Cambridge is a city of international heritage significance. It is therefore considered that the historic environment has been considered in the local plan far too narrowly. This policy needs to be linked to the wellbeing policies WS/HD as safeguarding and enhancing the historic environment is a key part of Wellbeing and creating healthy developments.

The definition of sustainable development must be broadened to include Culture (since 2010 the UN has included culture as the 4th pillar of sustainable development). Cambridge’s historic environment is a cultural asset of worldwide significance which must recognised when developing sustainable policies and development.

Concerns are raised on the Heritage Impact Assessment (2021). There is considered to be a flaw in the Baseline Study which does not assess and record the SIGNIFICANCE, as opposed to weighting, of the City as a whole or of any undesignated areas within and around it. This is a direct consequence of the study's approach to the Historic Environment in terms of considering only the setting of designated heritage assets, rather than taking a holistic strategic view.

It appears that the study has only taken a superficial look at the baseline information.
• The baseline study confines itself to stages 1 (“identify the historic assets” and 2 (“define and analyse the settings”) of Historic England’s ”Settings of Heritage Assets: Good Practice Guide”, without considering the dynamic of the city as a whole: what has been happening in its recent years?,and what are the potential impacts of the large scale growth that is planned? It is almost as if the Council asked for an updated version of the 1971 publication “Cambridge Townscape”, whilst completely disregarding the award-winning conservation plan approach of the 2006 Historic Core Appraisal which sought to understand not just the physical character of Cambridge but its dynamic, and threats and opportunities, as part of shaping policies.
• The HIA identifies Conservation Area Appraisals as data to inform the assessment. However, not all the conservation areas have a CAA (indeed the majority of Conservation Areas in South Cambs District do not have up-to-date CAA) and therefore there is a gap in the available data.
• The Baseline study does not mention the Suburbs and Approaches Studies.
• The Baseline study does not consider the strategic extent, or lack of, designations for example the extent to which Cambridge’s historic or cultural landscape (including the river corridor from Byron’s pool to Baits Bite Lock) is or is not protected.

We feel that the study fails to assess the significance of Cambridge as a whole. Dennis Rodwell’s “Conservation and Sustainability in Historic Cities” puts Cambridge on a similar level of international significance to Venice.

The “Strategic Heritage Impact Assessment” references a “Vu-City” model for assessing the impacts of tall buildings. We request that this modelling is made available for the public to see and assess both proposals, and the credibility of the Vu-City approach.

Concerns are raised on the failings of the “view” photos within the study, and that they don’t show the “eye-catching” impact on a viewer’s perception of a contrasting feature such as a tall building in a landscape.

Cambridge’s special character (which is what makes it a great place) will be put under significant pressure by the scale of growth proposed (73,000 extra residents). Cambridge Past, Present & Future is very concerned about the “limits to growth” capacity in trying to accommodate the 21st century demands this will create within the built fabric and spaces of a medieval market town. The fundamental conflicts between growth on the one hand and environmental capacity and special character on the other must be recognised as a key challenge for the draft Local Plan. We are concerned that the evidence base does not include an assessment of the cumulative impacts on the historic centre and what the likely impacts of this might be – without this it is impossible to reach a judgement. Para 3.2.4 of the Strategic Heritage Impact Assessment: baseline includes the statement that “3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity" but we could not find any evidence to support this statement.

A third-party, holistic overview is recommended, to identify and try to resolve some of these key strategic issues and balances. In relation to heritage, growth is seriously threatening what makes Cambridge Special. It is recommended that Historic England’s Historic Places Panel are invited to visit Cambridge and provide strategic recommendations which can inform the Local Plan.

Moving from strategic issues to safeguarding individual heritage assets and their settings, there are serious questions in relation to the effectiveness of existing policies which are proposed to be carried forward. A case in point is the former Mill Road Library, a grade II listed building of high public significance, which was recognised to be “at risk” but excluded during the development and approval of the adjacent City Depot site. This was an excellent opportunity to protect and enhance a heritage asset, which would not have been missed had the City complied with its own Local Plan policy regarding heritage assets. While the County has belatedly refurbished the former Library, it has not been integrated as a public building within the new development. It appears that the County may now be offering this public building, built for the public, for private sale!