GP/HA: Conservation and enhancement of heritage assets

Agree with the policy in general, however, the scope is not wide enough. it appears to be restricted to development being required to demonstrate how it provide service or enhances the significance of the heritage at assets of the girl greater Cambridge however it it appears to concentrate on heritage sites in the city without reference to some of the protected conservation areas in villages, e.g those of Fen Ditton, Horningsea, and Baites Bite Lock. see greeted Cambridge green infrastructure opportunity mapping: baseline report; LUC/South Cambridgeshire District Council and Cambridge City Council, November 2020.
figure 6.2, cultural heritage, Page 48 - map shows conservation areas are listed the buildings in circling the proposed site of the CWWTP on greenbelt which appears to negate the policy.

Support

This policy states : ‘Development will be required to demonstrate how it preserves or enhances the significance of the heritage assets of the Greater Cambridge, their setting and the wider townscape, including views into, within and out of conservation areas.’
Relocation of CWWTP to Green Belt is in contravention of this policy. Views within and out of conservation areas (Horningsea, Quy and Fen Ditton) will be damaged. See ‘Greater Cambridge Green Infrastructure Opportunity Mapping: Baseline Report’, LUC/South Cambridgeshire District Council & Cambridge City Council , November 2020,
Greater Cambridge Green Infrastructure Opportunity Mapping Baseline Report (Land Use Consultants) November 2020 (greatercambridgeplanning.org)
Fig 6.2, Cultural Heritage, p46 - this map shows conservation areas and listed buildings encircling the  proposed site of the CWWTP on the pristine Green Belt  between Fen Ditton, Stow cum Quy and Horningsea.
Other heritage assets and conservation areas such as Biggin Abbey, Baits Bite bLock, Anglesey Abbey may have reduced enhancement due to odour and proximity of commercial development.
Size of the development, height of the development, industrial nature of the development dwarfs heritage assets. Impact intensified by open nature of the landscape between the conservation areas.

The underpinning Strategic Heritage Impact Assessment considers 8 strategic spatial options across 3 potential growth levels:
https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/StrategicHeritageImpactAssessment_GCLP_210831.pdf
The report clearly indicates development for the Green Belt spatial option to represent Moderate/High risk for the medium growth option and classifies this option among the least preferred.
The subsequent Impact Assessment Supplement which further refines study focus on the Medium growth level establishes a Preferred Options Spatial Strategy as being the best performing:
https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-08/StrategicHeritageImpactAssessmentSupplement_GCLP_210831.pdf
While the assessment documents, along with the initial baseline study, offer a methodical approach to the assessment, they are fundamentally flawed as they do not consider the consequential land take required for relocation of the Waste Water Treatment Plant (WWTP) currently proposed for the Green Belt.
In order to deliver the intent of the Local Plan in considering land allocation, use and forward planning these assessments should be reconsidered taking into account the consequential Green Belt land take associated with the North East Cambridge development / WWTP relocation and re-classified accordingly.

West Wickham Parish Council support the policy direction, especially with reference to conservation areas, local heritage assets and archaeology.

The recent experience in conservation areas such as Barrow Road has resulted in the Trumpington Residents' Association being concerned about the way in which rebuilding and densification can have a negative impact on a conservation areas. The current policy should be reviewed to give greater control over significant changes within a coherent area.

A priority is to update Conservation Area Appraisals, using planning experts and community forums.
A priority is to have a full set of Conservation reports on Approach roads from all directions into the City of Cambridge and major towns and villages in County.
Please cross ref West cam site for example.

Abrdn acknowledges and supports the aims of proposed policy GP/HA. Abrdn also acknowledges that in some cases, new development or redevelopment can enhance heritage assets and requests that this is recognised in the policy.

Huntingdonshire District Council has no comment on this matter.

CWWTPR to Green Belt compromises this policy. Significant impact to heritage assets. Green Belt separating conservation areas, extensive numbers of important listed buildings including St Peter's Church and Biggin Abbey. Totally inappropriate industrial development at this location, blighting views from network of PRoWs and views to the villages and into Cambridge.

Relocation of CWWTP to Green Belt contravenes this policy. Views within and out of conservation areas (Horningsea, Quy and Fen Ditton) damaged.
Greater Cambridge Green Infrastructure Opportunity Mapping Baseline Report (Land Use Consultants) November 2020 (greatercambridgeplanning.org) Fig 6.2, Cultural Heritage, p46 - conservation areas and listed buildings encircling proposed site of CWWTP on pristine Green Belt between Fen Ditton, Quy and Horningsea, including Biggin Abbey, Baits Bite Lock, Anglesey Abbey.
Size, height, industrial nature of relocated WWTP dwarfs and harms setting of heritage assets. Impact intensified by open landscape.
No assessment Greenbelt landtake relied on to move WWTP for NEC.

Supported : Note- Fulfilment of S/NEC Policy through relocation of CWWTP to Honey Hill is contrary to this Policy

We support this policy. The policy should not only include listed buildings but also those recorded on Cambridgeshire's Historic Environment Record. Conservation areas should be respected and maintained per SCDC policy NH/14.

Local Geological Sites and Geological SSSI often have a historic and heritage aspects. These should be included in the assessment

Coton Parish Council is concerned that the heritage aspects of the setting of the American Cemetery are being ignored by the GCP and quote the words of the superintendent of the American Cemetery spoken at the Greater Cambridge Partnership Executive Board.
"The Madingley Hill landscape is a place of beauty that has been valued by many generations and is worthy of preservation. Its stunning viewshed extends north towards Ely Cathedral, east towards King’s College Chapel, south over Red Meadow Hill, and beyond; with the picturesque villages of Coton and Madingley nestled either side.

I support the proposals which exclude any development in the area of Little Linton.
The settlements of Linton and Little Linton have historically had distinct identities. New development in the area would disrupt the historic open landscape, destroying the separation and damaging the individual character of each settlement. Land in this area is a valuable environmental resource, which should be protected.
I support the retention of the land between Little Linton and Linton within the designated countryside.
The direction of future development to other more sustainable locations is appropriate and will ensure that Little Linton and Linton retain their identity.

I support the proposals which exclude any development in the area of Little Linton.
The settlements of Linton and Little Linton have historically had distinct identities. New development in the area would disrupt the historic open landscape, destroying the separation and damaging the individual character of each settlement. Land in this area is a valuable environmental resource, which should be protected.
I support the retention of the land between Little Linton and Linton within the designated countryside.
The direction of future development to other more sustainable locations is appropriate and will ensure that Little Linton and Linton retain their identity.

The major existing University developments at Eddington and West Cambridge, which are proposed for acceleration, have significantly changed the character of North Newnham. They represent removal of large areas of open space, with consequent effects on water management and dense urban development on the edge of the West Cambridge Conservation Area. Given this context, maintaining and strengthening Conservation Area policy protection is even more important to preserve The West Cambridge Conservation Area from inappropriate development which would damage its characteristics. Future development proposals could adversely affect the special character of the Conservation Area. Policy 67 does not afford sufficient protection.

I support the proposals which exclude any development in the area of Little Linton.

The settlements of Linton and Little Linton have historically had distinct identities. New development in the area would disrupt the historic open landscape, destroying the separation and damaging the individual character of each settlement. Land in this area is a valuable environmental resource, which should be protected.

I support the retention of the land between Little Linton and Linton within the designated countryside.

The direction of future development to other more sustainable locations is appropriate and will ensure that Little Linton and Linton retain their identity.

I support the proposals to build at existing and forthcoming towns and larger settlements that exclude any development in the area of Little Linton.
New development in this area would disrupt the historic open landscape, destroying the separation and damaging the individual historic character of each settlement. Land in this area is a valuable environmental resource, which should be protected.
The direction of future development to other more sustainable locations is appropriate and will ensure that Little Linton and Linton retain their identity.

I support the proposals which exclude any development in the area of Little Linton. The settlements of Linton and Little Linton have historically had distinct identities. New development in the area would disrupt the historic open landscape, destroying the separation and damaging the individual character of each settlement. Land in this area is a valuable environmental resource, which should be protected.
I support the retention of the land between Little Linton and Linton within the designated countryside.
The decision of future development to other more sustainable locations is appropriate and will ensure that Little Linton and Linton retain their identity.

Support the policy aims here.
With the densification of development in Cambridge and pressure for development on vacant sites, including green sites of visual and other amenity and environmental value within the city, the importance of effective Conservation Area policy protection is ever more important to preserve those areas from inappropriate development which would damage the characteristics of the Conservation Area which the designation was made to preserve. This may require updating Conservation Area Appraisals.

Policy GP/HA is supported in principle, noting that the underpinning Heritage Assessment clearly shows development for the Green Belt Spatial option at medium growth as a Moderate / High risk.
There appears no reference to the corresponding Green Belt dependency for Policy S/NEC, which therefore appears selective and should be considered more fully in the study for the options relating to S/NEC.

USS acknowledges and supports the aims of proposed policy GP/HA. USS also acknowledges that in some cases, new development or redevelopment can enhance heritage assets and requests that this is recognised in the policy.

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!

Gog Magog and the chalk hills are heritage assets.
Protecting public access to heritage assets encourages better well-being and the more assets encourages public rights of way including permissive footpaths.

Heritage conservation is fundamental to the National Trusts’ charitable purposes and the National Planning Policy Framework correctly establishes a very high threshold for new development to pass in historic places.

We are pleased to see acknowledgement of Cambridge’s historic environment, including the Wimpole Estate which is owned and managed by the Trust.

The National Trust understands that major infrastructure proposals lie outside the local planning authority’s consenting powers, however Local Plan policy should ensure that it establishes the highest possible safeguards for the protection of all heritage assets, historic places and important landscapes.

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.

This is critically important.

FORM RESPONSE

Vision and development strategy
Section / Policy Your comments
Vision and aims
How much development, and where – general comments Support the approach to contain any development to major clusters.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support Steeple Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support tightly drawn development boundaries are important to reduce encroachment into the countryside and particularly for linear villages protecting their character. Also assists in delivering exception sites.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity so do we have an obligation to consider where we might generate this locally? There should be clear comments on how and where solar PV farms and windfarms are going to be planned
CC/NZ: Net zero carbon new buildings Should not be specific about not connecting a gas pipe to new housing. This might prevent the future distribution of Hydrogen. Should keep this option open
CC/WE: Water efficiency in new developments Absolutely necessary.
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation. Especially managing hard surface run off.
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding.
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedialaction if required.
BG/GI: Green infrastructure Support for recognition of Pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support particularly providing enhanced protection to existing mature trees.
BG/RC: River corridors Support Steeple Morden has an important tributary of the Cam flowing through the Parish – The Rhee. There should also be recognition enhancement and protection for the brooks which emanate from the aquifer spring line and help feed the river system.
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety Support

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character particularly those villages with a predominantly linear form.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support Need to complete Conservation Area Assessments for villages
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support but condition included that if part of Pub is agreed for another use the marketing policy remains.

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Strongly support particularly in the light of grade I peat soil requiring remedial action and the need for increased food security.
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support but would stress the importance of ensuring that structures are sound.
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support and encouraged where there is no conflict with exception site policy.

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.

Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff from hard surfaces to minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but Improvements required to rural public transport and the last mile congestion into Cambridge City.
I/EV: Parking and electric vehicles Support for rural public charging points at community facilities
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support. Should also include disused railway lines with potential for future use.
I/AD: Aviation development Airfields are an important resource and difficult to replace. Local Plan should recognise the need for National Network of General Airfields.Government National Planning Policy Framework section 106.f, to ensure that planning decisions have regard to the importance of the national network of General Aviation airfields is clear. Environmental health concerns should be taken into account when deciding on housing location to avoid new occupants stress, disappointment and possible conflict.
I/EI: Energy infrastructure masterplanning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Supporting documents on which we are consulting
Policy Your comments
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)
Habitats Regulations Assessment

Firstly, the Form To Assist gives a comment column for Vision and Aims.
We have numerous comments to make under this heading but I have not been able to locate this on the online system.
Secondly, the online system asks "Did you raise the matter that is the subject of your representation with the LPA earlier in the process?"
Guilden Morden Parish Council have not been involved earlier in the process. I have therefore clicked "No" but the system will not allow me to proceed further.
The online system allows only 100 words for each comment and to summarise the comments to avoid exceeding 100 words. It would have been helpful if the Form To Assist had stated that.
Vision and development strategy
Section / Policy Your comments
Vision and aims 1.Guilden MordenParish Council has concerns that the increase in population resulting from the additional homes target of 44,000 will have a negative impact on an already struggling traffic, school and healthcare infrastructure.
Specifically on traffic and congestion:
Commuting into and out of Cambridge at peak times already attracts significant congestion and delay for commuters.
This not only effects commuting by car but also bus and the Park&Ride buses as these typically use the same roads as the other commuters and the bus lane network doesn’t extend to where it’s needed.
Links between the train stations and the city centre are also currently inadequate and equally effected by commuter congestion.
The guided busway is too infrequent to be a viable alternative and typically the Park& Ride parking is at capacity leaving commuters with little alternative other than to drive into the city centre.
All of the above describes the current situation which will clearly be significantly worsened by the addition of 44,000 homes by 2041.
2. Is the methodology used in arriving at the figure of 44,000 defendable?

How much development, and where – general comments Support that the proposed developments are to be in major clusters in areas with good public transport.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support. Guilden Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support. Tightly drawn development boundaries are important to reduce encroachment into the countryside.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity. Where might this be generated locally by solar and/or wind?
CC/NZ: Net zero carbon new buildings Support
CC/WE: Water efficiency in new developments Absolutely necessary
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedial action if required
BG/GI: Green infrastructure Support for recognition of pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support
BG/RC: River corridors Support
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Support
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.
Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff fromhard surfacesto minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but improvements required rural public transport and congestion into Cambridge (see comments under Vision and Aims)
I/EV: Parking and electric vehicles Support
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support
I/AD: Aviation development Support
I/EI: Energy infrastructure master planning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.