redevelopment of the Tarmac site and the associated relocation of the existing operation is not viable, then it will either not happen or adjustments will need to be made to the proposed quantum of development or mix and type of uses provided at the site. Policy 29: Employment and Training The employment, skills and training initiatives associated with development within North East Cambridge are supported.

Introduction The RSPB is the charity that takes action for wild birds and the environment. We are the largest wildlife conservation organisation in the country with over one million members. We own or manage 158,725 hectares of land for nature conservation on 220 reserves throughout the UK. The RSPB’s policy and advocacy work covers a wide range of issues including planning policy, climate change, energy, transport, marine issues and water. Our casework team is involved in responding to major infrastructure projects where these could result in significant harm to nature. We have also undertaken significant large-scale habitat restoration and nature conservation projects in partnership with major transport infrastructure projects to realise benefits for nature, the environment and society. Locally, we are an active member of Natural Cambridgeshire and own/manage three nature reserves in the Greater Cambridge area. Overview In line with the Governments 25 Year Plan for the environment, Natural Cambridgeshire has set an ambition to ‘Double Nature’ across the county of Cambridgeshire. Its vision to provide ‘…a world class environment where nature thrives alongside jobs and housing’ has been acknowledged and supported by the Greater Cambridge Council Partnership. In doing so, they pledge to ensure all existing and new developments provide opportunity to double the area of wildlife rich green space. A test of this support comes with the North East Cambridge Area Action Plan and if the proposals can meet the expectations of the Doubling Nature ambition. The RSPB vision for the entire Arc from Oxford to Cambridge is one that protects and restores nature while setting new standards for sustainable development. It requires that the Arc demonstrates best practice across all disciplines whilst aiming to showcase new and exemplar practices. It proposes all new developments, including infrastructure, aim for a minimum 20% net gain for biodiversity and be carbon neutral. In order to achieve this, economic growth must respect environmental constraints and should put nature first at all stages of planning and delivery, starting with master planning. It requires high standards of nature-friendly green infrastructure design that improves the quality of life for residents by increasing climate resilience, biodiversity and access to nature across the Arc. Not to waste these efforts and aspirations to meet the aims of the Government’s 25 Year Environment Plan, Natures Arc proposes long-term monitoring and management plans are established for all green infrastructure and new habitats. These should be funded in perpetuity through initial capital investments, making suitably qualified and mandated organisations responsible for delivery. We reviewed the North East Cambridge Area Action Plan vision against its potential to deliver the aims and objectives outlined above from Doubling Nature and Natures Arc. While the visions are ambitious there are areas, we feel require more attention and the scheme falls far short of being able to champion this as a sustainable low carbon development, that provides public health and wellbeing, quality of life, placemaking and high nature conservation value both on and off site. It is similarly contrary to the aims and image Cambridge strives to set in being a leader of sustainability. The plan should seek to follow leads such as this set by the EU's sustainable energy project SPARCS: https://finance.yahoo.com/news/shopping-centre-lippulaiva-become-pioneer-064700680.html Our key points in response of the ten questions follow, with qualifying notes set out in Appendix 1 at the end of the document.

This response is submitted on behalf of Urban&Civic (U&C) by David Lock Associates (DLA). The opportunity to prepare a response to the North East Cambridge Area Action Plan (NEC AAP) is welcomed. This response raises some general but important points about the APP and we hope that this form of submission is appropriate. Waterbeach Barracks and Airfield U&C is appointed as development partner and master developer on behalf of the Ministry of Defence (DIO) at Waterbeach Barracks and Airfield. Outline Planning Permission was granted in September 2019 and U&C is now progressing delivery of the redevelopment of the Barracks and Airfield for a new community, including up to 6,500 new homes. This consent relates to part of the wider Local Plan allocation for Waterbeach New Town. U&C is an important stakeholder in the wider development of the northern sector of the Cambridge Fringe and is committed to supporting the coordinated and comprehensive development of the city. In the context of this consultation, there is particular significance attached to ensuring the coordinated development of public transport between NEC and Waterbeach, as well as the wider area and also in achieving the most effective solutions for the relocation of existing uses at NEC, including the Waste Water Treatment Works. Through this consultation response, U&C welcome the opportunity to reinforce the importance of strategic infrastructure projects across this part of the city, and the need to ensure effective connections and integration of Waterbeach New Town with NEC, as a gateway to the wider city centre. Given the role of U&C as a significant stakeholder in the growth of northern Cambridge and the interrelationship, particularly from a sustainable transport perspective, between Waterbeach New Town and NEC, we would welcome further, early and ongoing dialogue with the Councils and other key stakeholders, to ensure continuing and effective co-ordination of all development and infrastructure across the northern sector of the Cambridge fringe. In light of the above, our comments primarily seek to support the emerging AAP and the recognition it provides to the evolving infrastructure projects, and reinforce that these must continue to be integral to the ongoing development of the AAP. Sustainable Travel in North Cambridge Cambridge is growing at pace and U&C endorses the efforts of all authorities, stakeholders and infrastructure providers who are currently involved in the multiple, prominent projects across the city and wider sub-region to facilitate and support this growth. This includes, importantly, the Cambridgeshire and Peterborough Combined Authority (CPCA) and its work on delivering significant improvements along the A10 and the Cambridgeshire Autonomous Metro (CAM) and the Greater Cambridge Partnership (GCP) and the Waterbeach to Cambridge Public Transport Projects, as well as infrastructure schemes and investments provided by development projects themselves, such as at Waterbeach Barracks and Airfield. These combined infrastructure projects represent a vital step change in the ability of Cambridge and its wider subregion to continue to sustain significant economic growth whilst operating effectively and efficiently. Together, they are critical in ensuring reliance on private vehicles is reduced and it is crucial that such projects align and work well together, creating a smoothly integrated sustainable transport system. These projects are all prominent in their own right and many are still at an ‘options’ stage of evolution. The AAP has a key role in coordinating comprehensive development at NEC, particularly given the multiple ownerships, the complexity of the site and proposed development and the convergence of numerous infrastructure projects in this location. U&C support the preparation of the AAP to secure this coordinated growth and importantly, a cohesive public transport system and integrated sustainable travel. We have set out our key comments in this regard below: Mere Way Sustainable Travel Link - U&C support the recognition in draft Policy 17 – Connecting to the Wider Network – for the Mere Way link. This is an important route being delivered by U&C as part of the Waterbeach New Town and it is vital that it is accommodated within NEC and that the development proposals respond positively to the route. U&C are currently progressing the detailed design of Mere Way for its implementation in accordance with the early trigger on its outline permission. With this detailed design underway, it is essential that ongoing work on the AAP takes into account the measures and design requirements of the route through the western component of the AAP area. We recognise that the figures / plans provided with the draft Regulation 18 AAP are diagrammatic, however, consider that there should be full regard to the accurate alignment of Mere Way as it passes through NEC. This is significant given the different ownerships at play and, whilst the route follows an existing Public Right of Way in this location, some minor works will be required to upgrade the route. The Mere Way scheme is understood to affect both the Cambridge Regional College ownership and the adjacent private landowners and therefore this should be reflected on any plans showing the route for transparency. U&C is happy to engage further on the details of the route in this location to assist in it being accurately represented. Waterbeach Greenway – U&C also support the AAP’s reference to the Greenway and approach to addressing its routing. This scheme has now secured funding and therefore it is necessary that the AAP continues to respond positively to it through subsequent stages of design and development. CPCA A10 Improvement Works – the A10 improvement works are a nationally significant project which would have a substantial positive impact on traffic movements both across Cambridge and the wider area. The Milton Interchange is a key node on the Strategic Highway Network and there are planned improvements to this junction to increase its capacity. Whilst the extent of the works committed as part of the U&C Waterbeach development should not have a direct impact on the NEC site, it is important that the AAP remains cognisant of its relationship to this junction and the wider A10 improvement works, which are still in evolution stages, and ensures that it does not have a detrimental impact on any future works being achieved. Furthermore, given the recognised capacity issues of the Milton Interchange within the AAP, there is an even greater onus on facilitating an effective public transport network through NEC. CAM and Waterbeach to Cambridge Project – Similarly, U&C welcomes the considerable recognition within the AAP to accommodating the CAM scheme, for which options are still being considered. Given the prominence of this project and its potential ability to transform travel around Cambridge and the wider area, it is of utmost importance that the AAP remains flexible to accommodate any of the CAM options which may be pursued. U&C support Policy 19 and the intention to safeguard the necessary corridors and reinforce that the AAP should allow for the necessary evolution of the scheme. In the same respect U&C support the approach to the Waterbeach to Cambridge Project and the Cambridge North Transport Interchange in the AAP. The Interchange will be a strategic transport hub, facilitating effective connections between different sustainable modes of travel as they converge on north Cambridge from the wider area. Ensuring such a facility is well positioned and designed and thus, efficient to navigate, will be essential in encouraging use of public transport. Therefore, it is paramount that the AAP allows for this project to evolve alongside the related public transport projects which it may serve. In this same context, we support the general policy position on Mobility Hubs also set out in Policy 19. As noted in respect of the North Cambridge Interchange, mobility hubs throughout north Cambridge will serve an important purpose in making public transport attractive and easy to use. This is essential in ensuring effective connections within the various growth locations of the Cambridge fringe, and also with Cambridge city centre and other key destinations, including key employment and education hubs. Such hubs should therefore be encouraged and provide for a range of facilities. Waste Water Treatment Works (WWTW) Relocation – The AAP is obviously reliant on the re-location of the WWTW and U&C provided comments on the recent Anglian Water (AW) consultation on this specific project. In its response, U&C set out a clear position on the three site options, this was based around two of the potential sites being more constrained and raising a number of key implementation issues. Acknowledging that one site is considered to be much more practical from a delivery perspective, it is important for the Council’s to continue to work with AW and support the selection and development of the relocation site, which U&C consider needs to be AW site option 3 as this is the least constrained and therefore will facilitate the AAP more effectively. We trust that this provides a clear position and demonstrates our support for the general approaches in the emerging AAP. The Councils have clearly taken a very considered approach to preparing the AAP and recognise the critical considerations for taking forward this important growth area. It is essential that in subsequent stages of the AAP, such projects are continued to be given sufficient regard and necessary flexibility to achieve a well aligned and coordinated development and sustainable travel system for the city. U&C welcome the opportunity for further dialogue with the Councils and please do let us know you have any queries regarding this response.

Central Bedfordshire Council (CBC) welcomes the opportunity to comment on the Area Action Plan (AAP) and we look forward to continuing the good working relations that have already been forged between our Councils. To this end, I hope you find the comments below useful. As the land area covered by the AAP is a reasonable distance from Central Bedfordshire, it is considered unlikely that the redevelopment of the site would directly impact on any settlements or communities within Central Bedfordshire. CBC is however supportive of a number of aspects of the AAP, particularly: • the overall approach to the north east of Cambridge which is to support all parts of the community by building social and economic links, encouraging collaboration and innovation, and creating access for everyone to jobs, training and leisure. • the approach to relocate the Waste Water Treatment Works (WWtW) to open up the site and enable a comprehensive regeneration development upon a brownfield site. It is recognised that the relocation of the WWtW will enable the provision of a newer, more fit for purpose facility that will have the capacity to meet future growth needs within the area; • the ambition to deliver 8,000 new homes and commensurate number of jobs. The provision of new homes is essential and being within the Oxford-Cambridge Arc, there is a need to deliver higher numbers so as to contribute to the Governments ambitious targets. 20,000 new jobs seems ambitious and whilst it is appreciated that new jobs provided will help to meet the wider needs of the area, it is considered important that the over-provision of new jobs should not be to the detriment of other locations and neighbouring authorities being able to attract and deliver economic growth. proposals for integrating walking and cycling throughout the development. This is considered to be an essential element of sustainable communities and also contributes to a reduced impact on the local environment and contributes to the climate change agenda. CBC looks forward to seeing how the North East of Cambridge proposals develop over the coming years as well as to future engagement in relation to the development of the Planning Policy – both in relation to our individual plans and in relation to the wider Oxford to Cambridge Arc.

Further Comments Transport 11.1 In a broader context, it is noted that the status of the document is such that it does not carry any weight or commitment in determining planning applications. Given the lengthy timescales for the adoption of the AAP and the number of planning applications that are likely to come forward before this time, County Council transport officers have developed a position statement to outline how we intend to deal with such applications in the meantime. The position statement does not prevent planning applications from coming forward and seeks to deal with them in an equitable manner that doesn’t jeopardise the overall direction that the plan is moving in. Fen Road Level Crossing 11.2 The position in the plan regarding the Fen Road Level Crossing is noted, as is the fact that a number of responses were received by the Shared Planning Service on the issue. Whilst acknowledging that it shouldn’t be the sole responsibility of the AAP to resolve the current issues experienced by users of the crossing which are largely caused by the way in which the rail industry operates its level crossings, there is a wider issue of facilitating the growth in rail capacity along the this stretch of the rail network. While development on North East Cambridge will drive additional rail patronage into and from Cambridge North station, it is growth across the Cambridge sub-region and county / neighbouring areas that combined is likely to lead to demand for more trains on the line. North East Cambridge, in common with other large development sites immediately adjacent to stations on the line will be a significant contributor to this demand. Furthermore, with the strict vehicular trip budget that North East Cambridge will have, it is imperative that future increases in rail capacity aren’t constrained through a lack of strategic planning. In the longer term if the crossing issue isn’t resolved it will hamper the ability for extra rail capacity to be provided on this part of the rail network and could frustrate plans to accommodate growth of the local economy more widely 11.3 In order to ensure that increased rail capacity can be delivered on this part of the rail network in the future, there is a need to start exploring what long-term alternatives to the Fen Road crossing might be acceptable. Although the level crossing lies outside the AAP area, North East Cambridge could provide one of these alternatives. 11.4 If future work identified that alternative access were needed, and that a bridge or underpass of the railway between North East Cambridge and Fen Road was the preferred option, land in the North East Cambridge site for such a link would need to have been reserved for this. It is therefore considered that until such time that it is demonstrated that a replacement for the crossing will not need to go into the NECAAP site, land should be safeguarded for this purpose. This is to ensure that potential options aren’t ruled out prematurely, rather than suggesting that the site should bear the cost of such a scheme. 11.5 Ownership of the problem is needed from a range of stakeholders, principally Network Rail the Local Planning Authorities, the Cambridgeshire and Peterborough Combined Authority as Transport Authority and Cambridgeshire County Council as the Highway Authority. Only through this joint ownership will the issue be moved forward and the issue of whether land needs to be safeguarded in the NECAAP area for such a purpose be thoroughly aired.

On behalf of The Crown Estate, the freehold owners of Cambridge Business Park, we submit representations to the Regulation 18 Consultation of the North East Cambridge Area Action Plan (AAP). The Crown Estate supports the principle of the regeneration and redevelopment of land covered by the draft AAP for high quality mixed use sustainable development. The Crown Estate is a long term investor/developer and is keen to work with Cambridge City Council, South Cambridge District Council, adjoining landowners and developers and other stakeholders in relation to North East Cambridge. The Crown Estate is taking an active role in the AAP process and is an active participant in stakeholder engagement. The Crown Estate notes that the adopted Area Action Plan will be a development plan document that will form part of the statutory development plan for both Cambridge City Council and South Cambridgeshire District Council. It is acknowledged that following the Regulation 18 consultation the draft policies will be refined in response to the comments received and emerging evidence studies that the Councils are undertaking. The next version of the Area Action Plan will then be published for a further round of public consultation in which The Crown Estate welcomes the opportunity to become actively involved. The Crown Estate and Cambridge Business Park The Crown Estate is the freehold owner of Cambridge Business Park (Site J on Page 30 of the Draft AAP). 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. Master Planning of Cambridge Business Park The Crown Estate recognises that Cambridge Business Park occupies a strategic location within the draft AAP area and therefore has a key role to play in delivering the spatial framework and objectives of the AAP. The five strategic objectives of the AAP which seek to guide redevelopment in the area are shared by the Crown Estate as set out below;  To ensure development addresses both the climate and biodiversity emergencies, and leads the way to reach net zero carbon;  To create a sense of place that will be a lively, mixed-use area which fosters community wellbeing and encourages collaboration.  To integrate with surrounding communities – to be physically connected, and socially cohesive.  To optimise the delivery of new homes, a full range of jobs and provision of local amenities.  To create a healthy district where wellbeing, recreation and community safety are built into how it is designed.  To be planned around walking, cycling and public transport as a key way to address climate change. The Crown Estate has appointed a multi-disciplinary team to consider the potential of the Site within the context of the evolving AAP objectives and having regard to the aspirations of the other landowners, developers and stakeholders in the AAP area. The on-going activities includes developing an over-archiving development framework or masterplan which is being prepared by masterplan architects Studio Egret West (SEW), and a Phase 1 office based development to the Milton Road frontage of the Site designed by Barr Gazetas in accordance with the masterplan. The latter is subject to a current pre-application process with Cambridge City Council. The wider consultancy team includes:  TTP Consultancy-providing transport consultancy  CBRE-providing commercial real estate advice  Watermans-providing environmental and sustainability consultancy The master planning undertaken by SEW and the Phase 1 building proposed by Bar Gazetas has regard to the objectives and broad design parameters evolving through the AAP process, including the potential scale and heights of buildings on the Site. Based on a variety of building heights across the Site, but typically 6-8 with a maximum of 10 storeys (see draft Policy 9 and Figure 21-see below), SEW consider that there is potential to deliver the range of uses proposed for the Site in the AAP and potentially net additional B1 offices compared with the draft AAP. We have included below an initial scale, height and massing exercise based on a full scale redevelopment of the Site which could deliver up to 180,000 sqm of new development. This exercise follow the approaches scoped as part of the landowner’s forum process with the Council’s and other stakeholders. Therefore, based on the master planning work undertaken to date and having regards to the stage that the AAP has reached, The Crown Estate consider that the AAP should fully reflect the development potential of the Site and therefore propose that the relevant policies, figures and trajectories include for additional development. Given the Site's prevailing B1 office use and the proposed wider distribution of uses across the AAP area, these representations are made on the basis that the additional development capacity of the Site is reflected in an increase in B1 offices. Scope of Representations These representations to the Regulation 18 Draft AAP are made on the following basis:  General comments;  Comments on the 10 main overarching questions raised by the Councils; and  Policy and Site Allocation specific. Absence of comment or representations on specific issues should not be taken to be “default” support and The Crown Estate reserves its position to make further comments as appropriate and specifically as and when further/additional evidence base documents and studies are completed and made available. General Comments We would make the following general comments which we would invite the Council’s to give due consideration to in their evolution of the AAP. The Council’s will be aware of the Governments White Paper “Planning for the Future” and it’s propositions with regard to spatial planning, a stream-lined development plans system, proposals to replace the current Community Infrastructure Levy and S106 mechanism with a new Infrastructure Levy, changes to Standardised Housing Need requirements, etc. Potentially, these proposed changes will have material implications for content, scope and delivery of the AAP. 4 Amendments were introduced to the Use Classes Order on 1st September 2020. These draw together the majority of the previous employment generating uses compatible with a residential area into a new Class E and also created new F1 and F2 Classes which would be relevant to the planning of the AAP area. The Government’s objective for Class E was to consolidate the commercial use classes to allow for greater flexibility and efficiency to allow for a wider range of uses to take place without the need for prior approval of local authorities. This includes the previous Class B1 uses and many of the uses commonly found in Centres (i.e. Use Class A1, A2 and A3 and some leisure and community uses). At the headline level, these changes will have implications for how the Councils have described the distribution of uses across the AAP area. In addition, we would respectfully suggest it would have implications for how the Councils approach the definition of uses, specifically within the proposed centres. We note that the supporting documents for the AAP is “work in progress”. This includes, inter alia, in relation to Heritage Impact and Townscape Assessments, the approach to an AAP wide energy solution, etc. It is acknowledged that the APP process will not be concluded before this evidence basis is concluded in full. In principle, The Crown Estate supports a regime to apportion the infrastructure and other costs to deliver development in the AAP area. This will need to have regard to the existing (“base”) position of the individual sites within the AAP area, the relationship between proposed development and infrastructure requirements, etc. We would suggest that the more effective approach would be one that is straightforward and transparent so that there is a clear apportionment of “cost” associated with development which can be factored into assessments at the outset. Various landowners and developers within the AAP area are at different stages of formulating proposals for their sites and potentially bringing forward development. This includes The Crown Estate who are engaged with the Council in a pre-application process for a new development fronting Milton Road. Given the need for a comprehensive approach to the planning of the AAP area as a whole and an equitable approach to the funding and delivery of infrastructure, etc it is important that the AAP (alongside other provisions available to the Councils) ensures that a “first past the post” position does not arise. Finally, we highlight the potential overlap between the AAP programme and timescales/trajectories set out in the Draft AAP. For example, the Local Development Scheme indicates potential adoption of the AAP in 2025 and that this will be dependent upon, inter alia, the Anglia water Treatment Works DCO, an Independent Examination into the AAP and the position of the Greater Cambridge Local Plan. Set against this, the draft AAP includes development trajectories for the period 2020-2025. We would suggest this either requires a direct acknowledgement of development in the AAP area running ahead of the AAP adoption or the trajectories should be pushed out. On the basis that the development of some sites within the AAP and the uses proposed thereon would not, in our opinion, be fundamentally dependent upon the relocation of the Water Treatments Works, the final adoption of the AAP, or can otherwise come forward within the development plan framework set by the existing Cambridge plans, this would suggest the former. Comments on 10 Overarching Questions The Crown Estate notes the 10 overarching questions for the Regulation 18 consultation, and sets out comments below on each question. 1. The Vision for North East Cambridge The Crown surrounding supports the Councils vision for North East Cambridge to be 'an inclusive, walkable, low-carbon new city district with a lively mix of homes, workplaces, services and social spaces, fully integrated with which aligns with The Crown Estate's key development principles. In addition, The Crown Estate sets a number of sustainability aspirations which support the overarching vision for North East Cambridge and will be applied across future development across its Site. These include: - Improving Social Value: Social value is increased where a great place brings people together, creates a community, and addresses the specific needs of the local context. The Crown Estate looks to ensure that the design of future buildings, and their relationship with the public realm support the creation of an economically inclusive, diverse and cohesive communities. - Improving Human Value: Human value is increased where quality and longevity of life is improved, and happiness is increased. The Crown Estate will seek to provide an environment across the Site that protects peoples’ health, both indoors and outdoors; support and encourage an active lifestyle; and enhance wellbeing by creating places that support health, happiness, and prosperity. - Improving Natural Value: Natural value is increased by achieving positive gain through the protection of existing quality and where new complimentary resources are introduced. Future development at the Site will seek to protect and enhance the existing biodiversity. The materials used in future development will be carefully considered so that they prioritise the use of reused and recycled products over raw materials. The embodied carbon impact of various construction options will be assessed for each building to inform decision making particularly on the structure, sub-structure and building envelope. - Improving Physical Value: Physical value is increased where buildings and infrastructure respond to the local context, are designed for longevity, and allow people to navigate easily on foot and by bike. Cambridge Business Park occupies a strategic location with the AAP area and The Crown Estate will seek to provide a high quality urban space which improves physical value and aligns with the hierarchy of spaces across the area. Furthermore, smart technology and sustainable design will ensure that the development across the Site will be future-proofed and climate adaptable. - Improving Economic Value: Economic value is increased where the development supports an equitable distribution of the economic benefits during construction, in-use, and supports a positive economic legacy. Connected and Integrated (see also Policy 17) The AAP sets out to improve accessibility across the AAP area, and includes new and improved pedestrian and cycle networks which help to link North East Cambridge with nearby villages, the City Centre and surrounding area. Of particular relevance to the Site are the new crossings points proposed over the guided busway, the new crossing on Milton Road (see below) and the improved junction for pedestrian and cycle movement at Milton Road. The Crown Estate's vision for Cambridge Business Park is to plan new development around walking, cycling and public transport as a key way to address climate change. In principle, The Crown Estate therefore supports the proposals to improve pedestrian and cycle connections within the AAP area but further work is required in relation to potential pedestrian and cycle connections over Milton Road with the draft AAP highlighting a preference for a bridge in the vicinity of Cowley Road / Science Park Entrance and an underpass further north in the vicinity of the Innovation Centre access, with an at grade crossing to the south by the existing Guided Bus junction. It is acknowledged that the bridge and underpass would have the least impact on motorised traffic running along Milton Road. However, a bridge in particular with a relatively long transition to obtain the necessary clearance over the road would have a relatively significant impact on accessibility to adjacent properties. Although an at-grade crossing could affect through vehicular movements along Milton Road, evidence from the DfT data suggests that these movements have been reducing over time, and by all accounts there is the potential for there to be more pedestrian and cyclists across Milton Road than motor vehicles along the corridor and as such pedestrians and cyclists should have priority. Construction costs associated with the bridge and underpass would also be relatively high when compared to at-grade crossings, with apportionment of costs along with benefits being further considerations that need to be taken into account. We are of the opinion that whereas delivery of the wider AAP is important, crossings over Milton Road are more likely to be key for connections between the Science Park and Cambridge North Station. Furthermore, the proposed at-grade crossing in the vicinity of the Guided Busway is likely to be the most direct route to / from Cambridge and large parts of the AAP once the frontage along the Guided Busway is opened up. Promoting at-grade crossings in all three locations could reduce costs which would increase delivery potential along with releasing funding for other uses with an anticipated relatively limited impact on the capacity of the Milton Road corridor. In terms of external connectivity, the Draft AAP and supporting documents refer to additional bus services and train carriages in the short to medium term, with the creation of the Cambridge Autonomous Metro (CAM) in the medium to longer term. However, whereas additional bus services and train carriages would provide additional capacity, usage will depend on the frequency along with the origin / destination of any services. Whilst the creation of the CAM with links to St. Neots, Huntingdon and Waterbeach to the north of Cambridge along with destinations to the south is supported in principle, is likely to be subject to significant funding and land constraints making delivery challenging. In conclusion, we respectfully suggest that additional work needs to be undertaken to address the connectivity and integration objective for the AAP area. Not least, this goes to the heart of the development capacity debate which is determined by a “no additional vehicle movements” objective. Social and Cultural Hubs (See also Policy 10) In principle, The Crown Estate supports the location of the four proposed centres within the AAP area which seek to create active, lively focal points for new and existing residents and workers. The location of the proposed District Centre, situated centrally to the AAP and along the north east boundary of the Site, is supported. This is particularly important for the District Centre which is proposed to straddle The Crown Estate and adjoining ownership so as to create a double sided “High Street”. This will require a joined up approach to its delivery and it is proposed that the relevant policy (see below) explicitly allows for this. Notwithstanding, The Crown Estate considers that emerging policies for the social and cultural hubs should include a degree of flexibility in terms of uses, scale and detailed location in order to reflect phasing of development and the changing economic and social context. Furthermore, The Crown Estate would suggest further consideration is given to the cost of delivering the social and cultural hubs, as seen with the apportionment cost mechanism for the site wide infrastructure. Given the social and cultural hubs will serve the AAP as a whole, it may be appropriate that the costs (or a proportion thereof) of delivering such centres should not fall solely on the landowners/developers of the sites where the centres are located. 4. Homes and Workplaces The Crown Estate notes the proposed mix of uses within the AAP area including the provision of 8,000 new homes and 20,000 new jobs. The Crown Estate supports the principle of an integrated mix of uses across the AAP area, however suggests the AAP considers a degree of flexibility should be applied with how this is distributed. 5. Social and Cultural Facilities The Crown Estate notes the proposed mix of social and cultural community facilities within North East Cambridge including the provision of health facilities, a library, cultural facilities, schools and a community centre. It is acknowledged that such facilities will be required to ensure pressure is not placed on existing resources arising from the increase of residents and workers in the area. The Crown Estate supports the provision of community facilities within the area. However it is considered that a degree of flexibility is required in the delivery of facilities in terms of phasing, location, and associated costs. 6. Distribution and Location of Building Heights and Density The draft AAP discusses the sustainability of North East Cambridge as a place to build having regard to its brownfield land, good public transport, walking and cycling links. The Crown Estate supports the AAP's aspiration to build a critical mass of new homes and workspace in the area, and considers the approach to the distribution of height and density across the AAP broadly appropriate (see comments on Figure 21 and Policy 9 below). 7. Open Spaces In line with The Crown Estate's objectives for Cambridge Business Park, the proposed public open spaces are supported to help create a healthy City district where wellbeing, recreation and community safety are built into how it is designed. The proposed Green High Street along Cowley Road and the Linear Park stretching from Milton Country Park to Nuffield Road, including where it passes through the Site, are supported in principle. Notwithstanding, The Crown Estate considers the need to for the AAP to provide additional details on specifically where the open spaces will be located and how they will be funded particularly in terms of the potential impact on development density, etc. It should be acknowledged that such open spaces will serve the needs of the wider North East Cambridge area, and therefore the costs of delivering such social infrastructure should not fall solely on the land owners to which the spaces are located. Discouraging Car Use (see also Policy 22) The draft AAP sets out the objective to encourage sustainable, active travel and discourage all non-essential vehicle traffic and an over-riding no additional vehicle movement objective. This objective is proposed to be achieved through a number of options, including, giving priority to pedestrian and cyclists, ensuring all streets are designed to keep speed limits below 20mph, limiting parking spaces to a maximum of 0.5 spaces per home, and ensuring no additional vehicle movements on Milton Road. The Crown Estate supports the strategy of the AAP to discourage car use into the area, however further work is required in relation to the details and in particular the modelling which forms the basis of the approach. We note that there has been much discussion regarding the most appropriate source of this additional information, including a suggestion that the landowners collectively undertaken an exercise. It is The Crown Estate's view that the transport issues, particularly the objective that there be no additional vehicle movements, are central to the AAP approach that presenting a comprehensive agreed set of base data and parameters against which, inter alia, development capacities can be assessed should be led by the Councils and comprise part of a sound evidence base for the AAP. The AAP area is relatively well connected by public transport with bus services running along Milton Road, the Guided Busway running along the southern boundary and the recently opened Cambridge North Station. However, it is recognised that Milton Road carries relatively high volumes of traffic and acts as a barrier to east-west pedestrian and cycle movements, albeit data from the DfT website suggests that traffic volumes a short distance to the south are lowest now (based on a 2016 count), with the highest recorded count of over 15,500 recorded in 2006. Notwithstanding this, the AAP sets targets of 3,900 two-way movements for the weekday AM Peak Hour and 3,000 two-way movements for the weekday PM Peak Hour for the AAP area. The flows have been based on a LINSIG model using traffic data from 2017 prior to the opening of the Cambridge North Station, and since this time there has been a mode shift away from the car at the Cambridge Business Park. We therefore have some concerns that the adopted targets have been based on a simplistic approach and that more detailed traffic counts and modelling need to be undertaken particularly given it forms the foundation for the principle approach to the AAP- i.e. no additional vehicle movements. Setting aside potential concerns regarding the base data, measures to discourage car use include increasing the capacity of the Park & Ride site to the north of the A14 along with parking “barns” with the aim of reducing car parking within the AAP area itself and associated traffic generation. Overall, capacity for a maximum of 6,500 cars is proposed within the Car Barns across the AAP area for employment uses with 4,800 spaces accessed from Milton Road and 1,700 spaces accessed from Kings Hedges Road. The Crown Estate is supportive of reducing car parking subject to details on the distribution of spaces, with neither the Draft AAP nor the Transport Evidence Base stipulating how spaces will be allocated. Furthermore, with existing and consented parking provision on the Science Park alone being greater than the overall proposed provision, there is concern that adhering to the proposed level could affect delivery of the wider AAP. Consideration could be given to allocating parking based on site area or on the current CCC aspirations rather than developer aspirations which would remove the potential for developers to be “allocated” more parking with higher density aspirations. It is unclear if the aspirations to increase the capacity of the Milton Road Park & Ride is seeking to remove vehicular movements from the wider highway network or just from the Milton Road corridor, as although it would achieve the latter, it would not necessarily remove many movements from the A14 / Milton Road interchange which is identified in the Draft AAP as a traffic hotspot and will be of interest to Highways England.

Re: North East Cambridge Area Action Plan Consultation under Regulation 18 of Town and Country Planning (Local Planning) (England) Regulations 2012 Submission of the Department for Education 1. The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. 2. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and DfE is the delivery body for many of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient school places, including those at sixth form, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We have published guidance on education provision in garden communities and securing developer contributions for education, at https://www.gov.uk/government/publications/delivering-schools-to-supporthousing- growth. You will also be aware of the corresponding additions to Planning Practice Guidance on planning obligations, viability and safe and healthy communities. 3. We would like to offer the following comments in response to the above consultation document. These comments follow from our previously submitted representations (March 2019) to the AAP which are appended, and also our representations to the Greater Cambridge Plan (February 2020). General Comments 4. DfE is looking to secure a site for the delivery of Cambridge Maths School through The Learning Alliance (a multi academy trust formed from merging Cambridgeshire Educational Trust into the Morris Education Trust) and has identified North East Cambridge as an ideal location for this, due to regional accessibility and wider economy and skills concentration. We look forward to working with Greater Cambridge Partnership (GCP) officers to achieve this and establish a high-performing educational establishment in the City. The government has committed to having a 16-19 maths school in every region, 11 in total. 5. By virtue of their high entry requirements, maths schools are small schools (with up to 250 places but usually 200 or less), this helps foster a close-knit and nurturing learning community. This is part of a range of initiatives to improve maths provision, including the Level 3 Mathematics Support Programme, and additional funding via the Advanced Maths Premium to support providers to increase A level maths participation; maths schools will also complement the work of Maths Hubs. Maths schools are characterised by high-quality long-term involvement from a university with a strong mathematics department – in this case Cambridge University. We expect the associated university to be committed to and accountable for the success of the school through a formal link with school governance and provision of, for example, curriculum and outreach support. 6. Two maths schools are currently established: King's Maths School and Exeter Maths School (opened in partnership with King’s College London and Exeter University respectively). Further maths schools in Cambridge, Durham, Imperial College London, Lancaster and Surrey are planned to open in two to three years, and Liverpool opened in September 2020. Ofsted found that the open maths schools (at King's and Exeter) both achieve high academic results, and provide an outstanding education, in 2017 inspections. In 2019 King’s Maths School was top in the country for A level attainment, ahead of every other school including independent schools. 100% of King’s students, and 93% of Exeter’s students, achieved an A or A* in A level mathematics. In 2019 King’s had an A level maths progress score of 1.28 and Exeter 1.45, meaning that pupils in these schools achieved on average a grade higher than similar students nationally; this places both schools in the top 1% of schools for A level maths progress. 7. All maths schools must offer A levels in Maths and Further Maths. There is some flexibility beyond this – there will be at least a third subject option which must include physics and be limited to STEM subjects. 8. The staffing model will be a matter for the school, in line with its pupil numbers and funding. Typically, a school (when full) will have a headteacher and assistant head, plus administrator, directors of faculty/subject leaders/subject teachers, teaching assistants, people with specialisms such as SEND & EAL, and typically graduate assistants/learning mentors. Schools will typically employ 15-20 FTE staff. 9. Maths schools are expected to draw pupils from a wide area, with pupils travelling for up to an hour/30 miles or even further. Therefore accessibility to transport links is important not just for the young people attending the school but also because maths schools are required to provide specialist outreach support to schools within their region, complementing the work of maths hubs. Teachers at the school will be travelling out to surrounding schools to do this. Also, pupils and their teachers at those schools will wish to be able to reach the maths school to access CPD and other opportunities. 10. As demonstrated by the open schools the highly specialist nature of the provision at maths schools, where every student has to undertake A Levels in maths and further maths, means we expect that it will only attract typically one or two pupils each from other schools and pupils will travel further than usual to access maths schools. 11. DfE welcomes reference within the plan to support the development of appropriate social and community infrastructure at section 6.3. DfE notes that the AAP includes site allocations pertaining to school delivery. 12. It is noted that paragraph 2.2 (3) ‘Strategic Objectives North East Cambridge’ will help meet the strategic needs of Cambridge and the sub-region. This wording is supported. 13. The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 94). 14. GCP should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on Planning for Schools Development1 (2011) which sets out the government’s commitment to support the development of state-funded schools and their delivery through the planning system. 15. Please note that there are two routes available for establishing a new school. Firstly, a local authority may seek proposals from new school proposers (academy trusts) to establish a free school, after which the Regional Schools Commissioner will select the successful trust. Under this ‘local authority presumption route’ the local authority is responsible for finding the site, providing the capital and managing the build process. Secondly, school proposers can apply directly to DfE during an application round or ‘wave’ to set up a free school, or (for maths schools) through submitting a business case. The local authority is less involved in this route but may support groups in pre-opening and/or provide a site. Either of these routes can be used to deliver schools on land that has been provided as a developer contribution. DfE has published further general information on opening free schools2 as well as specifically in relation to opening free schools in garden communities.3 (Question 5 and Policy comments added to specific questions) Site Suitability 27. The site is the most sustainably located of all of the sites appraised as part of the site search. This is due to its proximity to Cambridge North Station and busway interchange. Maths Schools are expected to have regional accessibility and therefore this is an optimum location for accessibility and sustainability. A full transport assessment will be undertaken and travel plan will be drawn up (having regard to the necessary policy requirements) to support the forthcoming planning application. 28. The proposed Maths School in land use terms is considered to be suitable for inclusion within a mixed-use residential/employment area. Indeed, the students who attend maths schools are high performing and studying a range of STEM subjects which are classroom based. The number of students is low and therefore it is unlikely that there will be any impact on amenity arising from the proposals. 29. The site has no heritage or ecological designations and is within Flood Zone 1. The layout and design will consider associated environmental constraints and propose mitigation measures where required. 30. The site may have former contamination issues which will be dealt with through detailed assessment provided at planning application stage. 31. The school is proposed to be built by Brookgate as part of the Cambridge North masterplan (location plan is appended) which would represent efficient land use and sustainable development, as well as enhancing mixed and balanced communities. 32. Therefore the allocation should include supportive wording which is sufficiently flexible for this use, as there are no alternative preferable sites. The development of a maths school at this site would assist in widening educational choice and attainment, and act as a high quality educational anchor for a mixeduse development within the AAP land in North East Cambridge. Policy wording should enable the delivery of specialist educational facilities in addition to schools meeting the needs of the wider demographic/population growth. This is required to ensure that the plan is compliant with the NPPF in widening choice. 33. The Learning Alliance trust has established links with Cambridge University and has also been in contact with the education authority at Cambridgeshire County Council, which has expressed support for the school (and a letter from CCC is appended setting this out in fuller detail). Conclusion 34. Finally, I hope the above comments are helpful in shaping the North East Cambridge AAP, with specific regard to the provision of land and a positive policy context for the proposed Cambridge Maths School. Please advise DfE of any proposed changes to the emerging policies, supporting text, site allocations and/or evidence base arising from these comments. 35. Please do not hesitate to contact me if you have any queries regarding this response. DfE looks forward to continuing to work with GCP to aid in the preparation of a sound AAP. Yours faithfully, Phoebe Juggins MRTPI Forward Planning Manager – South East

CCC Letter: My ref: HAB/Free Schools Your ref: Date: 17 July 2020 Contact: Hazel Belchamber Direct dial: E Mail: Mr Ryan Kelsall Principal Impington Village College New Road Impington Cambridge CB24 9LX Dear Ryan Cambridge Maths School It was good to have the opportunity to speak to you and Clare Hargreaves earlier this week on the progress with the Cambridge Maths School. As agreed, I am writing on behalf of the Education Directorate to confirm that: • The site on which the Maths School will be established seems an ideal location in that it: - is very close the new railway station and also the guided busway, offering easy access for both students and staff via public transport. Use of public transport will support students to further develop their independence. - offers connectivity not just into Cambridge but, importantly, a much wider area, helping to reinforce one of its key aims which is to extend opportunities to students from other parts of the county (as well as potentially from other Local Authorities) thus broadening participation and outreach. • Due to its specialism, the Maths School our assessment is that it is very unlikely to have a material adverse impact on any of the existing schools and colleges. It will not only complement, but enhance the range of educational provision available to students. You confirmed that the admissions criteria and process are still being refined, but the expectation is that you would start to promote the Maths School in early 2022, about 18 months before the school is due to open. My ref: HAB/Free Schools Your ref: Date: 17 July 2020 Contact: Hazel Belchamber Direct dial: E Mail: Mr Ryan Kelsall Principal Impington Village College New Road Impington Cambridge CB24 9LX People and Communities Executive Director: Wendi Ogle-Welbourn Box No: SH1210 Shire Hall Cambridge CB3 0AP I will be making contact with Councillor Simon Bywater, Chair of the Children and Young People’s Committee to provide him with a briefing on the project and seek his views on next steps with regard to sharing this information with other Council members. Kind regards Hazel Belchamber Assistant Director: Education Capital & Place Planning

Our Ref: DfE/Local Plan/NE Cambridge 7th March 2019 Dear Sir/Madam, Re: North East Cambridge Area Action Plan Consultation under Regulation 18 of Town and Country Planning (Local Planning) (England) Regulations 2012 Submission of the Department for Education 1. The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. 2. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and the DfE is the delivery body for many of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient schools, including sixth form places, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We do this through a variety of means, including by supporting the adoption of sound local plan policies, site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools. In this capacity, we would like to offer the following comments in response to the proposals outlined in the above consultation document. General Comments on the Area Action Plan Approach to New Schools 3. The DfE notes that significant growth and regeneration is being planned for North East Cambridge through joint development of this area action plan by Cambridge City Council and South Cambridgeshire District Council (referred to as the Councils below). While the number of homes has not yet been defined, a significant growth in housing stock is expected in the area which will place additional pressure on social infrastructure such as education facilities. The area action plan will therefore need to be ‘positively prepared’ to meet objectively assessed development needs and infrastructure requirements. 4. The DfE welcomes reference within the plan to support the development of appropriate community facilities (section 10) and we note that the councils are in ongoing discussions with service providers on what these needs are. 5. In light of the requirement for all Local Plans to be consistent with national policy, you will have no doubt taken account of key national policies relating to the provision of new school places, but it would be helpful if they were explicitly referenced or signposted within the document. In particular: - The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 94). - The DfE supports the principle of safeguarding land for the provision of new schools to meet government planning policy objectives as set out in paragraph 94 of the NPPF. When new schools are developed, local authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary. - The Councils should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on ‘Planning for Schools Development’1 (2011) which sets out the Government’s commitment to support the development of state-funded schools and their delivery through the planning system. 6. Given the above context and the Duty to Cooperate on strategic priorities such as community infrastructure (NPPF para 24-27)2, the DfE encourages close working with local authorities during all stages of planning policy development to help guide the development of new school infrastructure and to meet the predicted demand for primary and secondary school places. 7. In planning for schools, the DfE commends, for example, the approach taken by the London Borough of Ealing in producing a Planning for Schools Development Plan Document (DPD, 2016)3. We are not suggesting that the Councils produces a separate DPD as Ealing have done, but we do believe that the systematic approach they have taken is informative for local plans. The DPD provides policy direction, establishes the Council’s approach to providing primary and secondary school places and helps to identify sites which may be suitable for providing them (including, where necessary and justified, on Green Belt/MOL), whether by extension to existing schools or on new sites. It includes site allocations as well as policies to safeguard the sites and assist implementation and was adopted in May 2016 as part of the Local Plan. The DPD may provide useful guidance with respect to an evidence based approach to planning for new schools in the emerging AAP, securing site allocations for schools as well as providing example policies to aid delivery through Development Management policies. Site Allocations 8. Ensuring there is an adequate supply of sites for schools is essential and will ensure that the Cambridge City and South Cambridgeshire District Councils can swiftly and flexibly respond to the existing and future need for school places to meet the needs of the borough over the plan period. 9. At this early stage of the emerging Local Plan site allocations have not yet been drafted. The next version of the Local Plan should seek to identify specific sites (existing or new) which can deliver the school places needed to support growth, based on the latest evidence of identified need and demand in the updated Infrastructure Delivery Plan. The site allocations and/or associated safeguarding policies should also (1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment data/file/740441/ National Planning Policy Framework web accessible version.pdf 2 NPPF paragraph 24-27 specifies that this collaborative working should include infrastructure providers. 3 https://www.ealing.gov.uk/info/201164/local plans/1961/planning for schools dpd) seek to clarify requirements for the delivery of new schools, including when they should be delivered to support housing growth, the minimum site area required, any preferred site characteristics, and any requirements for safeguarding additional land for future expansion of schools where need and demand indicates this might be necessary. For an example of the latter, see draft policy CC7 in Milton Keynes’s Plan:MK Preferred Option draft from March 20174. 10. These site specific policy requirements need to be set out clearly, informed by robust evidence of infrastructure need, so that they can be accurately accounted for in the viability assessment of the local plan (to ensure that the total cumulative cost of all relevant policies will not undermine deliverability of the plan)5, and in the price paid for land by developers and other parties. 11. While it is important to provide clarity and certainty to developers, retaining a degree of flexibility about site specific requirements for schools is also necessary given that the need for school places can vary over time due to the many variables affecting it. The DfE therefore recommend the Council consider highlighting in the next version of the Local Plan that: - specific requirements for developer contributions to enlargements to existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that - requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use. 12. The DfE currently has one live central wave pipeline free school project for which a site has been identified in the AAP area: Cambridge Mathematics School, a mainstream sixth form with a specialism in Maths (200 pupils at full capacity). We have identified a site in the south east corner of the AAP area, located immediately west of the new Cambridge North station on vacant land that was formerly railway sidings. The site is central within an area proposed for residential, commercial and business uses. 13. The DfE believe that a D1 use, of the type and specialism proposed here, would be complementary to the high tech science park to the west, as well as the university and would fit in well as a community use within the proposed residential-led mixed use development of the wider site. A school with a Maths specialism will attract pupils from an area wider than the immediate city and district, therefore this location close to the new railway station is considered a highly suitable and sustainable site for this particular school. It will contribute to widening choice in the local education offer, as supported by the NPPF (see paragraph 5 above). To provide certainty around delivery of the school, we request that a site which can be brought forward early, be considered for formal allocation for D1 use to accommodate the proposed school in the next iteration of the AAP. We would be happy to provide further information about the school if required. Forward Funding 14. In light of proposals for significant mixed use development proposed for NE Cambridge, emerging DfE proposals for forward funding schools as part of large residential developments may be relevant, for example if viability becomes an issue. The DfE aims to be able to clarify forward funding options for schools shortly, following recent (4 https://www.milton-keynes.gov.uk/planning-and-building/planning-policy/plan-mk 5 PPG on Viability: https://www.gov.uk/guidance/viability#viability-and-plan-making) approval from Treasury. We would be happy to meet to discuss this opportunity further once details of the plans for the area, including requirements for new schools, have been progressed. Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed. Developer Contributions and CIL 15. One of the tests of soundness is that a Local Plan is 'effective· i.e. the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments. The DfE notes that neither Cambridge City Council or South Cambridgeshire District Council currently have adopted a Community Infrastructure Levy; rather the Councils intend, through the AAP, to put in place a Section 106 reg ime specific to the area "to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements" (para 12.4 ). The DfE broadly support this approach to ensuring developer contributions address the impacts arising from growth. 16. The council should set out education infrastructure requirements for the plan period within an Infrastructure Funding Statement6 . Where additional need for school places will be generated by housing growth, the statement should identify the anticipated section 106 funding towards this infrastructure. The statement should be reviewed annually to update the schedule and phasing of infrastructure requirements and report on the amount of funding received via developer contributions and how it has been used, providing transparency to all stakeholders. 17. The DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements, which will inform any emerging CIL and/or amendments to the Regulation 123 list. As such, please add the DfE to the database for future CIL consultations. Conclusion 18. Finally, I hope the above comments are helpful in shaping the NE Cambridge Area Action Plan, with specific regard to the provision of land for schools. 19. Please do not hesitate to contact me if you have any queries regarding this response. The DfE looks forward to continuing to work with Cambridge City Council and South Cambridgeshire District Council to aid in the preparation of a sound Area Action Plan. Yours faithfully, Douglas McNab MRTPI Forward Planning Manager Tel: Email: Web: www.gov.uk/dfe (6PPG on Plan-Making: https://www.gov.uk/guidance/plan-making#maintaining-effective-cooperation)

Dear Sirs, FDPC Consultation Response to NECAAP Consultation 2020 Thank you for the opportunity to submit today our response to the above consultation. In summary, Fen Ditton Parish Council (FDPC) strongly OBJECTS to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. Our principal concerns are: • The visual intrusion as seen from Ditton Meadows, Fen Ditton Conservation Area and other locations due to the proposed building heights and massing; • increased congestion and traffic in Fen Ditton; • major incursion into the Green Belt to relocate the sewage works; • provisions for biodiversity and green space; • a major addition to the population of Cambridge with attendant infrastructure needs; • timing of this consultation and the lack of relevant, up to date evidence to justify the proposals; and • missed opportunities to avoid degrading the environment of Cambridge and its surrounding villages and countryside. The above points are discussed in full in Appendix I. These objections are additional to those submitted in the letter to you dated 4th October from Parish Councils adjacent to the NECAAP area and others in South Cambridgeshire District. We would welcome the opportunity to receive a response to the points we raise and look forward to hearing from you. Yours faithfully, Vince Farrar Chairman (Appendix 1- see submission attachment) c/c

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Dear Sirs, Parish Councils' Joint Response to NECAAP Consultation 2020 We, the undersigned wish to record that we strongly object to the North East Cambridge Area Action Plan proposals as put forward in the current consultation. The plan includes a major incursion into the Green Belt to relocate the sewage works and a major addition to the population with attendant infrastructure needs. The consequences are likely to be increased congestion. continued or exacerbated inequality (Cambridge having one of the worst records in UK cities) and unavoidable degradation of the environment of north-east Cambridge. The proposed increase in jobs and homes will not decrease the pressure on housing in Cambridge but appears to be intended, at best, to merely keep pace with the increase in jobs. The proposal appears to add around 15-20.000 people, ie. 12 to 17 % of Cambridge's total population. into a development area of less than 5% of the city. Due to the provision of commercial space, it appears that very high densities are planned. The resulting building heights are incompatible with the historic city of Cambridge and the fenland landscape. We support the idea of building heights of 4 to 6 storeys generally. The case for a few taller buildings to break up the massing effect should be examined. The increase in commercial space and consequent jobs reflects a desire, translated into a commitment, made by local government in earlier years. This is presented as not being open to challenge under NECAAP, implying that national and local government would have to agree a different set of targets possibly in relation to the next local development plan (LDP). The events of 2020 are affecting economic growth. working practices and living arrangements. Lower economic growth will reduce the minimum housing provision in the LOP as required by Government. Increased working from home will reduce the requirement for office space and daily commuting but may result in a desire for more space in homes. to avoid living in dense urban areas or to live further away. The Government is proposing to allow change of use for redundant commercial buildings and other measures to rapidly increase residential space. This will affect NECAAP. The proposed relocation of the sewage works should be re-examined. We draw attention to Anglian Water's proposed buffer zones for residential and commercial premises. There are offices closer than 150 m to the existing works. Thames Water's Deephams works has residences much closer than 400 m and the recent upgrade (approved by the then Mayor of London, Boris Johnson) has led to ·' .. achieving a 99% reduction in odour emissions". The biggest step towards achieving a more sustainable development would be to scale back NECAAP and use more of the existing infrastructure especially the sewage works. The case for a district heating/cooling system including the sewage works (as at Deephams) should be examined. The energy plan proposed for NECAAP does include solar panels for power generation but these conflict with spaces also being developed as Green Roofs. The sustainability assessment should include a discussion of organic population growth and inward migration. The NECAAP proposal has several optimistic assertions that are not backed up by evidence, especially from the Cambridge sub-region. These include: residents will choose to work near their dwellings; that personal car use and ownership will diminish due to rationing of provision instead of ‘predict and provide’; that biodiversity will increase and that adequate green space will be provided. The 2017 and 2018 pattern of commuting to work in the NECAAP area shows little use of public transport. Although awards have been given to Accordia, Great Kneighton, Eddington and the Central Mosque, there is no discussion of travel to work patterns, car ownership or out-commuting to other places including London. The higher rise building and density of CB1 and the area east of the railway station may be more comparable to NECAAP but the proposals are silent as to if this is considered a success or even if it could be improved on. If the problem is lack of an evidence base, the 2021 census should provide a much clearer picture of living, working and travelling patterns. Comparisons should be made with successful and unsuccessful developments elsewhere in the UK or Europe. We object to the premise that biodiversity will increase if areas of suitable habitat are included. Actual baseline surveys of biodiversity are needed throughout the NECAAP area and Chesterton Fen if that is going to be acquired to meet the targeted increase. The institutional Framework for NECAAP should be examined. We consider that Milton PC and the future residents are the main stakeholders of the SCDC portion of the site and should be consulted accordingly. In conclusion, despite the current momentum and previous investment, we urge you to reconsider NECAAP and the use the extra time to evaluate the impact of events of 2020 and reconsider the improvements that could be achieved by scaling back the ambition. This will allow lower building heights, densities of dwellings and the often voiced desire to see a modernised sewage works on the existing site. In addition, we urge you to negotiate with the Government about targets for housing and employment growth especially if the quantum of the HIF grant can be scaled back to allow investment elsewhere in the UK. Yours Faithfully Parish Council Chairs: Histon/Impington, Milton, Landbeach, Waterbeach, Horningsea, Fen Ditton, Teversham

Broadly Support: Introduction These repre entations relate to the site currently occupied by Building 140 on the Cambridge Science Park (‘CSP’). A Site Plan, showing the boundaries outlined in red, accompanies this submission (Annex 1) (‘the Site’). South Cambridgeshire District Council (‘the Landowner’) own the freehold of the building on the Site. Building 140 is 2-storeys in height, built in the 1980s, and modernised/refurbished in the 2010s. the building is currently leased, with the earliest opportunity for vacant possession in 2030 (unless the current tenant exercised their break clause in 2025). The plan period for the North East Cambridge Area Action Plan (NEC AAP), is expected to cover the next 20 years, and it is likely that the Landowner will wish to consider redevelopment of Building 140 at the start of the second half of that plan period (or sooner if the tenant opts to leave). The purpose of these representations is therefore to seek suitable development parameters for future redevelopment, particularly in terms of scale/height, density, and parking, in order to provide developer confidence for any future planning application process. CSP is currently going through a process of regenerative change. An application (20/03444/FUL) is currently under consideration on an adjacent single storey building (127 – 136 CSP) for the provision of a new 5/6-storey of 6,279m2 GIA. The Landowner broadly supports the vision, spatial framework (Annex 2) and strategic policies of the NEC AAP, but seeks the following clarifications from the Greater Cambridge Shared Planning Services (‘GCSP’) team / changes to draft Policy:

To: Greater Cambridge Shared Planning Response to North East Cambridge (NEC) Area Action Plan (AAP) I strongly object to the NEC AAP in its current form. I have answered your ‘Ten Big Questions’ (see below), along with further comments and questions under the following headings: 1. impact of relocation of sewage works; 2. council planning in the wider context; 3. the conduct of the NEC AAP consultation; 4. the extent of legal requirements placed on developers; 5. the manner in which Government funding and NSIP status have been secured and the adequacy of funding for the new sewage works, and 6. ‘Ten Big Questions’ 1. Impact of relocation of sewage works My village is under threat from both Sites 1 and 2 as proposed by Anglian Water (AW). All the things you seek to achieve through the NEC AAP will be destroyed in whichever villages are chosen as the new location for the sewage works. See ‘Ten Big Questions’ for further details. 2. Council planning in the wider context There is a danger that the AAP is setting in train a series of disastrous planning decisions which could hamper future economic and infrastructure development on the strategically important land at Site 2. This has enormous potential to benefit Greater Cambridge and is too valuable to waste on a sewage works. There is access under the A14 to enable expansion of the Science Park plus proximity to the guided bus and proposed CAM route as well as the Mere Way cycle route. Indeed, the ‘unlocking’ of NEC could result in the ‘locking’ of this key site. In a wider planning context, NEC and the associated sewage works relocation seem to be advancing stand-alone from all the other projects in the pipeline (Airport site, Marleigh, Waterbeach New Town, A10 widening, CAM metro, Mere Way cycle route, Science Park expansion, recycling centre expansion, new Police Station). There is a risk that building a sewage works to a constrained budget will prevent further key developments and that it will need moving again. As taxpayers we urgently need to see a coherent planning approach being taken to have confidence that our money is being invested wisely. It seems bizarre that the impact of moving the sewage works is being given no consideration at all by Greater Cambridge Planning despite it being a highly significant impact of the AAP. 3. The conduct of the NEC AAP consultation Despite the sewage works relocation being a major impact the AAP does not quantify the enormous cost to the taxpayer or make any mention of the associated colossal carbon costs, destruction of Green Belt, wildlife, amenity and heritage or the impairment of lives and properties in villages. The City Council has driven the relocation project and the County Council sets waste policy ie the inadequate 400m ‘buffer zone’ for sewage works. Neither organisation has put forward leaders for scrutiny by residents in relation to the relocation. For such an important project affecting so many people this appears to show an utter lack of respect for and accountability to the communities that these organisations are supposed to serve. We seem to have arrived at this position via an opaque and undemocratic process involving multiple layers of local government, which has been invisible for most residents and it appears we have no local redress (see also 5. below for comments on 2019 consultation). An effective consultation cannot be achieved on Zoom during a pandemic and anyone without IT is almost completely disenfranchised. I was told by a Greater Cambridge planning officer that residents are muted at webinars in case they say anything offensive. Thus there is no opportunity for follow up questions eg: o Q (recording of first webinar): How can the development be stopped? (clearly a genuine question from someone concerned about the sewage works). o A: I’m not sure you would want to …….. (the question was thus deemed answered, with no right of reply from muted resident). This all gives the impression of a council determined to impose its ill-considered plans irrespective of residents’ views and common sense. 4. The extent of legal requirements placed on developers To what extent are the aims of the NEC AAP enshrined in legal requirements placed on developers? NEC seems doomed to be yet another development where the affordable housing, community facilities, energy and water savings etc never materialise. 5. The manner in which Government funding and NSIP status have been secured and the adequacy of funding for the new sewage works A condition of the Housing Infrastructure Fund (HIF) is that the project has local support. It appears that HIF funding was obtained on the back of the 2019 consultation on NEC AAP. At that point the move was hypothetical only, with no indication of possible sites for relocation or consideration of issues and impacts. At best, the villages which are now under threat were treated as peripheral to the consultation with no exhibitions, community liaison forum or local ward member forum. Surely the 2019 consultation cannot be considered as indicative of support and a valid basis for HIF funding when stakeholders were totally in the dark on proposed sites and the relocation was outside the scope of the consultation? Comments on the AW e-consultation indicate that there is strong support to leave the sewage works where it is, a contaminated brownfield site. I question whether the funding is sufficient to secure both the best site and best technology for a new sewage works and whether the shortlisted sites have been chosen based on cost. Nationally Significant Infrastructure Project (NSIP) criteria apply to sewage works of 500,000 population equivalent. The Odournet report in your own library of evidence-based documents cites ‘the works serves a population equivalent of approximately 165,000 ….’. There is no evidence provided as to why we need such a large sewage works. 6. ‘Ten Big Questions’ 1. What do you think about our vision for North East Cambridge? I strongly object to your vision for NEC in its current form because of the associated relocation of the sewage works to Sites 1 and 2 and the seeming lack of coherent vision for the wider area. This risks a planning disaster for Greater Cambridge with the particular danger of ‘locking’ strategically important land at Site 2. The NEC vision seems unrealistic; too much is being squeezed into too little space. I question the chances of everything promised in the AAP being delivered. The definition of ‘affordable’ is not clear. Examining some of the key aims of the AAP, the vision for NEC will have the following direct effects on the villages: ‘Healthy and safe’; Residents, businesses, schools, nurseries and a hospital will face multiple health and safety risks; contaminated bioaerosols, nausea and detriment to wellbeing from living with the stench of sewage and sludge processing, commissioning and decommissioning work. Flies, mosquitoes and rats. Noise, dust and vibration from construction work. Plus daily HGV traffic, including sludge transport, causing pollution and endangering school routes on overloaded, narrow and twisting roads. Sites 1 and 2 would result in the closure of a long established fruit farm and a recreational facility at Rectory Farm. ‘Green spaces’ and ‘Cultural Placemaking’; Your evidence-based document describes the area between Impington and Milton thus: ‘….. not recognised in published landscape character assessments and townscape assessments as making an important contribution to the setting of Cambridge. It contains few notable landscape or cultural heritage designations with very few public rights of way and no recreational routes of regional or national importance.’ This area actually contains the Mere Way, used by walkers, joggers and cyclists for health and recreation. Mere Way is also a heritage asset, a Roman Road, as well as an incredible wildlife corridor with pleasant views across to mature trees. ‘Biodiversity’; Our village conservation area is rich in wildlife which will suffer (little owls, tawny owls, barn owls, turtle doves, swifts, bats, common toads, hedgehogs, deer, foxes, badgers). ‘A real sense of place’; Whichever villages are forced to accept the sewage works will have a new ‘sense of place’, where quality of life and property values are diminished. 2. Are we creating the right walking and cycling connections to the surrounding areas? No. If the sewage works are relocated at Site 1 or 2 then Mere Way will be severed or rendered an unappealing route. Mere Way is supposed to be the cycle route from Waterbeach New Town, as well as existing villages. 3. Are the new centres in the right place and do they include the right mix of activity? No. Waste water treatment is a key activity. The best place for the sewage works is in its existing location. Under the proximity principle the City should deal with its own waste and not dump it on the villages. Otherwise a location well away from residential areas and strategic sites should be found. 4. Do we have the right balance between new jobs and new homes? 8000 homes equates to roughly 10,500 people in employment. Creating 20,000 new jobs will lead to a housing shortfall of 9,500. Covid-19 is changing the employment landscape, perhaps permanently. Surely the provision of commercial space should be re-evaluated in this light. Orchard Park never got its commercial space which was also supposed to act as noise attenutation. What legal guarantees are in place to ensure that the development is delivered to plan? 5. Are we planning for the right community facilities? What legal guarantees are in place to ensure delivery of the facilities you promise? 6. Do you think our approach to distributing building heights and densities is appropriate for the location? It is hard to see how the vision for NEC building heights fits in with the stated vision for Cambridge of a city surrounded by green space with a ‘necklace’ of villages. Aesthetically, looming tower blocks of 13 stories are completely out of character for Cambridge and could make the district square gloomy and dark. It has been calculated that the population density will be more than twice that of Inner London. This does not sit with claims that it will be a healthy and safe place to live. Living on a decommissioned sewage works seems a highly unattractive prospect. There is nothing in your evidence-based document library to show that this is safe practice. 7. Are we planning for the right mix of public open spaces? The AAP ‘borrows’ Milton Country Park and Chesterton Fen, both of which lie outside NEC. The Country Park is already very well used and there is no information as to how the capacity could be increased. Otherwise NEC itself seems deficient in Green spaces which would make Mere Way cycle path even more important to allow people to access open countryside. What legal requirements will be placed on developers to ensure that these facilities materialise? Will the public spaces be well maintained and safe? 8. Are we doing enough to improve biodiversity in and around North East Cambridge? According to your ecological summary there is very little habitat in NEC (a drain and one hedgerow). Improving it should not be difficult but it comes at the expense of the destruction of Green Belt which will be concreted over to build the new sewage works. NEC is effectively being built on Green Belt. This is not mentioned in the AAP. 9. Are we doing enough to discourage car travel into this area? It is not enough simply to discourage car travel. Transport infrastructure is needed. Provision should be made for the needs of those who are not able to walk or cycle. Mere Way is intended as a major cycle route between Waterbeach New Town and the city. Putting the sewage works on Sites 1 or 2 will either sever it or greatly reduce its value. Site 2 could also affect the CAM. 10. Are we maximising the role the development at North East Cambridge has to play in responding to the climate crisis? Definitely not. There should be more transparency about the true carbon cost of NEC by including the environmental cost of relocating the sewage works. There need to be absolute guarantees that developers will play their part in reducing carbon emissions. Surely NEC buildings will have the highest carbon footprint in the land after factoring in the colossal carbon cost of moving the sewage works, building all the extra pipes and tunnels and decommissioning work. The associated sewage works relocation to Sites 1 and 2 also risks reducing options for cycle and public transport infrastructure. We all want the NEC development to benefit everyone in Cambridge but if it can only be achieved by moving a large sewage works into the middle of thriving and developing communities this is far from desirable or equitable, and a wider planning disaster could result. Mrs Diane Plowman

02 October 2020 Dear Sir/ Madam Regulation 18 Consultation - Draft North East Cambridge Area Action Plan The East West Railway Company (‘EWR Co’) would like to take this opportunity to submit representations on the above consultation. The representations are submitted via email in the form of this letter and include comments on specific sections of the Area Action Plan, relevant to the East West Rail (‘EWR’) project. As you are aware, on 30 January 2020 EWR Co announced the preferred route option between Bedford and Cambridge1. This preferred option will link existing stations in Bedford and Cambridge with communities in Cambourne and the area north of Sandy, south of St Neots (see Figure 1).(see Form attachment) The preferred route option arrives into Cambridge Station from the south where a change of train will allow customers to connect with Cambridge North Station (see Figure 2). Through this consultation, we are keen to engage with the combined authority to explore ways in which the delivery of the railway could maximise opportunities within the North East Cambridge Area. (See Form Attachment) Figure 2: Extract of proposed EWR Central Section route (detailed map) (Image from https://eastwestrail.co.uk/the-project/central-section) We welcome the acknowledgement of the East West Rail project in Section 2. We strongly agree that the North East Cambridge Area Action Plan will play an important role in bringing forward thousands of new homes and jobs along these nationally important corridors (p.26). The sections of the Draft Area Action Plan we would like to comment on and make recommendations are as follows: 4) Climate Change, water and biodiversity We are pleased that Section 4: Climate change, water and biodiversity states that the North East Cambridge Area Action Plan has been fundamentally shaped by the requirement for it to be a low-carbon, low-impact, biodiverse exemplar (p.47). Furthermore, we welcome the statements in Section 7: Connectivity that development at North East Cambridge will shift travel away from the private car, at a level not seen in Greater Cambridge before. To achieve this the Area Action Plan encourages the use of sustainable travel modes, as well as limiting car use and parking significantly (p.181). Travelling by train is one of the most carbon-efficient ways to travel; EWR will allow local people to leave the car at home, helping to reduce road congestion, in favour of a more sustainable form of transport across the region. We also know how important it is that the railway is constructed, operated and maintained in an environmentally responsible way that minimises negative environmental impacts and in fact realises opportunities for improvement. We aim to become a net-zero carbon railway and are committed to achieving biodiversity net gain. We are looking at ways to advance low carbon design and green energy to power our trains. Recommendation As an organisation we are continuously thinking how the delivery of EWR can help unlock opportunities to increase active travel modes, as well as other connecting modes of public transport, as credible alternatives to private car. EWR Co would therefore welcome the opportunity to work with the combined authority to identify joined up ways to improve active travel (including both cycling and pedestrian routes) around North East Cambridge and into both Cambridge North Station and Cambridge Station, to facilitate better access into the EWR network. 6) Jobs, homes and services EWR will influence the development of the places it serves in terms of economic growth, investment and jobs and supporting the delivery of new homes by potentially unlocking land for development and providing more sustainable transport connections. We therefore concur that North East Cambridge is a strategically important economic driver for Greater Cambridge and further afield and there is a huge demand for more business space and homes as a result (p.134). Recommendation The combined authority should set aspirational targets for housing and employment growth within North East Cambridge to take advantage of the more sustainable transport connections presented by EWR and to meet the aspirations of the UK government for growth across the Oxford-Cambridge Arc. This aligns with Draft Policy 13a: Housing which makes provision for at least 8,000 net dwellings and Draft Policy 12a: Business which plans for a range of spaces supporting jobs across all forms of business and industry which could provide up to 20,000 new jobs in the area. This concludes our representations on the Draft North East Cambridge Area Action Plan. Please do not hesitate to contact me should you require clarifications or any further information. Yours sincerely, Kirsty Young Head of Programme Consents East West Railway Company

Broadly Support: Introduction These representations relate to the site currently occupied by Buildings 270 and 296 on the Cambridge Science Park (‘CSP’). A Site Plan, showing the boundaries outlined in red, accompanies this submission (Annex 1) (‘the Site’). South Cambridgeshire District Council (‘the Landowner’) own the freeholds of the two buildings on the Site. Building 270 is 2/3-storeys in height, built in the 1980s, and currently vacant, having been formerly occupied by WorldPay, who have since moved into a new office building on an adjoining site. It is envisaged that Building 270 will be refurbished and then offered for let on a short/medium term basis in 2021. Building 296 is 2-storeys in height, built in the early 00’s, and is currently occupied, with the earliest opportunity for vacant possession in 2027. Building 270, in addition to the Johnson Matthey building to the east, formed part of a hybrid planning application (S/0630/15/FL) that was approved in March 2016 for the provision of a new 4-storey building and a new decked car park (detailed consent), both of which have been built, and occupied by WorldPay – and two new replacement buildings (for Building 270 and the Johnson Matthey building) of four-storeys each (outline consent). Planning permission was given for 17,219m2 GIA across the three buildings, 497no. car parking spaces, and 602no. cycle spaces. The plan period for the North East Cambridge Area Action Plan (NEC AAP), is expected to cover the next 20 years, and it is likely that the Landowner will wish to consider redevelopment of Buildings 270 and 296 during the first half of that plan period. The purpose of these representations is therefore to seek suitable development parameters for future redevelopment, particularly in terms of scale/height, density, and parking, in order to provide developer confidence for any future planning application process. The planning consent provides a baseline that indicates 4-storey redevelopment is acceptable in this location, but given the wider strategic aims of the NEC AAP particularly in seeking to reduce the significant levels of existing car parking, optimising development opportunities for economic and social benefits, and maximising connectivity across the AAP area, it is considered that the Site might offer the opportunity for increasing the quantum of floorspace further. The Landowner broadly supports the vision, spatial framework (Annex 2) and strategic policies of the NEC AAP, but seeks the following clarifications from the Greater Cambridge Shared Planning Services (‘GCSP’) team / changes to draft Policy:

Broadly Support: Introduction These representations relate to the site currently occupied by The Vitrum Building (‘Vitrum’) on St John’s Innovation Park (‘SJIP’). A Site Plan, showing the boundaries outlined in red, accompanies this submission (Annex 1) (‘the Site’). South Cambridgeshire District Council (‘the Landowner’) own the freehold of the building on the Site. Vitrum is 3-storeys in height, of approximately 3,200m2 (GIA), built in the 2000s. The building is currently leased, with the earliest opportunity for vacant possession in 2024. The plan period for the North East Cambridge Area Action Plan (NEC AAP), is expected to cover the next 20 years, and it is likely that the Landowner will wish to consider redevelopment of Vitrum during the first half of that plan period. The purpose of these representations is therefore to seek suitable development parameters for future redevelopment, particularly in terms of scale/height, density, and parking, in order to provide developer confidence for any future planning application process. The Landowner broadly supports the vision, spatial framework (Annex 2) and strategic policies of the NEC AAP, but seeks the following clarifications from the Greater Cambridge Shared Planning Services (‘GCSP’) team / changes to draft Policy: