Object

Representation ID: 55742

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 9 sets out expected building heights and densities across the area and how
the scale and massing (shape) of buildings should consider its impact on the
skyline.
To understand the potential impact of development, the Councils have undertaken
a Landscape Character and Visual Impact Appraisal to inform Policy 9 but are also
commissioning a Heritage Impact and Townscape Assessment to inform a wider
Townscape Strategy for North East Cambridge.
Policy 9 states that ‘development densities and building heights should not exceed
those identified on Figure 21 and Figure 23. Densities and intensification of
appropriate uses will increase around highly accessible parts of the Area Action
Plan area taking into account wider development sensitives, and activity clusters
such as the District Centre and Cambridge North Station.’
Brookgate object to Policy 9 in that the Policy is overly restrictive in stating that
building heights ‘should not exceed’ those identified on Figure 21. 4-5 or 5-6 typical
building height in an area around an existing station and public transport
interchange is particularly low. Figure 21 also fails to take account of the building
heights of the consented hotel and office adjacent to the station (both 7 storeys).
Both of these detailed applications demonstrated through detailed technical
evidence the acceptability of 7 storeys in this location.
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Furthermore, the maximum heights proposed in Figure 21 are assuming a
residential storey height as opposed to an office typical level and do not appear to
allow sufficient additional ground floor height for active frontage and alternative
uses. It should also be noted that office storey heights have recently increased to
be in line with developing national space standards and therefore they may be a
small increase when comparing to existing precedents.
Setting overly restrictive maximum height limits in certain locations and without the
proper consideration of the wider planning potential of development sites and wider
implications of not maximising those opportunities (by displacing development to
other locations that may not be best placed to accommodate it) is a risk to the
current approach set out in the NEC AAP. Such a displacement effect presents a
lost opportunity in key urban areas of high demand for new accommodation,
whether that is for living, working, leisure or other requirements in the built
environment.
With particular reference to Cambridge North, the Site is bounded by the railway
line to 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;
● Make optimal and efficient use of the capacity of the site and release
significant development pressure from the historic core of the City;
● Optimise the effectiveness of substantial investment in public transport
infrastructure and mobility corridors in terms of improved and more sustainable
mobility choices and enhanced opportunities and choices in access to housing,
jobs, community and social infrastructure;
● Create an opportunity to define the north east corner of the City with striking
buildings visible from the A14;
● Support the additional uses and amenities that will make this a selfsupporting
district; and
● Assist in reinforcing and contributing to a sense of place, such as indicating
the main centres of activity, important street junctions, public spaces and transport
interchanges. In this manner increased building height is a key factor in assisting
modern placemaking and improving the overall quality of our urban environments.
The NPPF confirms, at paragraph 118, that planning policies should “give
substantial weight to the value of using suitable brownfield land within settlements
for homes and other identified needs” and “promote and support the development
of under-utilised land and buildings”. The NPPF continues, at paragraph 112, in
advising that planning policies should support development that makes efficient use
of land, taking into account, inter alia, the identified need for different types of
housing and other forms of development, and the availability of land suitable for
accommodating it.
The NEC AAP is the largest brownfield site in Cambridge and is served by
excellent public transport infrastructure. It therefore presents a significant
opportunity to transform into a high-quality gateway to the city and act as a catalyst
for the regeneration of the wider area. Opportunities for densification of existing
urban areas in locations well served by public transport should therefore be
maximised wherever possible.
The tax payer, through the construction of the Station and the relocation of the
water treatment works, will contribute over £300M towards the regeneration of the
area. It is therefore imperative that a proper return is achieved on this massive
investment in the area and if the Mayor’s CAM comes to fruition, further tax payers
monies will be secured.
A high density development would represent efficient use of land in a sustainable
location and create the opportunity for people to live close to where they work. 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.
The need for densification in urban parts of Cambridge and adjoining transport
hubs is also supported by the Cambridge and Peterborough Independent
Economic Review (CPIER), 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.”