North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33759

Received: 25/03/2019

Respondent: Brookgate

Agent: Bidwells

Representation Summary:

Not necessary

Full text:

1.0 Introduction

1.1 These representations are made on behalf of Brookgate Land Limited and in response to the
North East Cambridge Area Action Plan (AAP) Issues and Options 2019 consultation. These
representations follow those previously submitted in respect of the 2014 Issues and Options

1.2 Brookgate Land Ltd is the development partner of Network Rail and D B Schenker (and through
them Freightliner and Lafarge Tarmac) who own 21.18 hectares of land formerly known as the
Chesterton Sidings and who collectively form the Chesterton Partnership.

1.3 Brookgate Land Limited has been working as promoter for The Chesterton Partnership in order to
secure the rationalisation and redevelopment of the former Chesterton Sidings site. Planning
permission has been granted for a 217 bed hotel (under planning application reference
S/2372/17/FL) and a 90,000 sq ft office (under planning application reference S/4478/17/FL),
referred to as the Phase 1a site. Construction is soon to begin on these two important
permissions which will serve to bring life to the Cambridge North station area and act as a
catalyst for the development of the wider North East Cambridge AAP.

1.4 Brookgate Land Limited are now seeking to bring forward the next phase of development ('Phase
1b') alongside the AAP process which will further build on the momentum created by the Station
development and the hotel and office permissions. A location plan indicating the Phase 1b site is
included at Appendix 1.

1.5 Phase 1b will comprise a residential-led mixed use development providing 1000 PRS homes, a
new specialist maths college and another office building. The intention is to submit a planning
application by the end of 2019. The land interest is wider than Phase 1b and that is included at
Appendix 2.

1.6 Brookgate Land Limited are supportive of the overall vision for the APP but wish to make the
following responses to the relevant questions in the Issues and Options consultation document.

2.0 The North East Cambridge Area Today

2.1 Question 4 - Have we identified all relevant constraints present on, or affecting, the North
East Cambridge area?

2.2 Brookgate Land Limited consider that paragraph 4.16 (Odour) requires further clarification and

2.3 To support the hotel and office applications, Brookgate Land Limited commissioned Arup to
prepare an Odour Assessment Report to assess the odour from the Cambridge Water Recycling
Centre. The Report has been shared with the Councils and is publicly available.

2.4 The Arup 2015 report confirms that the entire Phase 1b site is suitable for residential use. This
was based on Anglian Water's own monitoring data and included an allowance for higher
temperatures in the Summer months to ensure a robust approach.

2.5 The 1.5 ouE/m3 contour line from the Arup report (i.e. whereby residential uses are no longer
likely to be suitable) is shown by a dotted blue line below [attached].

2.6 Since the preparation of the above Arup 2015 Odour Assessment, the Councils have
commissioned their own independent Odour Impact Assessment, as referred to in paragraph
4.16 of the NEC AAP document. This Assessment involved an odour measurement survey which
was conducted at the Water Recycling Centre (WRC) in summer 2017 and the report is dated
October 2018. Despite several requests to be provided with copies of the Assessment by
Brookgate Land Limited as part of on-going discussions regarding the development potential of
the Phase 1b site, the report was only made publicly available on 13 March 2019 when it was
released as part of papers for the 20 March 2019 Joint Development Control Committee meeting.

2.7 The Odour Impact Assessment is due to also be reported to the City Planning Committee on 3
April 2019 and the South Cambridgeshire District Planning Committee on 10 April 2019. The
Odour Impact Assessment is therefore being reported through the committee cycle but is not
being subject to consultation, despite it being recognised as a key technical evidence base
document relevant to the NEC AAP area.

2.8 Brookgate Land Limited therefore object to the lack of opportunity for consultation on the findings
of the Councils Odour Impact Assessment.

3.0 Vision and Strategic Objectives


Question 5 - Do you agree with the proposed vision for the future of the north east
Cambridge area? If not, what might you change?

3.1 Brookgate Land Ltd supports the proposed vision. The AAP area is the largest brownfield site in
Cambridge and is extremely well served by existing public transport. It therefore has the potential
to transform into a high-quality gateway to the city and act as a catalyst for the regeneration of
the wider area.

3.2 The Cambridge and Peterborough Independent Economic Review (CPIER) was published in
September 2018. One of the key recommendations from the review, at 2.3, is to consider some
densification, particularly in Cambridge, away from the historic centre, and more on the edges, as
and where new development sites comes forward. The CPIER report specifically states that the
east side of Cambridge offers significant scope for housing and commercial development:
"Such development would have the advantage of being close to the principal centres of
employment and the existing rail infrastructure whilst also opening up opportunities for
new transport links to connect the main centres of employment more effectively. Most
significantly, it includes land which has previously been safeguarded for development
and is within the boundaries of the existing urban area so would proving opportunities in
line with the existing spatial strategy.


3.3 Question 6 - Do you agree with the overarching objectives? If not, what might you

3.4 Brookgate Land Limited broadly support the proposed overarching objectives.

3.5 Brookgate Land Ltd support proposals to improve pedestrian and cycle links to the surrounding
area, existing residential areas, employment areas, River Cam and Milton Country Park, and to
improve connectively across the Milton Road corridor.

3.6 However Objective 18 should be bolder given that the NEC AAP is the largest brownfield site in
the city and is served by excellent public transport infrastructure. Objective 18 should therefore
require proposals to make optimal and efficient use of the potential of the site given the highly
sustainable nature of the NEC AAP area.

4.0 Place Making

North East Cambridge Indicative Concept Plan

4.1 Question 7 - Do you support the overall approach shown in the Indicative Concept Plan?
Do you have any comments or suggestions to make?

4.2 Brookgate Land Limited support the Indicative Concept Plan, particularly in terms of the
opportunity for residential-led mixed use development on land they control. The AAP should
however be clear that the Indicative Concept Plan only refers to a broad arrangement of uses
across the AAP site and is not prescriptive. The Local Authority therefore needs to take a flexible
approach to ensure the AAP can adapt to change.

Creating a Mixed-Use City District

4.3 Question 8 - Do you agree that outside of the existing business areas, the eastern part of
the Cambridge Northern Fringe (i.e. the area east of Milton Road) should provide a higher
density mixed use residential led area with intensified employment, relocation of existing
industrial uses and other supporting uses?

4.4 Brookgate Land Limited support the proposal for a higher density mixed use residential led area
on land east of Milton Road. This would facilitate a large number of dwellings to be
accommodated near the station, increased Offices/RD provision with associated increase in job
creation. This represents efficient use of land in a highly sustainable location and creates the
opportunity for people to live close to where they work.

4.5 A higher density of people also helps to form a critical mass and sense of place to support the
range of ancillary retail uses, services and facilities that would come forward alongside the
residential and employment accommodation.

District Identity

4.6 Question 12 - What uses, or activities should be included within the NEC which will create
a district of culture, creativity and interest that will help create a successful community
where people will choose to live and work and play?

4.7 The AAP should allow for flexibility for a wide range of supporting uses to come forward. The
uses should include those typically understood as necessary for a fully functioning city or district
within a city.

Creating a healthy community

4.8 Question 13 - Should the AAP require developments in the NEC to apply Healthy Towns

4.9 Planning policies should aim to achieve healthy, inclusive and safe places. The need to
encourage healthy lifestyles and the use of sustainable transport modes will therefore be key in
any development proposals within the NEC.

4.10 Overarching principles relating to health and wellbeing are therefore welcomed but the AAP
needs to remain flexible in terms of any specific policy requirements in order to be able to
respond to change.

Building Heights and Skyline

4.11 Question 15 - Should clusters of taller buildings around areas of high accessibility
including district and local centres and transport stops form part of the design-led
approach to this new city district?

4.12 Brookgate Land Limited support the proposal for clusters of taller buildings around areas of high
accessibility. This permits a development of higher densities and the articulation of nodal points,
vistas and landmark buildings to aid legibility and orientation.

4.13 NEC is bounded by the railway line on the east, the A14 to the north, the Cambridge Science
Park to the west and the suburban Chesterton to the south. The City Centre is some 3.5km from
the site. This physical context presents an opportunity to investigate heights and densities which
might not be supported in other locations in Cambridge: taller buildings would have no impact on
any existing residential properties with regard to sunlight and daylight but could a) release
significant development pressure from the historic core of the City, b) create an opportunity to
define the NE corner of the City with striking buildings visible from the A14, and c) support the
additional uses and amenities that will make this a self-supporting district.

Local movement and connectivity

4.14 Question 16 - Should the AAP include any or a combination of the options below to
improve pedestrian and cycling connectivity through the site and to the surrounding

A A strong east-west axis to unite Cambridge North Station with Cambridge Science
Park across Milton Road. This pedestrian and cycle corridor would be integrated
into the wider green infrastructure network to create a pleasant and enjoyable
route for people to travel through and around the site. The route could also allow
other sustainable forms of transport to connect across Milton Road.

B Improve north-south movement between the Cowley Road part of the site and
Nuffield Road. Through the redevelopment of the Nuffield Road area of the NEC, it
will be important that new and existing residents have convenient and safe
pedestrian and cycle access to the services and facilities that will be provided as
part of the wider CNF proposals.

C Upgrade connections to Milton Country Park by both foot and cycle. This would
include improving access to the Jane Coston Bridge over the A14, the Waterbeach
Greenway project including a new access under the A14 (see Transport Chapter),
as well as the existing underpass along the river towpath.

D Provide another Cambridge Guided Bus stop to serve a new District Centre
located to the east side of Milton Road.

E Increasing ease of movement across the sites by opening up opportunities to walk
and cycle through areas where this is currently difficult, for example Cambridge
business park and the Cambridge Science Park.

4.15 Brookgate Land Limited are supportive of the above. The emphasis of the movement principles
must be the promotion of non-car and active modes of travel and delivering a highly connected,
and accessible development by walking, cycling and public transport.

4.16 Some form of District Centre also needs to be provided within walking distance of Cambridge
North station to serve commuters.

Crossing the railway line

4.17 Question 17 - Should we explore delivery of a cycling and pedestrian bridge over the
railway line to link into the River Cam towpath?

4.18 Yes, additional connectivity would be a positive improvement although there is already a
pedestrian and cycle route to the River Cam Tow Path from the south of the NEC via Moss Bank
and Fen Road, Furthermore, it should be noted that Network Rail would not likely support a
crossing point on land they control.

Milton Road connectivity

4.19 Question 18 - Which of the following options would best improve connectivity across
Milton Road between Cambridge North Station and Cambridge Science Park?
A One or more new 'green bridges' for pedestrians and cycles could be provided over
Milton Road. The bridges could form part of the proposed green infrastructure
strategy for the NEC, creating a substantial green/ecological link(s) over the road.

We support the proposals to improve connectively across the Milton Road corridor
particularly for pedestrians and cyclists, and to better integrate the existing Science Park with
the wider NEC area and the Cambridge North railway station. However, we question the
practicalities of 'green bridges' and the associated cost and impact on the viability of the
overall development area. There are a lot of opportunities to enhance green infrastructure in
the NEC area which doesn't require significant infrastructure costs such as a 'green
bridge'. The Thames 'Garden Bridge' project is an example of the spiralling costs associated
with the overall 'green bridge' concept, a project which was cancelled after significant costs
had already been incurred. We support a scheme that improves connectively for
pedestrians and cyclists either by rationalisation of the current complex traffic signals, which
prioritise vehicle movements, or a grade separated footway / cycleway bridge. We consider
this to be a more practical and deliverable approach.

B Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled
below ground in order to create a pedestrian and cycle friendly environment at street
level. This option would allow for significant improvements to the street which would
be more pleasurable for people to walk and cycle through.

As the response to Q18a) we see this option as prohibitively expensive, and creates a lot of
difficult engineering challenges to overcome. There are numerous accesses off the Milton
Road corridor to the NEC which would require slip roads etc which in themselves will create
a huge visual impact and a barrier to pedestrian and cycle movements. The existing Milton
Road where is joins the A14 grade separated junction is on a significant embankment, in
engineering terms it appears impractical, if not impossible to 'cut and cover' this road
effectively. Rather than a tunnel this option is likely to deliver a very expensive urban
underpass with associated negative visual impacts on the NEC area.

C Milton Road could be significantly altered to rebalance the road in a way that reduces
the dominance of the road, including rationalising (reducing) the number of junctions
between the Guided Busway and the A14 as well as prioritising walking, cycling and
public transport users.

Fully support this. The existing string of signalised junctions is unduly complex and designed to prioritise the predominance of vehicles over pedestrians and cyclists. There are opportunities to significantly alter and rationalise the existing signalised junctions on Milton Road and rebalance pedestrian and cyclist priority through targeted interventions. Further work is required to test these, but the street scene is currently motor vehicle dominated. The corridor is wide and presents opportunities for a rebalancing of priorities and to offer multiple crossing locations (rather than just focussing on a single location).

A reduction in vehicle movements associated with Cambridge Science Park would also
significantly help to improve connectivity across Milton Road between Cambridge North
Station and Cambridge Science Park

D Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.

A pedestrian / cycle bridge would require long ramps (to provide a max. of 1:20 slopes). This could be constructed on the axis of the Cowley Road cycleway / footway, incorporating the ramps east / west into the Science Park main entrance. This would provide a grade separated bridge which would allow pedestrians and cyclists a direct 'off road' east / west route from the Cambridge North railway station to the NEC and existing Science Park without having to cross any main roads.

A frequent 'shuttle bus', say every 15 minutes, could be provided from Cambridge North railway station to the whole CNF area, using the CGB, Cowley Road and internal NEC roads, encouraging employees of the existing Science Parks and the wider NEC to use the new Cambridge North rather than rely on the current mode of choice, the car.

E Other ways of improving connections (please specify)

Managing car parking and servicing

4.20 Question 20 - Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Support low car parking proposals for the whole of the NEC site. This is essential for the successful delivery of a sustainable district. These low car parking principles should be applied across the whole of the NEC, including the existing science parks which have very high car parking provision and not surprisingly high car usage at present. A consistent car parking approach is required across all land-uses supported by a range of sustainable infrastructure improvements to enhance access by other modes.

4.21 Question 21a. In order to minimise the number of private motor vehicles using Milton
Road, should Cambridge Science Park as well as other existing employment areas in this
area have a reduction in car parking provision from current levels?

4.22 Yes. The fundamental reason why the existing area has a very low uptake in non-car modes is the historic high provision of car parking across the NEC. This is a legacy of earlier developments in other times. Although there are very good public transport links, including a main line railway station, and cycle and walking infrastructure to these existing employment areas, there is little incentive to use modes of transport other than the car due to the abundance of car parking and the proximity of the strategic highway network, also the immediate environment around the station is not welcoming This needs to be addressed to provide a balance and sustainable transport strategy for the NEC area as a whole.

4.23 Question 21b: Should this be extended to introduce the idea of a reduction with a more
equitable distribution of car parking across both parts of the AAP area?

Yes essential.

4.24 Question 22: Should the AAP require innovative measures to address management of
servicing and deliveries, such as consolidated deliveries and delivery/collection hubs?

The APP must embrace new technologies and new ways of managing places. Yes, support the
centralisation of refuse collection for example.

Car and other motor vehicle storage

4.25 Question 23 - Should development within the north east Cambridge area use car barns for
the storage of vehicles?

4.26 Yes, however there are no periphery development areas that are not accessed directly off Milton
Road so although the concept is supported (as it could remove 'trips' off the highway network)
the practical delivery of this option is questioned. An alternative is the suggested use of the
existing Milton Road Park and Ride site. This site is currently an underutilised piece of existing
infrastructure. We would suggest that this site could deliver a 'car barn' concept, taking vehicles
off the A10 prior to the A10/A14 junction thereby reducing the overall impact of the NEC on this
key part of the highway network. To encourage employees (both existing and future) to use this
facility, shuttle buses could be used to get people from the P&R site to NEC, cycle (and
pedestrian) links could be greatly improved to allow people to park and cycle from the P&R site to
NEC and Cambridge North railway station.

Green Space provision

4.27 Question 24 - Within the north east Cambridge area green space can be provided in a
number of forms including the following options. Which of the following would you

A Green space within the site could be predominately provided through the
introduction of a large multi-functional district scale green space. Taking
inspiration from Parker's Piece in Cambridge, a new large space will provide
flexible space that can be used throughout the year for a wide range of sport,
recreation and leisure activities and include a sustainable drainage function. The
sustainable drainage element would link into a system developed around the
existing First Public Drain and the drainage system in the Science Park. The green
space could be further supported by a number of smaller neighbourhood block
scale open spaces dispersed across the site.

We could support this in principle, but it would have to be planned and designed collaboratively to ensure it functioned appropriately for all developments across the district. This may be difficult to do due to the phasing of the development of the district.

Furthermore, Brookgate Land Limited have learnt, through their experiences at CB1, that green spaces at a smaller scale, i.e. pocket parks, are more effective in residential-led schemes to serve the surrounding local community.

B Green spaces within the site could be provided through a series of green spaces
of a neighbourhood scale that will be distributed across the residential areas.
These green spaces will also be connected to the green infrastructure network to
further encourage walking and cycling. Again, these spaces will include a
sustainable drainage function and link into the existing First Public Drain and the
Science Park drainage system.

We would support this, but it would have to be planned and designed collaboratively
across the district to ensure proper accessibility and connectivity for both utilization by
residents and workers, as well as functionally connected for infrastructure purposes.

C Enhance connections and corridors within and beyond the site to improve the
biodiversity and ecological value as well as capturing the essential Cambridge
character of green fingers extending into urban areas. These corridors could also
be focussed around the green space network and sustainable drainage and would
reflect the NPPF net environmental gain requirement.

We would support this, but it would have to be planned and designed collaboratively
across the district to ensure proper accessibility and connectivity for both utilization by
residents and workers, as well as appropriate connections to the broader network.

D Green fingers to unite both sides of Milton Road and capitalise on the existing
green networks.

We could support this, but it will require a review of specific proposals.

E Consideration of the site edges - enhancement of the existing structural edge
landscape and creating new structural landscape at strategic points within and on
the edge of the CNF. This would also enhance the setting to the City on this
important approach into the City.

We could support this, but it will require a review of specific proposals. One challenge
with structured landscape edges is that they can tend to act as buffers which separate
parts of a district. Care will need to be taken to ensure that any landscape edges provide
benefits to the visual characteristics of the district without reducing the level of perceived
or actual connectivity across the district.

F Creation of enhanced pedestrian and cycle connectivity to Milton Country Park
and the River Cam corridor
We would support this.

5.0 Transport

Non-Car Access

5.1 Question 25 - As set out in this chapter there are a range of public transport, cycling and
walking schemes planned which will improve access to the CNF. What other measures
should be explored to improve access to this area?

● A frequent 'shuttle bus', say a minimum of every 15 minutes, could be provided from
Cambridge North railway station to the whole NEC area, using the CGB, Cowley Road and
internal NEC roads, encouraging employees of the existing Science Parks and the wider
NEC to use the new Cambridge North rather than rely on the current mode of choice, the car.

● Better use of the existing Milton Road Park and Ride site. This site is currently an
underutilised piece of existing infrastructure. We would suggest that this site could deliver a
'car barn' concept, taking vehicles off the A10 prior to the A10/A14 junction thereby reducing
the overall impact of the NEC on this key part of the highway network. To encourage
employees (both existing and future) to use this facility, shuttle buses could be used to get
people from the P&R site to NEC, cycle (and pedestrian) links could be greatly improved to
allow people to park and cycle from the P&R site to NEC and Cambridge North railway
station. This could include improvements to the existing pedestrian only footbridge over the
A10 to allow it to be used by cyclists thereby improving the cycle links between the P&R site
and NEC (via Milton village and Jane Coston Bridge).

● Providing Park and Cycle facilities at Milton Road Park and Ride site.

Car usage in North East Cambridge

5.2 Question 26 - Do you agree that the AAP should be seeking a very low share of journeys
to be made by car compared to other more sustainable means like walking, cycling and
public transport to and from, and within the area?

5.3 Yes. The current area has significant historic car parking which does not encourage or assist
with more sustainable transport choices. The NEC area has good public transport connectively,
the CGB, frequent local buses (the Citi 2) and Park and Rides services, a mainline railway station
and good cycle and pedestrian connectively to Cambridge City Centre and the cycle network in
general. The NEC area as a whole can support a low car parking strategy due to the abundance
of other non-car mode options available. There are significant opportunities within the NEC to
further enhance non-car modes of transport and to increase the number of 'internal trips' from
existing / proposed employment areas to existing and proposed residential areas. There are
significant opportunities to build a community where people can live and work, commuting by foot
or bike or public transport within the NEC and surrounding urban area.

5.4 Question 27 - Do you have any comments on the highway 'trip budget' approach, and how
we can reduce the need for people to travel to and within the area by car?

5.5 A highway 'trip budget' approach is considered to be a reasonable as long as it is applied to the
NEC as a whole, both the existing science parks and the currently undeveloped (or
underdeveloped) areas. We would not support a 'trip budget' that restricts vehicle trips for new
development to a level that is not commercially viable (or practical in terms of a based need for vehicle movements) nor would we support a 'trip budget' which restricts the efficient use of this
important and strategic brownfield site, in terms of density of development or the mix of
development uses, residential and commercial.

5.6 We would not support a 'trip budget' approach that does not address the current dominance of
car trips, due to high car parking provision and poor uptake of sustainable modes of transport,
within the existing employment areas within the NEC. For a 'trip budget' approach to be
deliverable, and balanced, and successful in delivering a sustainable development across the
NEC it must address the current imbalance between car parking provision on the existing science
parks and that proposed for new development.

5.7 We support proposals which further improve cycle and walking infrastructure and public transport
services to and within the NEC, which will reduce the need for people to use their cars to access
the NEC.

Car Parking

5.8 Question 28 - Do you agree that car parking associated with new developments should be
low, and we should take the opportunity to reduce car parking in existing developments
(alongside other measures to improve access by means other than the car)?

5.9 Brookgate Land Ltd support the use of more restrictive car parking standards across the whole
area to reflect the highly sustainable location. Priority should be given to zero or low parking
schemes as maintaining existing parking levels is not acceptable. Priority should also be given to
electric cars and car clubs.

5.10 Transport modelling work will assist in determining the appropriate levels of car parking taking
into account the site accessibility and proposed land-uses.

5.11 Reducing the reliance on car parking in the AAP area employment areas is key to addressing the
current dominance of car use within the existing NEC. This would reduce the impact of the NEC
on the existing highway network and enable the whole area to be developed to its full potential,
and for any 'trip budget' for the NEC to be reasonable, both commercially and practically

Cycle Parking

5.12 Question 29 - Do you agree that we should require high levels of cycle parking from new

5.13 Yes, high cycle parking is necessary to deliver a truly sustainable development, for both the
existing developed areas and new development proposals.

5.14 Question 30 - Should we look at innovative solutions to high volume cycle storage both
within private development as well as in public areas?

5.15 Yes, cycle parking requires a significant amount of space. High density cycle parking such as
'double stackers' should be the norm for commercial and residential developments in the NEC. It will enable efficient use of land and provide the quantum of cycle parking necessary to deliver a
sustainable development based on low car parking numbers.

Question 31 - What additional factors should we also be considering to encourage cycling
use (e.g. requiring new office buildings to include secure cycle parking, shower facilities
and lockers)?

5.16 Yes, convenient and secure cycle park and other facilities such as showers and lockers for cyclist
on commercial developments are supported. Charging points for electric bike should be

Innovative approaches to Movement

5.17 Question 32 - How do we design and plan for a place that makes the best use of current
technologies and is also future proofed to respond to changing technologies over time?

5.18 The CGB provides a high quality, uncongested corridor through the CNF area, with one crossing
of Milton Road. This corridor has the potential for early delivery of a rapid transport, autonomous
vehicle shuttle between Cambridge North Station, the Science Park and Cambridge Regional

Linking the Station to the Science Park

5.19 Question 33 - What sort of innovative measures could be used to improve links between
the Cambridge North Station and destinations like the Science Park?

5.20 Yes. The Cambridge North Station is a fantastic facility which is currently underused. Links
between the station and the existing science parks could be significantly improved by a number
of measures:

● A frequent shuttle bus.
● Better pedestrian and cycle connectively across Milton Road.
● Better 'wayfinding' to encourage walking and cycling between the station and existing employment areas (a walk of less than 20 minutes).

6.0 Employment

Types of Employment Space

6.1 Question 34 - Are there specific types of employment spaces that we should seek to
support in this area?

6.2 A combination of commercial and residential uses which are likely to include offices and R & D
uses, should be provided in the NEC area, with the mix being informed by both market conditions
and successful place-making.

6.3 Question 35 - In particular, should the plan require delivery of:

A A flexible range of unit types and sizes, including for start-ups, and Small and
Medium Sized Enterprises (SMEs);

B Specialist uses like commercial laboratory space;

C Hybrid buildings capable of a mix of uses, incorporating offices and
manufacturing uses.

D Shared social spaces, for example central hubs, cafes.

E Others (please specify).

6.4 The policy framework should be flexible to allow for such developments. Bespoke solutions to
maximise economic and employment benefits should therefore be secured as part of individual
applications rather than through a generic and inflexible policy approach.

7.0 Housing

Housing Mix

7.1 Question 38 - Should the AAP require a mix of dwelling sizes and in particular, some
family sized housing?

7.2 Brookgate Land Limited would be supportive of a mix of dwelling sizes across the AAP, including
for purpose built private rented sector housing (PRS). This would support the Government's
objective of significantly boosting the supply of homes in ensuring that a sufficient amount and
variety of land can come forward where it is needed and that the needs of groups with specific
housing requirements are addressed.

Affordable Housing

7.3 Question 40 - Should the AAP require 40% of housing to be affordable, including a mix of
affordable housing tenures, subject to viability?

7.4 Subject to viability testing, the 40% requirement should be applied to the NEC AAP as a whole.
The very heavy infrastructure costs and brownfield nature of the land with associated remediation
costs must be recognised and viability is of key importance.

7.5 Consideration should however be given to PRS developments where a different approach may
be required, such as discounted market rents, off-site contributions toward affordable housing
provision etc. As such, the NPPG (Paragraph: 004 Reference ID: 60-004-20180913) advises
that if agreement is reached between a developer and a local authority, the affordable housing
requirement could be met by other routes, such as a commuted payment and/or other forms of
affordable housing as defined in the NPPF. The details of this must be set out in the section 106.

Private Rented Sector (PRS) Housing

7.6 Question 44 - Should the AAP include PRS as a potential housing option as part of a wider
housing mix across the north east Cambridge area?

7.7 Yes. There is clear Government support for PRS with Build to Rent now explicitly recognised as a
distinct asset class within the private rented sector and has been defined in the NPPF glossary.

7.8 The cost of homeownership is rising and access to social renting has declined, meaning more
and more people in the UK now rely on PRS housing. In the 80s and 90s, PRS property
represented around 10% of all households in England. However, PRS has since become the
fastest-growing sector in the country, and that figure has doubled.

7.9 The ability of PRS schemes to create quality places to live cannot and should not be doubted, it
is no different to any development in the built environment. It needs a clear brief and good design
and delivery and collaborative working to make it successful architecturally and in urban design

7.10 PRS provides a means of widening housing choice for tenants, particularly those who may be
renting long term, and also to deliver much needed housing within a faster timescale.

7.11 Many authorities are developing PRS design guides (GLA, Newham) to assist developers. The
authorities may wish to follow a similar route and as part of the AAP produce guidance in
association with the developer but the ULI UK residential council has recently produced "Build to
Rent, a Best Practice Guide", which represents significant time and expertise and a question
must be posed over simply replicating existing guidance.

7.12 The Greater Cambridge Housing Strategy 2019-2023 recognises that PRS models can help
support the needs of those on middle incomes who come to work in the area but cannot afford to
live locally.

7.13 The Strategy states, at page 17 that
"We recognise that PRS can meet the needs of households on a range of incomes, from
those who are unlikely to be considered for social housing for rent to those who can
afford but do not want to own their own home. We also recognise PRS can help
accelerate overall housing build-out rates on large strategic sites. Subject to clear
evidence of need, we may consider proposals for new PRS as part of a wider housing
mix. Any such homes provided should remain available as PRS for an agreed period."

7.14 Question 45 - If PRS is to be supported, what specific policy requirements should we
consider putting in place to manage its provision and to ensure it contributes towards
creating a mixed and sustainable community?

7.15 Brookgate Land Limited are keen to work with the Council to develop a set of local requirements
to inform the development of a PRS scheme at NEC AAP. An example is Policy H13 of the Draft
New London Plan, an extract of which is below:

● the development, or block or phase within the development has at least 50 units
● the homes are held as Build to Rent under a covenant for at least 10 years
● there is unified ownership and unified management of the development
● there is on-site management, this does not necessarily mean full-time dedicated on-site staff,
but all schemes need to have systems for prompt resolution of issues and some daily on-site
● providers have a complaints procedure in place and are a member of a recognised
ombudsman scheme

7.16 Question 46 - Should PRS provide an affordable housing contribution?

7.17 The NPPG advises that it is expected that developers will usually meet their affordable housing
requirement on build to rent schemes by providing affordable private rent homes. However, if
agreement is reached between a developer and a local authority, this requirement can be met by
other routes, such as a commuted payment and/or other forms of affordable housing as defined
in the National Planning Policy Framework glossary. The details of this must be set out in the
section 106.

7.18 Consideration should therefore be given to PRS developments where a different approach may
be required, such as discounted market rents or off-site contributions toward affordable housing

7.19 It is clear that the provision of good quality, institution-operated private rented accommodation
meets an identified housing need group, principally for those economically active individuals who
are vital to the Cambridge economy, and contribute massively to the success of its academic and
commercial research and development industries. Many of those working in these sectors do not
qualify for Affordable Housing, and the price of open market housing in the City is for them at an
unaffordable level, a point which has been well made by a number of employers in the area.
Failure to provide accommodation which is affordable to this group risks damaging the status of
Cambridge as one of the UK's fastest growing cities.

7.20 It is nevertheless challenging to build new accommodation specifically for the private rented
sector in the absence of a separate Planning Use Class, meaning that new applications for PRS
accommodation are assessed on the same basis as conventional C3 dwelling house
applications. Some local authorities have recognised that the economics of delivering PRS are very different to conventional housing and recognising the positive contribution to meeting housing need that PRS makes, have provided flexibility on other planning gain requirement, notably affordable housing. The delivery of PRS is linked closely to the City Deal objectives and will considerably add to the additionally argument that the combined authorities will need to demonstrate to access further tranches of monies.

7.21 The Greater Cambridge Housing Strategy 2019-2023 confirms, at paragraph 7.6.2 that recognising the different financial model involved in delivering PRS, consideration may be given to part of the affordable housing requirement on a strategic site being met through provision of Affordable Private Rent as part of a PRS scheme (rents set at least 20% below local market rents).

7.22 The Housing Strategy continues, at paragraph 7.6.2 and 7.6.3, in stating:

"For any new PRS scheme we will seek a range of rent levels to meet a variety of income levels. Rent levels in any scheme would need to be agreed with the relevant council, based on robust evidence around needs and income levels. As a guide, it is considered that 35% of net household income is reasonable to spend on housing costs, including rent and any service charges.

Prior to the review of the local housing needs assessment, as a benchmark for the levelof affordable private rent homes on PRS schemes, the local authorities will seek at least 20%."

7.23 Brookgate Land Limited are keen to work with the Councils to identify ways in which the challenges of delivering good quality private rented accommodation and affordable housing can be met to provide the best economic outcome for Cambridge.

7.24 Question 47: What 'clawback' mechanisms should be included to secure the value of the
affordable housing to meet local needs if the homes are converted to another tenure?

7.25 Clawbacks mechanism should be used on multi-phased developments only where market conditions may change over the life of the project. Projects with shorter build out programmes should not automatically be subject to claw back arrangements as they greatly affect funding streams.

7.26 Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

7.27 A suitable period would be a maximum of 10 years. No compensation.

7.28 Question 49: What type of management strategy is necessary to ensure high standards of
ongoing management of PRS premises is achieved?

7.29 The PRS model for Phase 1b is proposed to be owned by an institutional investor rented out through an agent or directly. Lease lengths are generally the same as other privately rented housing, but since the landlord is a professional investor, they are keen to keep tenants in place for the long term. This provides tenants with greater long-term stability.

7.30 The management is undertaken by a professional management company. This PRS property management model gives tenants access to professionally managed property and since the homes are purpose-built for renting, better all-round quality.

7.31 Management will be key to creating a "place" where people want to be. An example to refer to of
a successful PRS scheme is East Village, Stratford. This has a number of on-site leisure, retail and recreation facilities which are managed by a professional management company, together with areas of open space and landscaping. They have a management team on site to manage day to day matters.

Quality and Accessibility of Housing

7.32 Question 51: Should the AAP apply the national internal residential space standards?

7.33 There is no national requirement for authorities to apply national space standards in their area.
Space standards are optional. However, Brookgate Land Limited are committed to a PRS scheme that would be designed, constructed and managed to a high quality standard.

7.34 Question 53: Should the AAP apply External Space Standards, and expect all dwellings to
have direct access to an area of private amenity space?

7.35 The AAP should ensure that all dwellings are designed, constructed and managed to a high quality standard. External space standards could apply where the viability of development is not compromised.

7.36 Question 54: Should the AAP apply the Cambridge Local Plan accessibility standards?

7.37 The AAP should ensure that all dwellings are designed, constructed and managed to a high quality standard.

8.0 Retail, Leisure and Community Services and

8.1 Question 55 - Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision on the North East Cambridge area? Are there other important factors we should be considering?

8.2 Yes, in order for the regeneration of the NEC area to be successful the required services and facilities must be provided. This will require collaborative strategies between key stakeholders and will be easier to achieve on sites such as Phase 1b, where large areas can be brought forward by relatively few stakeholders, simplifying the planning and engagement process. The delivery of such services and facilities is essential to ensure the creation of a vibrant, mixed use neighbourhood, as set out in the proposed vision.

Community Facilities

8.3 Question 57 - What community facilities are particularly needed in the NEC?

8.4 A range of community uses should come forward to create a vibrant, mixed use neighbourhood.

Open Space

8.5 Question 58: It is recognised that maximising the development potential of the North East
Cambridge area may require a different approach to meeting the sport and open space
needs of the new community. How might this be achieved?

8.6 A collaborative effort to produce a network of connected green and open spaces which are accessible to all residents and workers in the district should be facilitated. This would include connections to the broader green network outside the district, as well as providing sport and recreational spaces within the district

8.7 Question 59: Should open space provision within the North East Cambridge area prioritise
quality and functionality over quantity?

8.8 Yes, if this is to truly be an urban place, the open space provision should be as efficient as possible and provide access to all residents and workers, and the spaces should be programmed at a district-wide level. Provisions of open space should be evaluated across the district and not on a parcel-by-parcel basis.

8.9 Question 60: Should open space provision within the North East Cambridge area seek to
provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

8.10 The open space provision should provide a wide variety of recreational opportunities, but it should not over provide inside the district, nor should it replicate recreational provisions that are easily accessed outside the district for the sake of variety. It needs to be planned in consideration of existing offerings as well as a distributed system across the district.

8.11 Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

8.12 Yes, as appropriate

9.0 Climate Change and Sustainability

Sustainable design and construction standards

9.1 Question 63 - Do you support the approach to sustainable design and construction standards suggested for the AAP?

9.2 Yes, but the AAP needs to remain flexible in terms of any specific policy requirements in order to be able to respond to change.

Reviewing Sustainability Standards in the future

9.3 Question 64 - Do you support the proposal for the AAP to be clear that review mechanisms should to be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy?

9.4 The development industry needs certainty, certainly at the point it embarks on attaining planning
permission for a new development. It is not reasonable to have a policy position that could shift following the start of that design and planning process. Any advancing sustainable agenda should be clearly set against clear and transparent policy milestones.

Site wide approaches to sustainable design and construction

9.5 Question 65 - Do you support the plan requiring delivery of site wide approaches to issues
such as energy and water, as well as the use of BREEAM Communities International?

9.6 Such matters can often be difficult to provide in practice for many technical or feasibility reasons;
however, there should be an aspirational policy agenda around sustainability.

Smart Technology

9.7 Question 68 - Should the AAP require developments in the area to integrate smart
technologies from the outset?

9.8 As a place to be founded on the Science and Technology section there should be an ambition to
embrace Smart Technologies.

Waste Collection

9.9 Question 69 - Should the AAP require the use of an underground waste system where it is

9.10 This would be difficult to retrospectively fit to CSP but would be more viable for new large scale

10.0 Implementation and Delivery

Phasing and Relocations

10.1 Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

10.2 Yes. Refer to our answer to question 78. Land that Brookgate Land Limited control can be developed early without prejudicing the outcome of the AAP process or the achievement of the comprehensive vision for the area as a whole.

Funding & Delivery of infrastructure

10.3 Question 72: Do you agree with an approach of devising a Section 106 regime specifically
for the NEC? If not, what alternative approach should we consider?

10.4 No, it is more appropriate for individual s106 which are site specific.

10.5 Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome

10.6 At the outset, it would appear appropriate for it to be related to the amount of new floorspace
provided against its use class and also based on number of and type of trips.

Joint Working

10.7 Question 77: Should the Councils actively seek to facilitate joint working between the
various landowners/developers within the NEC? If so, what specific matters could we target for joint working?

10.8 Yes. Brookgate Land Limited have been committed to joint working with the various landowners
and developers within the NEC since 2014 and continue to remain fully engaged to cooperate.
Specific matters are being discussed through the ongoing Landowner Liaison forums.

Pre-AAP Planning Applications

10.9 Question 78: Do you agree with the Councils' proposed approach to dealing with planning
applications made ahead of the AAP reaching a more formal stage of preparation.

10.10 Phase 1b is part of the designation of Policy SS/4 'Cambridge Northern Fringe East and
Cambridge North Railway Station' within the recently adopted South Cambridgeshire Local Plan
(2018). Phase 1b is on the border with Cambridge City Council and is also designated under
Policy 15 'Cambridge Northern Fringe East and new Railway Station Area of Major Change' of the Cambridge City Local Plan (2018).

10.11 Under both policies, the area is allocated for high quality mixed-use development, primarily for
employment uses such as B1, B2 and B8, as well as a range of supporting commercial, retail, leisure and residential uses (subject to acceptable environmental conditions).

10.12 Paragraph 3.31 in the supporting text of Policy SS/4 of the South Cambridgeshire Local Plan
Policy SS/4 states the following:
"Cambridge North railway station will provide a catalyst for regeneration of this area. Early development around Cambridge North station could help create a vibrant area around this key infrastructure to meet the needs of users of the station and bring forward further phased delivery elsewhere within the CNFE area. Planning applications submitted before the adoption of the AAP will be considered on their own merits and subject to ensuring that they would not prejudice the outcome of the AAP process and the achievement of the comprehensive vision for the area as a whole that will be established by the AAP."

10.13 The recently adopted Local Plan therefore makes it clear that planning applications are capable
of being submitted and granted planning permission in advance of the AAP being adopted.

10.14 Brookgate Land Limited are seeking to bring forward Phase 1b a residential-led, mixed use
development providing 1000 PRS accommodation, a new specialist maths college and another office building. The intention is to submit a planning application by the end of 2019.

10.15 The proposed uses would not generate significant peak hour traffic due to both the excellent
public transport accessibility of the site and the nature of the proposed uses. The proposals are to provide a relatively low level of car parking for the residential quarter. This would be supported by a range of measures to promote travel by means other than the car, taking account of the site's excellent accessibility by a range of means of transport along with measures to control parking in the surrounding area. This will significantly reduce potential traffic impacts on the existing highway network.

10.16 Better uptake of more sustainable modes of transport on the existing science park could also
reduce the traffic on the network and improves the position on the A14 junction, as would possible 'car barns' or similar measures.

10.17 The Station Amendments application and associated access roads largely determine the layout
for the Phase 1b site such that, with continued dialogue with Urban Design officers alongside the production of the NEC AAP, this would not prejudice or predetermine the design of the wider NEC AAP area. The Phase 1b proposals are also in accordance with the Indicative Concept Plan included in the NEC AAP and Brookgate Land Limited have undertaken extensive consultation (and will continue to do so) with neighbouring landowners and stakeholders to ensure that shared ambitions can be achieved,

10.18 In summary therefore, the Phase 1b proposals would clearly not prejudice the outcome of the
AAP process or the achievement of the comprehensive vision for the area as a whole.

10.19 The approach in the recently adopted local plan in respect of early submissions should not be
watered down through the AAP process, indeed, through the AAP process the opportunity to bring Brookgate land forward early should be explicitly acknowledged as beneficial to the regeneration of the area, creating a sense of place and arrival around the new Station and evidencing in commercial terms how the low parking ratios might work.

Meanwhile (Temporary) Use

10.20 Question 79: What types of 'meanwhile uses' should the AAP support for the CNF?

10.21 Brookgate Land Ltd is supportive of appropriate meanwhile uses where they add to the vibrancy of the area and are appropriate uses to support the AAP area.

10.22 Question 80: Should there be any limit on the scale of a proposed 'meanwhile use'?

10.23 No

10.24 Question 81: Do you think it appropriate to set a maximum period for how long a 'meanwhile use' could be in operation?

10.25 Not necessary