Climate change

Horningsea Parish Council believes the proposal to relocate the Cambridge Waste Water Treatment Plant - a fully functioning waste water treatment plant - to Green Belt is a waste of taxpayers’ money, a waste of Green Belt and an unnecessary contribution to the effects of climate change.

Flooding is already a serious problem in the fields immediately to the south of the city. During January 2021 a lot of the fields were under water, as can be seen in the attached photos. Flooding is already an issue for the recently completed Ninewells development. Further development would make this worse. Climate change threatens an increase of 35% in winter rainfall above the current levels, so permitting development of this land now seems very irresponsible.

USS notes the aim for the proposed climate change policies is to help Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions.
USS strongly supports this proposed approach, noting that the first priority for new development should be to redevelop brownfield land in existing town centres. This is the most effective way of ensuring new development limits carbon emissions as it reduces the need to travel long distances for commuting, education and leisure. Increasing density on brownfield sites and adding residential uses to town centres can be a significant driver of limiting carbon emissions across Greater Cambridge.

DB Group’s strategy is focused on improving sustainability within the construction sector, and the company seeks to reduce their environmental impact in everything they do. That’s why, in 2015 they introduced Cemfree® ultra-low carbon concrete which was a complete game changer for the construction industry that achieves dramatic embodied carbon savings of up to 88% in concrete. This innovative technology was developed in-house to ensure every detail was exactly as it should be. It has since won multiple awards and continues to excite and impress the industry in equal measure.
Local production and use of Cemfree ultra-low embodied carbon concretes can play a part in the Councils plans for more sustainable development across Greater Cambridge, replacing environmentally damaging cement-based concretes and demonstrating its commitment to the low carbon agenda.
Ensuring that businesses and employment opportunities within the District are also focussed on achieving net zero carbon by 2050 will be essential to the Council achieving this goal. The Council should be proactively working with DB Group, and companies like them, to ensure that the Council enables them to achieve their full potential in terms of contributing towards this goal.

Hallam Land Management (HLM) support the Councils aims in respect of climate change.

General support.

Marshall agrees that planning to limit and mitigate the effects of climate change is of central importance. Cambridge East is being planned to achieve an exemplar development which can act as a flagship for the Councils’ objectives. By pioneering new technologies and considering the long term welfare of our planet and its people, we believe Cambridge East can create a transformative green infrastructure connecting the City with the countryside that sets the new global standard for sustainability.

The ambitions of Cambridge East include net zero embodied carbon and net zero operational carbon through careful design of infrastructure, carbon offsetting through local (if possible) sequestration via the creation of new or enhancement of existing areas of woodland and other habitats, sustainable water management for the wider area (not simply for the benefit of Cambridge East), and creating a ‘green link’ which will encompass many climate initiatives such as using green infrastructure to reduce the impacts of climate change (e.g. providing shade and reducing overheating). These commitments are set out in the Sustainability Vision that Marshall submitted in February 2020. These commitments will be developed further through Marshall’s joint working with the GCSP.

Marshall’s view is that there is the potential for the sustainability benefits of Cambridge East to be even greater if development also includes land east of Airport Way, enabling planning at an even higher strategic scale.

In line with the climate approach of the Local Plan, the ambitions of Cambridge East seek to provide a net zero operational development, and reduce embodied carbon to net zero through construction. Offsetting would ensure consideration at an on-site and local scale where feasible. In order to provide a holistic approach to carbon offsetting, it is recommended that consideration is given by GCSP to a holistic carbon offsetting strategy, and the demarcation of potential sites where the offsetting of the carbon impacts from allocated Local Plan development could bring additional local benefits. This will ensure that this intrinsically important, yet often difficult to apply, policy is targeted, local, and achievable. Marshall is happy to work in collaboration with GCSP in order to develop, agree and achieve a strategy which works for all. Through collaboration a truly balanced plan will be created, in which the 4 pillars of the Local Plan objectives are achieved by embracing growth rather than resisting it.

More detail is provided below when responding to specific proposed policies.

The University supports the Councils’ aim for Greater Cambridge to transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use, and is resilient to current and future climate risks.

As the plan progresses, you need to ensure that it references and is based on the latest government targets. Technology, standards and targets will continue to change rapidly during the period of the plan and so the plan will need to include mechanisms to ensure that policies and supplementary policies can keep pace.

Agree that development should be located so that low carbon transport links can be accessed. However, such locations should not be chosen based on proposed busways – the delivery of these is uncertain and their construction generates carbon emissions through the embodied carbon in the building materials, tree felling reducing carbon capture, maintenance and serving works, and lighting, contrary to the Council’s net zero carbon agenda. The majority of the busways are also in the green belt.

Section 3 of the First Proposals relates to ‘The Plan Themes’, the first of which is ‘Climate Change’. The Church Commissioners for England strongly support the Councils’ aim to transition to net zero carbon by 2050 and recommend that this provides further justification as to why the Plan period should be extended to 2050 as detailed in the response to Policy S/JH. It is acknowledged that the Councils seeks to achieve this target by ensuring that development is sited in places that help to limit carbon emissions. The Commissioners wish to reiterate the comments made in response to Policy S/DS and Policy S/CB where reference is made to the Councils’ identification of development at Cambourne being the most sustainable outside of Cambridge. This is in part due to the proposed infrastructure works in the area which would help reduce carbon emissions.

The importance the plan places on climate change and the achievement of net zero status by 2050 is supported, recognising NPPF (2021) Paragraph 153, which requires plans to take a proactive approach to mitigating and adapting to climate change.

The First Proposals document states that the spatial strategy has been informed by carbon assessment that highlights the impact that transport emissions can have, and promotes patterns of development that enable low carbon transport modes, shifting away from a reliance on the private car. Many of the rural settlements, despite being a lower order in the settlement hierarchy, are sustainably located on public transport networks, as well as having good access to local services, facilities and employment opportunities. Land West of London Road, Fowlmere benefits from local employment, primary school, village hall, recreation ground and places of worship and is also serviced by two bus services, providing frequent links to Cambridge as well as other sustainable settlements that benefit from train stations.

In adapting to climate change, it should be noted that well-designed new residential development can contribute to carbon offsetting through tree planting, and the delivery of sustainable technologies such as water reduction, solar panels, ground source heat pumps, high levels of installation, improved lighting and other measures, whilst encouraging existing and new communities to adopt more sustainable methods of travel, including the provision of attractive open spaces and green linkages to encourage walking and cycling.

The provision of Sustainable Drainage Systems within new development can also alleviate existing fluvial and pluvial flood issues.

Land West of London Road, Fowlmere is proposed to contribute to carbon offsetting through the provision of a landscape strategy, including additional tree planting, provision of sustainable drainage systems that are multi-functional, and delivering an attractive open space in the form of a village park. The proposed development would also deliver low carbon housing, electric vehicle charging at every dwelling and promote low water consumption, therefore proactively mitigating the effects of climate change through reducing overall carbon emissions.

Climate change policy should not be overly prescriptive such that it provides a barrier to sustainable development. It should also be acknowledged that technologies are constantly changing. For example, the shift to electric vehicles significantly reduces the carbon footprint of the private car and the introduction of new sustainable technologies such as water reduction, solar panels, ground source heat pumps, high levels of installation and improved lighting, all of which contribute to sustainability and reducing carbon footprint. Therefore, policies should enable flexibility to accommodate evolution in technology and way of life.

The importance of climate change and the achievement of net zero status by 2050 is supported, recognising NPPF Paragraph 153, which requires plans to take a proactive approach to mitigating and adapting to climate change.
The First Proposals document states that the spatial strategy has been informed by carbon assessment that highlights the impact that transport emissions can have, and promotes patterns of development that enable low carbon transport modes, shifting away from a reliance on the private car. Many of the rural settlements, despite being a lower order in the settlement hierarchy, are sustainably located on public transport networks, as well as having good access to local services, facilities and employment opportunities.
Land East side of Cambridge Road, Melbourn offers an opportunity to deliver much needed growth to the settlement, to support local housing need and enhance social cohesion. The site is in a sustainable location, in proximity to services and facilities and is available for development. It is considered that development within this location will encourage future occupiers to adopt sustainable modes of transport, including walking, thereby contributing to supporting healthy lifestyles and seeking to mitigate the impacts of climate change.
In adapting to climate change, it should be noted that well-designed new residential development can contribute to carbon offsetting through tree planting and the delivery of sustainable technologies such as water reduction, solar panels, ground source heat pumps, high levels of installation, improved lighting and other measures, whilst encouraging existing and new communities to adopt more sustainable methods of travel, including the provision of attractive open spaces and green linkages to encourage walking and cycling.
The provision of Sustainable Drainage Systems within new development can also alleviate existing fluvial and pluvial flood issues.
Climate change policy should not be overly prescriptive such that it provides a barrier to sustainable development. It should also be acknowledged that technologies are constantly changing. For example, the shift to electric vehicles significantly reduces the carbon footprint of the private car. Therefore, policies should enable flexibility to accommodate evolution in technology and way of life.

TMLC supports the aim for the proposed climate change policies to help Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks.
TMLC supports that planning is not just concerned with buildings themselves but place making, and as such has the potential to be a powerful tool in the response to the climate emergency. Achieving net zero carbon status cuts across all elements of place making; not just how homes and buildings are designed and constructed, but also by ensuring new development is located where it is or can be served by low carbon transport links, like public transport, cycling and walking.

CBC and the landowners share and strongly support the proposed transition to net zero carbon by 2050 and welcome the recognition that this will be enabled by locating developments in locations that limit carbon emissions. The CBC 2050 Vision for growth at Cambridge Biomedical Campus aligns with GCSP’s goals and it is our intention to ensure that development mitigates and can adapt to the impacts of climate change through measures such as management of water supply, mode shift, local living, green infrastructure and net zero buildings. We envisage close joint working with GCSP, stakeholders and local communities to co-design steps towards these outcomes. The Greater Cambridge Local Plan Strategic Spatial Options Assessment - Integrated Water Management Study, November 2020, identifies that “… Growth is most preferable concentrated in new settlements or urban extensions …. and can maximise opportunities for high standards of design for efficient water usage and re-use, and multi-functional blue-green infrastructure.”

Specific ways in which future development must meet these objectives are anticipated to be agreed with GCSP through the development of the general and site specific local plan policies.

In light of the overarching objective of preventing or reducing carbon emissions, and mitigating against the impact of climate change, it is clear that development which clearly promotes, and effectively encourages, the use of public transport, particularly where there is direct access to rail services in particular should be supported. The current development strategy delivers new development in the north of the Greater Cambridge Area but fails to maximise the opportunities for sustainable development in the southern areas where the areas in close proximity to public transport links are not allocated for growth.

Climate change is one of, if not the, biggest challenges facing us all. The aim to “Help Greater Cambridge transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use, and is resilient to current and future climate risks” is supported.

We support the proposed policy direction. The policy direction should apply to the delivery of new floorspace only. The policy should also allow for viability considerations, as not all developments will be able to meet other requirements and obligations required by the emerging Greater Cambridge Local Plan.

Focusing development on the edge of Cambridge in immediate proximity to employment and to planned public transport improvements is demonstrably the best strategy to enable growth to take place consistent with climate change objectives. At Cambridge South, comprehensively planned development would have the additional benefit of integrating social, recreation, retail and support facilities to reduce the need to travel. The opportunity exists to plan an exemplary urban extension.

The RSPB supports the approach set out to climate change and the role the local plan can make in reducing carbon emissions within the Greater Cambridge area. It is imperative that new development that will be in place for decades or even hundreds of years embodies net zero design, in locations which will enable non-fossil fuel transport provision. We fully agree that new development also needs to be fit for purpose to deal with the climatic conditions that will be present in its lifetime and to not be at risk of, or exacerbate, future flooding. Nature-based solutions, where habitat creation and retention helps mitigate carbon emissions are also an important element, which highlights the overlap between the climate change and biodiversity policies in the plan.

We need resilient food systems that are fit for a changing climate. We support regenerative and agro ecological farming and we prioritise local, seasonal food that is good for the planet. Our local plan should reflect this need through,
• designating space for small scale vegetable and fruit growing, either as a tenanted farmer, community supported agriculture or on the model of CoFarm
• provision of allotments, a community garden and orchard
• A market place and encouragement for local growers to have an outlet for their produce in order to support access to local fresh produce

Grosvenor supports these policies which are consistent with their objectives to achieve:
Zero carbon - By 2030, Grosvenor will achieve net zero carbon from its buildings, developments, and supply chain.
Zero waste - By 2030, Grosvenor will send zero non-hazardous waste to landfill from its buildings and developments under its control.
Valuing nature - By 2030, Grosvenor’s portfolio will have achieved a significant net biodiversity gain, NBG, responding to the need to restore ecosystems.
Proposals at Whittlesford would provide 300 Net Zero homes and a NBG, making a positive contribution to reducing CO2 emissions and nature recovery.

During its meeting in November, Great Shelford Parish Council declared a climate emergency. With this in mind we wish to ensure that exemplar environmental practices are used from the outset, our biodiversity is protected and our sustainability increased.

We support the policies seeking to create more sustainable communities and places, and request that the NHS is supported in seeking to deliver more sustainable facilities and services to meet the needs of the population.

Cambourne Town Council supports the theme as it addresses the aims contained in the vision.

We are concerned that growth remains a priority in the plan when in order to counter climate change we actually just need to consume less and build less. Zero emissions should be the target rather than carbon neutrality which allows for pollution as long as there is a counter balance.

Support for the climate change policies. The Cambridgeshire and Peterborough Independent Commission on Climate, set up by the Combined Authority, has set out the climate challenges and opportunities facing the area. It noted that growth is compatible with climate change objectives, provided that appropriate action was taken on how that growth was delivered. The suite of policies in this section of the Plan show a clear path to reducing emissions from new developments, and making sure that they are resilient to future climate events.

WATER
Cambridge and its surrounding area are already experiencing water scarcity and over-abstraction of our rivers as a result of excessive development in the region. We are concerned by the way Cambridge City Council and South Cambs District Council are promoting house building at levels that exceed already-inflated government targets and that will have destructive effects on the river system.

The surge in the population of Cambridge and surroundings is already contributing
to a water crisis with the depletion of precious chalk aquifers which feed the Cam, Ouse and their tributaries, and insufficient water for farmers. The chalk streams are increasingly polluted by industrial waste, and runoff from agricultural and nonagricultural pesticide-use, and are also drying up. The proposed development, with its excessive targets to build homes, will exacerbate these problems.

The Environment Agency has requested that water companies and farmers reduce abstraction and it encourages more efficient use of water. Moreover, it maintains that any further growth will harm the environment. It says there is insufficient water to supply the existing population, let alone an expanded one. The Integrated Water Management Study, the Stantec Report, found that that low, medium and high regional growth scenarios all have a deleterious impact on the river system. To fill ‘the water gap’ it is proposed that water be transferred, by building new infrastructure (which itself will generate substantial carbon emissions), from areas which are already losing jobs and people to the Cambridge area. This would draw another resource from areas from which jobs and people are migrating. Surely it is better to encourage jobs in and movement of people to the places where the water and houses already exist?

The local plan makes no reference to the provision of sustainable water supplies, reduced flood risk and effective waste water treatment; these should be established as baseline conditions for any new development.

Shepreth Parish Council (SPC) is pleased to see sustainability at the heart of the local plan. Water supply and overburdened infrastructure have been ignored for too long.

Countryside fully supports the strategic commitment by the GCLP to positively address the issue of climate change mitigation and adaptation within the plan period and welcome the opportunity to comment on the draft policies to ensure they evolve to meet the tests of soundness and are both deliverable and viable whilst supporting the delivery of much needed high quality, private and affordable homes within Greater Cambridge.
Bourn Airfield already benefits from a recommendation for outline planning permission and is supported by a strong sustainability strategy that deploys extensive renewable energy technologies across the development.
Countryside supports the emphasis placed on responding positively and proactively to climate change in the Greater Cambridge Local Plan (GCLP). This aligns closely with Countryside’s own ambitions for their business operations and future development sites.
Countryside recognises the recently published findings by the International Panel on Climate Change (IPCC), which makes clear that the chances of crossing the global warming level of 1.5°C in the next few decades is likely unless immediate, rapid and large-scale action is taken.
To ensure Countryside plays its part, the company has recently published its Corporate Strategy ‘Path Finder – Marking Out the Route to Net Zero’ which sets out the company’s strategy to achieving net zero. As part of this strategy Countryside have set science-based carbon targets which have been verified by the Science Based Carbon Institute, and are to:
• Reduce our absolute Scope 1 and 2 emissions by 42% by 2030
• Reduce our Scope 3 emissions by 52% per sqm built by 2030
The GCLP Plan, and its emphasis on climate, will also play a very important role in meeting the challenges put forward by the IPCC. It is important to note that in meeting its net zero ambitions, one of the most important steps that the GCLP can take is to ensure that its spatial distribution strategy directs growth to locations that are sustainable and help to facilitate reductions in GHG emissions by reducing the need to travel by private car for work and leisure.
As a general theme, Countryside support the strategic objectives of the policy but note that the targets presented within the GCLP will introduce some of the highest sustainability standards in the UK at a time when the housebuilding industry is already responding at pace to the introduction of the Governments Future Homes Standard.
Given the volume of new homes required within Greater Cambridge there is a risk that the introduction of these standards will restrict the delivery of new homes particularly given that the supply chain is currently not able to deliver these standards at volume. These challenges will also be particularly acute for smaller housebuilders which may further restrict delivery and diversity within the market.
Whilst Countryside note the ambition of the GCLP, it is important that the sustainability policies do not restrict the delivery of much needed new private and affordable housing across the county. To meet the requirements of the National Planning Policy Framework, these policies must be supported by a robust evidence base and viability assessment that demonstrates these policies and targets are deliverable.
Countryside have reviewed each of the draft policies within the climate change section of the GCLP and have provided representations for each policy which we hope is of assistance to the Greater Cambridge Shared Planning authorities. Our focus is to ensure that each policy is both viable and deliverable whilst facilitating a shared objective of delivering more high quality affordable and private homes in an area with current and growing demand.
Where necessary these representations make reference to the GCLP Climate Change Topic Paper which summarises the evidence to support each of the policies and is hereafter referred to as the Topic Paper.
For draft Policy CC/ NZ, we have also reviewed the evidence base supporting these specific policies which is the Greater Cambridge Net Zero Carbon Evidence Base Non-Technical Summary and which is hereafter referred to as the Evidence Base document. Unfortunately a more detailed review of the full evidence is not possible as only the non-technical summary has been published and therefore Countryside reserve the right to amend our representations once this material has been reviewed.
Countryside welcome the opportunity to comment on these draft policies and would be happy to discuss our comments in greater detail with the authorities. We also recognise that these are currently policy options which will be informed by consultation feedback. Countryside look forward to reviewing the next iteration of the draft GCLP.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.