S/LAC: Land allocations in Cambridge

Site allocations in Cambridge should be increased to spare rural spread.

Agree in principle with the exception of North East Cambridge site (see comments on Policy S/NEC). Wherever possible low carbon expenditure conversion should be employed rather than demolition and construction of existing buildings, e.g.Henry Giles House. Some downward revision of proposed total numbers of dwellings is needed in the light of post-Covid working practices and the need for recreational and personal space to support mental and physical well-being

We agree with the proposals/

(Education) The Council notes the intended use for S/C/SCL Land South of Coldham’s Lane as for commercial purposes, which will not impact on existing Land North of Cherry Hinton/Cambridge East education plans.

(Minerals and Waste) Site S/C/SCL – within a Mineral Safeguarding Area (MSA) for chalk. Former landfill so it is assumed that mineral has already been extracted. Within the settlement boundary.

The Trumpington Residents' Association strongly supports the removal of housing allocations for the Telephone Exchange and Car Park, Long Road (Site , 091, R14) and the Cambridge Professional Development Centre, Foster Road (R16), due to uncertainty about availability by 2041 (page 72).

The Wildlife Trust strongly objects to allocation S/C/SCL, because it allocates development on a City Wildlife Site which formed the third largest area of scrub and grassland mosaic within the City limits, valuable to a wide range of fauna including birds and invertebrates, prior to the deliberate destruction of the habitats ahead of the last Local Plan. The area was also used by local people and had significant potential to provide much needed accessible natural greenspace. This allocation is contrary to the Council commitments on addressing the biodiversity crisis and the site should be restored to nature.

The housing and mixed-use allocations that are being proposed to be carried forward from the Cambridge Local Plan 2018 and the South Cambridgeshire Local Plan 2018 should be reviewed and not automatically carried forward through this emerging plan. Where site allocations have been granted consent since the Local Plans were adopted, these allocations should not be repeated and instead the sites integrated within the urban area. On such occasions the emerging plan should seek to add to the allocations proposed and replace those sites from the 2018 Plans that have been delivered/ implemented.
Where these past allocations have not been progressed and delivery is therefore not certain, the opportunity should be taken to review their deliverability and viability to ensure the supply of sites is reliable and delivery sustained throughout the plan period. As such, the Local Planning Authority should not be reliant on these sites within their housing supply figures until their delivery can be confirmed. Claremont Planning recommends that the urban sites be supplemented by a mix of small to medium scale development opportunities within the surrounding larger settlements and villages to ensure that the provision of housing is not reliant on a single form of provision.
In order to maintain housing delivery the strategy should be widened to actively address the whole of the plan area. Claremont advises that the most robust approach to address this shortcoming would be to allow for growth of existing rural settlements.

The housing and mixed-use allocations that are being proposed to be carried forward from the Cambridge Local Plan 2018 and the South Cambridgeshire Local Plan 2018 should be reviewed and not automatically carried forward through this emerging plan. Where site allocations have been granted consent since the Local Plans were adopted, these allocations should not be repeated and instead the sites integrated within the urban area. On such occasions the emerging plan should seek to add to the allocations proposed and replace those sites from the 2018 Plans that have been delivered/ implemented.
Where these past allocations have not been progressed and delivery is therefore not certain, the opportunity should be taken to review their deliverability and viability to ensure the supply of sites is reliable and delivery sustained throughout the plan period. As such, the Local Planning Authority should not be reliant on these sites within their housing supply figures until their delivery can be confirmed. Claremont Planning recommends that the urban sites be supplemented by a mix of small to medium scale development opportunities within the surrounding larger settlements and villages to ensure that the provision of housing is not reliant on a single form of provision.
In order to maintain housing delivery the strategy should be widened to actively address the whole of the plan area. Claremont advises that the most robust approach to address this shortcoming would be to allow for growth of existing rural settlements.

USS notes that its asset at Clifton Road Industrial Estate is an existing site allocation that is proposed to be continued. The Clifton Road Industrial Estate is in a highly sustainable location that is well connected to public transport and has good active travel links. The site allocation (ref. S/C/M2) has a proposal to connect the site to Cambridge National Rail Station which will further increase its sustainability. USS therefore supports its proposed continued identification as an area that can support new mixed-use development.

USS notes that its asset at Coldham’s Road Industrial Estate is proposed to be continued to be protected as an industrial area. USS would encourage the Council to pursue a flexible policy in relation to protecting industrial areas, noting a range of complementary uses can often benefit industrial areas. USS also requests that the emerging Local Plan supports the densification of industrial areas, which is a more sustainable way of meeting increasing demand for these uses.

USS notes that it is proposed to continue to identify its asset at Clifton Road Industrial Estate as an allocation for development within the ‘Clifton Road Area’ allocation.

USS notes the following commentary on the Clifton Road Area allocation in the consultation document: “the redevelopment of this site to provide new homes will result in a significant loss of employment uses that would need to be relocated, and we have limited evidence that it will still come forward, and therefore we will need to work with the landowners to gather this evidence to have greater certainty that this site will be brought forward for development by 2041. These issues will be considered further as the draft Local Plan is prepared”.

As set out in representations to the Issues and Options Consultation (2020), USS is preparing a strategy for the delivery of the redevelopment of the Clifton Road Industrial Estate. USS therefore strongly supports the proposed continuation of the Clifton Road Area allocation for mixed-use development and looks forward to working collaboratively with the Council as it gathers evidence to show that the site can be brought forward for development by 2041.

Greater Cambridge has noted in the First Proposals document that there are two allocations where delivery is currently uncertain:

• S/C/R6: 636-656 Newmarket Road, Holy Cross Church Hall, East Barnwell Community Centre and Meadowlands, Newmarket Road – Currently allocated for 75 residential units.
• S/C/M2: Clifton Road Area – Currently allocated for a maximum of 550 dwellings and 2 ha of employment land.

Huntingdonshire District Council would like assurance that the Councils have additional sites to meet their housing need if these sites are not carried forward.

As noted in the representations to section S/DS, Cambridgeshire County Council as landowner supports the focus on Cambridge as the most sustainable location for new development. The County supports the ambition to regenerate brownfield land with high quality new development.

Cambridgeshire County Council as landowner support the continued allocated of Cambridge Professional Development Centre (allocation ref R16) and the Horizon Resource Centre (allocation ref R11). Both can be made available for residential development within the plan period, and additional submissions have been made to indicate their suitability, availability and achievability.

It is noted that only two new sites are proposed for allocation within the City boundary (S/C/SMS and S/C/SCL). The majority of allocations within Cambridge are carried forward from the previous local plan.

Cambridgeshire County Council supports the allocation of the former Bellerbys College (ref 40172) and Hawthorn Community Centre (ref 40166). Bellerbys is a brownfield site where the building, previously occupied by a private education provider, has been demolished as it was beyond its economic life. Cambridgeshire County Council, as landowner, would be pleased to work with the adjacent landowner CMAT in bringing forward residential development of the site. The County Council already has access rights from Arbury Road.

Cambridgeshire County Council supports the allocation of Hawthorn Community Centre (ref 40166). This is a single storey building in a highly sustainable site which could be better utilised for residential development. Cambridgeshire County Council has rights of access to the site from the public highway (with the access under the ownership of the City Council), and is therefore achievable.

Requested Change
It is requested that the development strategy for Cambridge City reinstates the allocation at Cambridge Professional Development Centre, as promoted by Cambridgeshire County Council, with the following policy requirements:
• Site Area of 1.49 Ha
• Capacity for approx. 67 dwellings including affordable dwellings
• Access to Foster Road and provide improved links to Clay Farm

It is requested that the development strategy for Cambridge City reinstates the allocation at Horizons Resource Centre, as promoted by Cambridgeshire County Council, with the following policy requirements:
• Site Area of 0.82 Ha
• Capacity for approx. 40 dwellings

It is requested that the development strategy for Cambridge City includes an additional residential allocation at the former Bellerby’s College, with the following policy requirements:
• Site Area of 0.25 Ha
• Capacity for approx. 20 dwellings including affordable dwellings
• Access from Arbury Road

It is requested that the development strategy for Cambridge City includes an additional residential allocation at the Hawthorn Community Centre, with the following policy requirements:
• Site Area of 0.43 Ha
• Capacity for approx. 15 dwellings including affordable dwellings

Over dense development is contrary to the well being of residents and the retention of significant green spaces within developed areas is vital for mental and physical wellbeing - S/S/SCL should be used as a publicly accessible 'green lung'.

I support the rejection of following Sites, ref. 40380,40425,40396, because they are Protected Open Space, and also following assessment by HEALAA (Appendix 4) . I also support the rejection of Site 40391
Additional comments of the HEALAA (Appendix 4) appraisals of these sites are included in attachment ED1

We support the rejection of following Sites, ref. 40380,40425,40396. They are currently Protected Open Space, and assessment by HEALAA (Appendix 4) reinforces this position. We would stress the contribution of these sites to biodiversity and geodiversity is incorrectly assessed. The sites make a significant contribution to the green corridor between the Backs and the M11. They are an inherent part of the West Cambridge conservation area. Their importance is enhanced given the 66 hectare development on the West Cambridge site. The flood risk assessment is unduly optimistic. Site 40380 has flooded several times in the last twenty years.

Land south of Bateman Street is proposed to be carried forward as a Mixed Use allocation under Policy S/LAC (site reference S/C/M5: 82-88 Hills Road and 57-63 Bateman Street). However, the site excludes No. 90 Hills Road.
Trinity Hall supports the continued allocation of Land south of Bateman Street but requests that the allocation also includes for No. 90 Hills Road. Trinity Hall remains committed to the sites’ positive redevelopment as a Commercial-Led, Mixed Use allocation.
The Science and Technology sector is the engine of the Cambridge Phenomenon that has driven the economy and it will remain an important part of the local economy and job market. Alongside, it is important to have all types of commercial space to provide for a wide range of job opportunities and to serve Greater Cambridge at close quarters to not overly rely on long-distance travel to service the area with goods and services. Further prime office floorspace in high quality developments is also needed to consolidate and expand the world class facilities which have recently put CB1 on the international property investment map.
Opportunities for densification of existing urban areas in locations well served by public transport should be maximised wherever possible. Furthermore, the redevelopment of areas around Cambridge central station for high quality offices within mixed use development which offers a healthy working environment is supported, together with the delivery of a high quality public realm.
Densification of existing urban areas in locations well served by public transport will also help to keep Cambridge as a compact city whilst still supporting the significant unmet needs arising from knowledge intensive (KI) companies, especially artificial intelligence firms around Cambridge Central station. This supports CPIERs third key recommendation: “Ensuring that Cambridge continues to deliver for KI businesses should be considered a nationally strategic priority”.
Land south of Bateman Street, Cambridge 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 respond to local character and protect the historic environment.
The Site has been assessed as suitable, available and achievable in the HELAA (reference OS044). Any matters scored as Amber in the HELAA are fully capable of being satisfactorily mitigated or compensated.
The key opportunities for the site are outlined below:
Meeting unmet development needs
− Hills Road forms part of the gateway into the city and a significant and thriving cluster of businesses. There is an opportunity for the Site to actively contribute to the hub of commercial buildings along Hills Road and deliver employment to help meet the needs of Cambridge whilst also supporting the local economy and community;
A highly sustainable location
− the Site is extremely well located for access to key facilities and services, including transport infrastructure such as Cambridge Railway Station, the Cambridgeshire Guided Busway (CGB) and the city centre; all within a 10 minute walk
− There are a number of strategic schemes coming forward which will improve mobility in the area (the Chisholm Trail and extensions to the CGB)
− Opportunities to promote sustainable transport modes reduce car use to ease congestion and reduce airborne pollutants. The same measure offers opportunities to promote active travel choices (walking, cycling) to enhance health and wellbeing.
Enhancing the public realm
− There is an opportunity to significantly enhance the public realm along Hills Road and in turn create wellbeing through improved green spaces to relax and socialise. New areas of green infrastructure can also mitigate against climate change, through creating resilient new habitats. In turn helping to fulfil the aspirations of the Opportunity Area policy.
Sustainability, social inclusion and wellbeing
− Trinity Hall are committed to ensuring that any development proposal would meet the highest sustainability standards
− This site presents a significant opportunity to spearhead solutions around sustainability, social inclusion and wellbeing in the context of move to a net zero-carbon society. In addition to its central location being able to support active travel choices; a number of climate change mitigation and adaptation measures would be incorporated in to redevelopment proposals for the Site
Preserving and enhancing heritage assets
− Land south of Bateman Street, Bateman House and 90 Hills Road are identified as buildings that detract from the Conservation Area in the New Town and Glisson Road Conservation Area Townscape Analysis. Any redevelopment proposal provides the opportunity to make a positive contribution to local character and distinctiveness and provide opportunities for improvements in the quality of the historic environment

Map Fig 22: shows the proposed new site allocations, including North East Cambridge (Policy S/NEC).
As outlined within proposed Policy S/NEC, the corresponding Waste Water Treatment Works relocation is being led by Anglian Water under a separate process. However, map Fig 22 should also display for reference the proposed relocation site for the Waste Water Treatment Works 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.

Cambridgeshire Constabulary have instructed Savills (UK) Ltd to make representations to the Greater Cambridge Local Plan (First Proposals). Savills have acted on behalf of the Constabulary in previous discussions and meetings with officers in respect of the police station at Parkside and also on the new station site at Milton.
The Greater Cambridge Local Plan is the first Joint Local Plan covering both Cambridge City and South Cambridgeshire District Council. The symbiotic relationship between the two administrative areas is clear since many residents of South Cambridgeshire look to the City for their employment, retail, leisure and entertainment needs and consequently the preparation of a Joint Plan is logical. The plan will necessarily have to consider how to plan for the level of growth needed and where it should go. Such elements are key components of the plan period up to 2041 and Cambridgeshire Constabulary is keen to ensure that the police service is an important part of this strategy.
The publication of the First Proposals consultation document seeks feedback on the emerging development strategy, the policy direction and the broad issues that the Councils need to address as they formulate the necessary policies. It is in this context that the Constabulary are making comments on the content of the document as it relates to the police station site at Parkside.

The current adopted Local Plan 2018 allocates the Parkside police station site (0.5 hectares) for 50 dwellings at a density of 102 dwellings per hectare. The allocation was carried forward from the previously adopted Local Plan of 2006.
The Greater Cambridge Local Plan First Proposals which is now out for consultation seeks to continue with the same allocation on the same site. Page 71 of the document identifies the housing allocation alongside a number of other housing allocations that are being taken forward in this new plan. It notes
“S/C/M4; Police Station, Parkside – the Building of Local Interest must be retained as part of the proposals for the redevelopment of the site for new houses”
A plan of the site is shown on page 334 of the document.
The Council will be aware that planning permission was granted in March 2019 for a new police station adjacent to the Milton Park and Ride site.

The new building will include
• Enhanced facilities enabling the Constabulary to respond to, and investigate, complex crimes such as fraud and online investigations more effectively
• Enhanced facilities allowing for the increased use of virtual courts which reduces the need for travel to courts
• Increase in cell provision from 12 to 24 to help meet future need
• The facilities and ability to better meet demand as population growth continues
• Better road access, subject to less traffic, enabling officers to respond to calls for service more efficiently.

Having regard to the permission granted for the new station at Milton, it will be essential for the Constabulary to consider the future of the existing police station at Parkside. The property occupies a site area of approximately 0.5 hectares bounded by Parkside, Warkworth Terrace, Warkworth Lodge and the Cambridge Fire Station and associated housing. The four storey L-shaped property dates from the early 1970’s and provides approximately 3995 square metres of accommodation. The site also accommodates a multi storey car park for 99 cars and a further building, originally designed as a gymnasium, and now used for storage.

The site is located within the Kite Conservation Area designated in 1969, extended in 1993 and 1997 and allocated as a separate Conservation Area in November 2018. The Kite Conservation Area Appraisal identifies Parkside as a Building of Local Interest, commenting that the property is “a good relatively unaltered example of its type”.
As stated above, the policy intending to be rolled forward into this new Local Plan would appear to continue the presumption in favour of retaining the Building of Local Interest (BLI). The building’s BLI status is a matter of fundamental concern as far as the client project team is concerned and we will continue to question its designation. Discussions have taken place with officers back in 2019 regarding the development potential of the site, recognising that the reference to 50 dwellings on the site was only an initial indication of capacity. It was accepted that further design work would need to be undertaken in the context where officers acknowledge the very prominent nature of the site and its surroundings.

Whilst the Constabulary Project Team welcomes the recognition that the site has development potential, it is important to ensure that the site can bring forward a mix of uses which the current Local Plan wording will not permit. At present the site is allocated purely for residential use. It is our view and indeed shared with officers that a more mixed use would be preferable on this site to reflect its central and prominent location. In the context of a mixed use, it is considered that there is potential for a boutique style hotel, apart hotel or office in this location alongside residential development and which would need to be carefully designed having regard to this sensitive location and the very prominent frontage it possesses overlooking Parkers Piece. It is important in this context to acknowledge that the police car park building to the rear of the site, the square and the store/former gym do not share any of the characteristics of the main building and do not constitute part of the Building of Local Interest designation or contribute to the Conservation Area. Consequently these elements should be the subject of demolition as part of any new development coming forward on the site. Clearly it will be a significant challenge to provide modern 21st Century accommodation in a purpose-built 1970’s police station and part of that assessment will necessarily involve a condition survey including a structural survey to assess the implications for a re-use (eg. cost of adaption and conversion). Indeed the designation of the police station as a BLI continues to be questioned by our client and the project team given the fundamental objections we have to its BLI status. We will continue to question the relevance of such a constraint to the redevelopment of this site as part of the ongoing strategy of bringing this site forward for development.

It is the case that the site will need redevelopment on the basis of the planning permission granted at Milton. The opportunity for the Council to fully exploit this central, prominent site should not be lost and not be constrained by the wording within the existing Local Plan. Accepting that we are still at the early stage of Local Plan preparation, the Constabulary wishes to promote a more mixed use on the site rather than restricting this to residential use. As such we would suggest a new policy relating to the Parkside police station site which more fully acknowledges the opportunity that exists for a mixed use and should be reflected within any new Plan.

We support the site allocations for the Old Press Mill Lane site and the New Museums Site being rolled forward from the adopted 2018 Cambridge Local Plan into the new Greater Cambridge Local Plan. Development of both of these sites will come forward during the plan period.

The University does not support the removal of land Hills Road as a site allocation (currently identified as Proposals Site E5 in Policy 25 of the Cambridge Local Plan (2018)). 7-9 Hills road has recently been refurbished and let for a short period, with the potential to redevelop during the plan period to 2041 once the lease has expired. The University intends to bring forward redevelopment of 1-3 Hills Road in the early part of the plan period.

No Comments

Please see additional supporting planning commentary.

S/C/SCL Land South of Coldham's Lane, Cambridge

This area is very close to land identified as an opportunity area for ecological development. The opportunity area is key for biodiversity. It does not make sense for this area to be near commercial large intensive works such as construction or builder's works. There is a risk of pollution, traffic (especially from heavy goods vehicles) which is counterproductive to the opportunity areas identified in the plan

In light of the comments provided to other policy directions contained within the emerging Greater Cambridge Local Plan, it is considered that the St Matthews Centre site should be identified at Figure 22 and allocated accordingly as a site capable of delivering mixed use education and student accommodation facilities.

The College support including allocations within Cambridge City that can be well-located to bus routes, cycle paths, pedestrian paths, jobs, services and facilities, but objects to only one such modest new allocation. An additional site to be allocated is Land at Wilberforce Road (40380). This Concept Layout shows it can be repurposed in such a way as to introduce significant new public open space and delivered with a landowner in a manner to help the Council meet its Big Themes underpinning the emerging Local Plan.

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 attached 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.

Please see attached planning commentary.

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.