S/OA: Opportunity areas in Cambridge

Broad support for housing at the identified sites. Huge car parks are a waste of space. Newmarket Road Tesco site seems under utilised. Please consider passivhaus standards and more green spaces, smaller shops incorporated into the design

Very concerned to see the north area of St Matthew's Piece and the allotments on New Street are identified as 'opportunity areas'.

As protected open spaces there should be no question of any 'opportunity' to build on these valuable green spaces.

For the avoidance of doubt these areas need to be removed from the classification of an 'opportunity area' and re-classified as untouchable protected open space for the health and well-being of the local community.

Old fashioned/outdated areas should be developed to their full extent.

We agree with the proposals.

(Education) The Council is supportive of the objective for the Opportunity Areas in Cambridge. The new Opportunity Areas, S/OA/NR (Newmarket Rd Retail Park) and S/OA/BC (Beehive Centre) both fall within the St. Matthew’s Primary School catchment. St. Matthew’s is a restricted site. Whilst the existing school cannot expand any further to mitigate any potential children from potential housing in the OAs, the intention to ‘improve…infrastructure delivery’ in the OAs could enable longer-term solutions for the school’s needs, e.g., new-build and relocation as part of the holistic approach outlined.

Huntingdonshire District Council has no comment on this matter.

The department notes that existing opportunity areas are being carried forward from the existing local plans and two new ones are being created at Newmarket Retail Park and the Beehive Centre. We welcome the recognition that the urban retail landscape is changing and these sites present an opportunity to reimagine these places close to the heart of Cambridge. Please consider education among the potential suitable uses within these areas, subject to other criteria such as active and sustainable travel. Education development can be a complementary use which increases footfall in retail areas that may be struggling to remain viable.

The plan states that there is already sufficient land assigned for job creation. Where is the evidence that this land is in the right place for that development to proceed? We note the Business park to the North of Waterbeach on the A10 is still only partially occupied several years after it was opened: many businesses consider the location that far out of Cambridge to be unacceptable..

It is proposed to continue to identify the Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area. Land south of Bateman Street continues to fall within this opportunity area.

Trinity Hall supports draft Policy S/OA and the proposal to carry forward the Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area to the emerging Greater Cambridge Local Plan.

Trinity Hall is also supportive of the proposed policy direction, in particular the drive to deliver public realm improvements. The opportunity that Land south of Bateman Street can provide in terms of an improved public realm along Hills Road should be particularly recognised in future policy wording. The Policy should explicitly attach positive weight to a development that helps to meet the aims of the Opportunity Area policy.

With reference to the Abbey Stadium Opportunity Area (Policy S/OA site AS):

If it should eventually be decided that this site is to be used for housing, as well as if additional housing is provided on the site whilst retaining the existing use, then I would like to suggest that no more access routes be created into the site, ie that the existing access routes from Newmarket Road and Cut Throat Lane continue to be the only access routes to the site.

This is because this should continue to provide sufficient access to the site for both possible future uses (ie all housing and part housing/ part continued stadium use) and because it would therefore be unnecessary to provide access onto Elfeda Road, particularly as that might potentially involve the destruction of one or two 1930s houses and would involve unnecessary increased disturbance to residents of Elfleda Road and Whitehill Road.

Map Fig 17: shows Existing and Proposed allocations outside this broad location, including North East Cambridge covered under Policy S/NEC.
It is noted that the corresponding Waste Water Treatment Works relocation process set out in Policy S/NEC is being led by Anglian Water under a separate process. However, map Fig 17 should also display for reference the proposed relocation site for the Waste Water Treatment Works in a similar manner to the NEC area, to provide proper context for the S/NEC Policy in terms of future land use and corresponding Green Belt cost, or neither until the DCO is approved.

Any examination of the Retail Park and Beehive must make note of the fact that

* Many of the retail stores here are very popular and full at weekends
* The Beehive in particular has facilities such as the private gym with a swimming pool, facilities that are in key demand around cambridge

Any prioritisation of the Newmarket Road area should focus on
* Improving public transport links to these areas
* Focusing on the further retail park elements (e.g. the stores nearer Abbey from DFS to roughly Argos area) as these are less busy for footfall
* Be mindful of the social and leisure elements in the Beehive that would be lost to the community if replaced by housing

Representation to Greater Cambridge Local Plan – First Proposals
Submission by Savills (UK) Limited on behalf of Grosvenor (Britain and Ireland)
Policy S/OA/AS Abbey Stadium
Savills (UK) Limited are instructed by Grosvenor (Britain and Ireland) to make relevant and necessary representations to the Greater Cambridge Local Plan – First Proposals document which has been the subject of consultation.
The publication of this document reflects the work done to date in respect of a new joint Local Plan for both Cambridge City and South Cambridgeshire District Council. A new plan that covers both administrative areas reflects an acknowledgement of the clear symbiotic relationship that exist between the two Council areas since it is the case that the City remains a focus for many South Cambridgeshire residents who continue to look to the urban area for their employment, retail , leisure and recreation needs.
Accordingly, the joint approach for a plan for the wider area around Cambridge is supported and this is particularly relevant having regard to Grosvenor’s property interests in the Abbey Stadium on Newmarket Road and the future of Cambridge United Football Club either remaining in situ or relocating to an alternative location within the Plan area. It is entirely appropriate that the emerging spatial planning policies of any new review should be contained within one single document. To that end we support the need for a review of the currently adopted two Local Plans and the submission of these representations should be seen in that context.
On behalf of our client, we have made previous representations to the Call for Sites consultation in Spring 2019 which sought to engage with the Council in respect of finding a long term solution for the future for the football club, its supporters and the City as a whole.

Current location and character
The Abbey Stadium is located off and to the south of A1303 (Newmarket Road), immediately to the north-east of Cambridge Retail Park and Cambridge City Inner Ring Road. The site has an area of some 2.58 hectares. It is bounded by the A1134 Newmarket Road to the north, residential properties to the east, the City Council owned Whitehill Road allotments to the south and Coldham’s Brook and Coldham’s Common to the west.
Abbey Stadium was reportedly built in 1923, with its first match being played in 1932. The current capacity of the Stadium is understood to be just over 8000 with just over 50% seated. It has four single tier stands; the North (Newmarket Road End) and West (Habbin) Stands being all terraced and the Main (East) and South Stands being all seated. The South Stand is understood to have been built in 2002 with the other three stands having been built in, or before, the 1960s. Accordingly, it is the case that all of the stands, with the exception of the South Stand which opened in 2002, have exceeded their useful life. Between the North Terrace and Newmarket Road is a portacabin-type structure which houses the Club’s ticket office and shop. To the west of this structure is an area of car parking capable of accommodating approximately 35 cars and an area of cycle racks (40 Sheffield Stands). The Cambridge United Supporters’ Club (CUSC), which includes a bar and social space, is located at the northern end of the ground. On the eastern side of the Stadium is an area of car parking, capable of accommodating approximately 122 cars. Vehicular access to this area of car parking is gained from Cut Throat Lane – an unmade track around 80 metres to the east of the main site entrance The site also contains a single storey garage to the rear of 535 Newmarket Road. The Club is currently in League 1 having been promoted in 2020/21 and having played in League 2 for several years– it was in the Conference League between 2005 and 2014. The Club is supported well locally and is the largest single supported regular sporting fixture in the City during the season.
Regarding the wider site context, the site clearly falls with the built up area of the City with the site bordering the Whitehill Road allotments to the south of the site. The site lies immediately north and to the east of Coldhams Brook and the wider area of Coldhams Common lies further south and west. The most immediate built environment around the site is given over to residential development with some commercial properties on the street frontage.

Content of the Greater Cambridge - First Proposals as it relates to the Abbey Stadium
Page 65 of the document identifies the Abbey Stadium in Figure 20 as an “Opportunity Area in Cambridge” under Policy S/OA. As such it is identified as one of 4 new “Opportunity Areas” “that would benefit from a holistic approach to any future development that comes forward, to provide policy guidance for development that also improves public transport access and infrastructure delivery, and seeks improvements to the public realm.” (page 62)
Grosvenor support this approach since it acknowledges the important role that this site can play to deliver new development in a key corridor leading into and out of the City. In such a context the site may be able to deliver a mix of uses together with multiple functions and the identification of the site under this policy provides a necessary framework to promote change.
Figure 20 on page 65 of the consultation document identifies the red edge boundary for the Opportunity Area which generally corresponds with the boundary submitted to the Councils back in March 2019 as part of the Call for Sites response (there is a small anomaly in the south east corner where further land should be included with the red line on Figure 20).
The supporting wording to Figure 20 as it relates to “S/OA/AS Abbey Stadium” states :
“The Abbey Stadium is home to Cambridge United Football Club. The club is keen to improve its facilities to raise its profile as a commercial sporting enterprise. It could achieve this aim by either staying on site and securing enabling development on site alongside an enhanced stadium facility or by relocating elsewhere and redeveloping the existing site for new homes. The draft plan will provide guidance for this site for both possibilities.”
Whilst we support the site’s identification as a proposed opportunity area, there is no expression as it relates to the long term views of the Councils in terms of either the Club staying on site and securing enabling development or relocating elsewhere and redeveloping the existing site. We fully accept that there is an important need to develop a planning strategy and in such a context we welcome the text which states that “the draft plan will provide guidance for this site for both possibilities”.
We read this text as constructive in so far as it states that both redeveloping in situ or relocation are both possible and this will be part of the ongoing discussions with the Councils as part of this Local plan review.
Greater Cambridge HELAA (2021)
In this context where redevelopment of the site is possible, we note that the Abbey Stadium is referenced as site 40123 and is identified in the Councils Greater Cambridge HELAA (2021), Appendix 4: Proformas for all HELAA sites (Part A). The site is summarised in that HELAA work as “red” in terms of its suitability and then green in terms of its availability and whether it is achievable. The methodology and the use of traffic light is a crude approach to site suitability since a single “red” as it relates to open space/green infrastructure has meant that the site is “unsuitable” (according to page 22 of the HELAA report).
The Comments part of the HELAA assessment as it relates to Open Space/Green infrastructure states the following:
“Within or Partially within an Outdoor Sports Facility
Within 50m of a Semi-Natural Green Space
Within or Partially within Protected Open Space
Within or Partially within Country Park - Parks and Gardens
Abbey Stadium is protected open space. Its loss will impact on formal sports provision for Cambridge United FC. Alternative site needed, or for a scheme to demonstrate how the use will be retained”
There is no dispute that the playing pitch is identified as “Protected Open Space” in the current adopted Local Plan but equally, it has been made very clear by Grosvenor that the loss of the playing pitch (and its open space qualities) would only occur in the event that relocation take place. Both options (redevelopment on site and relocation) would require the provision of the playing pitch. The reference to “its loss will impact on formal sports provision for Cambridge United FC” is misleading and seems to totally miss the point about following one of two options , both of which would not result in a “loss” to the Club . Consequently we cannot understand why the conclusion to this element is red within the HELAA and should in the circumstances be changed to “amber”. Indeed, the Council approach is further confused by the fact that the site is then identified under Policy S/OA above as a “Opportunity Area in Cambridge”

The case for options for redevelopment/relocation
The Club has been actively looking at plans to relocate / redevelop without success for over a decade in the context of an ageing stadium, currently near the end of its life and which is not suitable for a club with ambitions to play at the current level, let alone to play in higher leagues. The current capacity is a little over 8,000 with standing on two sides.
The freehold of the site is mostly in the ownership of Grosvenor who acquired the stadium in 2010 and have been working jointly with the Club to assess the potential for either redeveloping the existing stadium or considering options to relocate the stadium to an alternative site. The Supporters Club own the freehold of a part of the frontage, where the Supporters Club is sited and the City Council own the freehold upon which the away supporters stand sits. The Football Club has a lease with Grosvenor for the stadium which has some 34 years remaining and has been unable to make its full rental payments under the lease.
It is critical that a long term solution for the Football Club is identified and in such a context the Supporters Club are continuing to cooperate in finding a solution to the redevelopment of the stadium. Regarding the promotion for the redevelopment of the existing Abbey Stadium to provide for a new stadium facility alongside uses which can assist in paying for such proposals, it is the case that such an option must be viable, suitable , available and deliverable. Viability is of course a key issue and in the event that a redevelopment option is pursued which looks to retain a playing pitch on the site then we would hope that the Councils would support a site specific case for redevelopment of the site which would enable a viable scheme being put forward. In such a context the Council has the ability to draft a site specific policy and allocate the site for development and to set out the circumstances which it sees as relevant to a particular situation where there is the potential of reducing obligations on the site to ensure the redevelopment of the site and importantly to provide the long term security for the football club in this location. It is entirely appropriate for the Council to take such a policy stance should it decide to do so and we urge the Councils to grasp this opportunity in the context of this Local Plan review.
Given that the Plan states that “The draft plan will provide guidance for this site for both possibilities”, the Council should also provide a policy context whereby it looks at the relocation of the football stadium to an alternative site. The effect of this approach is to consider new greenfield sites including land currently designated as Green Belt. In any major review of the Local Plans, it is entirely appropriate that the adoption of any development strategy should consider the location of future growth must involve a strategic review of both the inner edge and outer edge of the Green Belt. The future of the Football Club must therefore be seen in this context.
At the Call for Sites stage back in March 2019 we set out a number of important factors which would be considered as beneficial from the planning perspective should such a strategy be pursued. They are outlined again for the purposes of this consultation:
In no order of priority these are identified as follows:
1. Moving the football stadium to an alternative location would result in making the current Abbey Stadium site available for new development which could include the provision of new housing and community infrastructure. The site constitutes previously developed land is located in a highly sustainable location within the City
2. A new stadium in an alternative location could be designed to accommodate other uses – not only community sports facilities but also, e.g. a conference centre and concert space and thus have a wider community function
3. Dependant upon the new location, access to a new stadium could be much improved over the existing site and thus potentially easing congestion and improving air quality in the Newmarket Road environs.
4. The Club would not have to temporarily relocate from the Abbey Stadium in the circumstances that a new related site was coming forward (which would be the case with redeveloping the Abbey). A season away from playing at the Abbey Stadium would pose a significant financial risk to the Football Club.
5. A relocation site would ideally be nearby in order that the Football Club could remain in the Abbey/ Barnwell area which would be beneficial for local employment, leisure and business and bring social benefits through the work of the Community Trust who would continue to focus the majority of their efforts on those areas of greatest need.
6. A new location would allow The Club to elevate their ambitions much further as a model community club through a genuine purpose built community facility, potentially open 24/7 all year round serving all sorts of different community needs. This presents an exciting opportunity to explore with the Councils and wider stakeholders exactly how that vision could be realised.
7. The stadium could be designed in a way to be able to grow with the progress of The Club.
8. The opportunity to secure a new greenfield site would mean a new start for the Club in masterplanning and layout terms and introduce the potential to create a modern 21st Century stadium with the necessary facilities alongside that befits the Club and the City as a whole.
Closing comments
The above comments are made to the consultation document in order to ensure that the Plan is moving forward in a manner that properly addresses the issue of the long term future of the football club. The two options (redevelopment and relocation) would appear to have been acknowledged in this document but without a clear policy picture of what strategy is being pursued to accommodate both possibilities. The new Local Plan has the ability to address the issue and the identification of the Abbey Stadium as an “Opportunity Area” is certainly welcomed whilst acknowledging that such a designation is inextricably linked to the need to find a solution to the future location of the club either on site or in an alternative location.

It is unclear why the Old Press Mill Lane site is identified both as an ‘Opportunity Area’ and as a site allocation.

S/OA/NR Newmarket Road Retail Park
S/OA/BC Beehive Centre
Cambridge Past, Present & Future strongly supports the inclusion of these two new opportunity areas. Combined, they include some 25 acres of surface parking. If a multi-storey car park was built on a small portion of this land, some 20 acres could be released for development. Cambridge Past, Present & Future submitted an outline proposal for the re-development of the car parking area on both sides of Coldhams Lane during the public consultation for the 2018 Local Plan. This showed how the site could accommodate 1200 dwellings with only a marginal loss of car parking space through the provision of a multi-storey facility and by allowing parking beneath the residential blocks which were raised on columns.

When progressing the development opportunities for these sites, access to green space must be included in any schemes.

We also request that you include an adjacent area as part of these two New Opportunity Areas and this is marked in orange on the diagram attached.
There are two reasons for requesting for this inclusion:
1. It is a similar land use to the other two areas and in the same location and therefore the same principles apply.

2. We have seen a number of planning applications coming forward in this area. These are being dealt with on a piecemeal basis with all the associated problems of piecemeal development. This is not an area of high quality design and is negatively impacted by Newmarket Road. A strategic planning approach is required to ensure that any planning applications contribute towards improving public realm and the overall improvement of the area.

No comments

Please see additional planning commentary.

S/OA/CH Inclusion of Castle Park within the Opportunity Area is supported.
The text only references Shire Hall/Castle Mound but the OA covers a wider area including Castle Park with considerable differences in scale, character and uses and multiple ownerships. Guiding principles for development are appropriate but should accommodate different design challenges.
Policy should not be overly restrictive and include flexibility to:
• allow for improvements/enhancements of buildings and spaces and redevelopment, to be brought forward in different parts of the OA on different timescales;
• make the best use of existing buildings/infrastructure;
• encourage a creative approach to enhancing identity.

I agree that Abbey Stadium is a great opportunity for sustainable development in the heart of Cambridge that can make use of new cycle path access

We support the continuation of existing Opportunity Areas, especially, S/OA/ Policy 23. It is however considered that the Policy and the Eastern Gate Development Framework, Supplementary Planning Document could be updated to provide specific guidance on the sites contained therein, especially given that the SPD was formulated in 2011 and in line with the then adopted Local Plan (2006).

Moreover, some of the proposal sites shown therein (Figure 2 of the SPD) have since come forward for development. Other sites, shown as ‘Other Potential Development Site’s, have also come forward through the planning application process, and are considered to play an important role in assisting with the delivery of Greater Cambridge Local Plan’s housing, employment and other land use needs over the plan period.

An update of the SPD will provide a useful baseline of the current position on the ground and to guide development proposals moving forward to 2041.

For example, Figure 39 of the SPD sets out the ‘Built Form, Scale and Massing Strategy’ for the SPD study area, including indicated building frontages and storey heights. The redevelopment of the Cambridge College for Further Education site on Young Street is shown as delivering 3 plus 1 storeys along New Street and 2 plus 1 storeys on at the corner of New Street and Sturton Street.

However, planning permission with reference: 12/0489/FUL, as developed on site, shows 3 plus 1 storeys at the corner of New Street and Sturton Street and along the New Street frontage leading to East Road.

It is therefore considered that the SPD been updated to reflect the above building form and height, and continue this along the remainder of New Street at 3 plus 1 storeys.

Moreover, the development has corresponded with the traditional building frontages in line with the SPD.

These indicative building frontages, are continued along New Street (Figure 39 of the SPD) along the St Matthew’s Centre site, which is supported. Nevertheless, the SPD should recognise that the St Matthews Centre site frontage is constrained by setback tree planting to its New Street and Sturton Street frontages, and protected open space to its York Street frontage. In order to facilitate the potential development and aspirations of the SPD, especially for the St Matthew Centre site, and to reflect the prevailing street frontage character of New Street, the SPD should development that faces New Street, whilst ensuring the protected open space is maintained and enhanced.

The St Matthew Centre site is an important facility for the Cambridge School of Visual and Performing Arts, and has the potential to assist with the delivery of modern enhanced facilities for the college as it grows.

In light of the above, it is considered that some or all of the sites highlighted as ‘Other potential development sites’ should be included as proposed sites, in particular the St Matthews Centre, Sturton Street site.

Although we have no opinion on the allocation of the Abbey stadium as an opportunity site, we would have significant concerns regarding any relocation of the stadium to a site near the A14 J.35 with regards to potential adverse impacts on Little Wilbraham Fen SSSI and its sensitive priority spp. (including rare breeding birds). We are pleased to see that there is no such allocation proposed within the First Proposals document.

Railpen, as landowner of both Newmarket Road Retail Park and Beehive Centre, support the Local Plan ‘First Proposals’ to include for two new Opportunity areas as S/OA/NR and S/OA/BC to cover each site, respectively. The policy direction recognises the current sites do not make efficient use of the land in what is a highly sustainable location and could be reimagined to bring about a multitude of social, economic and environmental benefits.

Railpen support the policy approach and look forward to working with stakeholders to determine what the optimum, long-term and beneficial reimagining of the sites could be.

The College supports draft Policy S/OA and the proposal to carry forward the Cambridge Railway Station, Hills Road Corridor to the City Centre Opportunity Area to the emerging Greater Cambridge Local Plan.
The College is also supportive of the proposed policy direction, in particular the drive to deliver public realm improvements. The Opportunity Area policy should provide clear indication that positive weight would be provided to those developments that help to achieve the aims of the policy and act to fulfil the opportunity identified

Please see attached planning commentary.

Land to the north of Station Road, Cambridge is submitted as a potential allocation for employment in the Local Plan.
The supporting Planning Representations and Vision Document provides further detail on the significant opportunity that the site presents, informed by additional site assessment work and in light of the four ‘big themes’ identified in the consultation document.
Land to the north of Station Road is the last section of the Station Road area to benefit from a clear and shared long-term vision and so represents a significant opportunity to continue the successful transformation of this part of the city and provide additional capacity to support the further clustering around the Station.
The Site is within single ownership and capable of delivering a well-designed, high quality development that could make efficient use of a brownfield site, in a highly sustainable location, whilst also being able to respect its historic context. The site’s proximity to Cambridge railway station, links to the Chisholm trail and the transport interchange at the Station also enables opportunities to promote sustainable transport modes.

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.

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.

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.

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.

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.