S/CE: Cambridge east

Endorse in general the proposed policy direction especially to enable the development of the airport site. However, the delivery of only 2,900 homes out of the proposed 7,000 by 2041 appears lacking in ambition. Of those 2,900 homes preference should be given to affordable and social housing to ensure housing available for the employment mix proposed. The council should support Marshall Holdings to bring forward their relocation of airside activities to Cranfield Airport to release brownfield land for housing and employment development, especially that of affordable housing which is a priority in this part of Cambridge.
The mix of employment uses needs to be scrutinised in the light of post-Covid working and living conditions.
It will be important to retain the individual character of Teversham village and prevent encroachment on the Green Belt. The maintenance of the green corridor widening out at Teversham to provide a green separation as adopted in the 2010 Local Plan must be retained. The proposal for relocating Cambridge Waste Water Treatment Plant to an area of unspoiled Green Belt at Homey Hill between the villages of Horningsea and Fen Ditton does not accord with the policy’s intention to provide additional wildlife habitat as part of Eastern Fens green infrastructure initiative. It is also contrary to Policy GP/GB
The policy proposals should not depend on complete integration with or extension to the proposed North East Cambridge Area Action plan which predicates on the relocation of Cambridge Waste Water Treatment Plant to an area of Green Belt at Honey Hill which is the subject of a Development Consent Order.

Clandestine destruction of Green Belt at Honey Hill, no consultation via the local plan process. In order to build under 3000 homes by 2041. The Marshall site is not on Green Belt and can accommodate the housing requirement more quickly. Carbon impact of rebuilding a fully functioning WWTP a couple of fields away is massive and totally mad. Moving it 2 fields is short sighted and does not allow for expansion and increased environmental standards relating to storm overflows. Too close to conservation areas and new development of Marleigh and Airport site. Wrong on so many levels

Endorse in general the proposed policy direction especially to enable the development of the airport site. However, the delivery of only 2,900 homes out of the proposed 7,000 by 2041 appears lacking in ambition. Of those 2,900 homes preference should be given to affordable and social housing to ensure housing available for the employment mix proposed. The council should support Marshall Holdings to bring forward their relocation of airside activities to Cranfield Airport to release brownfield land for housing and employment development, especially that of affordable housing which is a priority in this part of Cambridge.
The mix of employment uses needs to be scrutinised in the light of post-Covid working and living conditions.
It will be important to retain the individual character of Teversham village and prevent encroachment on the Green Belt. The maintenance of the green corridor widening out at Teversham to provide a green separation as adopted in the 2010 Local Plan must be retained. The proposal for relocating Cambridge Waste Water Treatment Plant to an area of unspoiled Green Belt at Homey Hill between the villages of Horningsea and Fen Ditton does not accord with the policy’s intention to provide additional wildlife habitat as part of Eastern Fens green infrastructure initiative. It is also contrary to Policy GP/GB
The policy proposals should not depend on complete integration with or extension to the proposed North East Cambridge Area Action plan which predicates on the relocation of Cambridge Waste Water Treatment Plant to an area of Green Belt at Honey Hill which is the subject of a Development Consent Order. It is recommended a more ambitious target of 4000 homes during the plan period . This could be achieved with forward planning prior to Marshalls final departure. Ensuring protection and a green separation of dwellings from Teversham village is important . Opportunities to link cycle ways across Coldhams Common, through the airport and out towards National Cycle route No.11 & National Trails eg Harcamlow Way should be fully optimised as part of the development plan - Enabling safe foot-cycle access to SSSI Quy Fen; SSSI Wilbraham Fen and wider network of surrounding PRoW’s.

It is highlighted that this proposed allocation for a new eastern quarter to Cambridge will bring Cambridge’s eastern boundary in much closer proximity to Teversham, and RWS Ltd’s site Land at Fulbourn Road. This new development will significantly enhance the sustainability of Teversham with access to the services, facilities and employment opportunities on site easily by foot and bicycle, with the addition of enhanced accessibility to the remainder of Cambridge through the infrastructure to be provided.

(Education) The Council notes the further development of this area subsequent to it being ‘safeguarded’ under the 2018 Local Plans and the existing permission granted to Land North of Cherry Hinton (LNCH) within the site. The Council is already working on proposals for the delivery of a primary and secondary school in the context of the outline permission for 1,200 homes at this location.
The Council notes a further 2,900 dwellings are anticipated at Cambridge East to 2041, with a total of 7,000 once the site is completely developed. The Council would find it valuable, in the context of the existing schools’ proposals, to understand at the earliest possible opportunity where the 2,900 dwellings are planned within the site; whether adjacent to the current LNCH site south of the airport/green corridor or to the north along Newmarket Road and adjacent to Marleigh, etc., or both.
Based on the Council’s approved general multipliers, the level of additional development proposed to 2041 (2,900 dwellings), would generate approximately 580-870 early years’ children, 870-1,160 primary-aged pupils (4.1FE-5.5FE) and 520-725 secondary-aged pupils (3.5FE-4.8FE).
In theory, Cambridge East could require the equivalent of three 2FE/two 3FE schools to accommodate site development until 2041, with a further possible 3FE school required (630 places) to cater for the 640 places (max multiplier) for the residual 1,600 dwellings post 2041.
Further, assuming the landowner/developer(s) may wish to bring forward smaller land parcels across the site for development at different stages, the Council recommends adoption of an up-to-date area action plan for the holistic development of both the remaining site and integration with existing communities at Cherry Hinton, LNCH and Marleigh.
One reason for this is around timing. LNCH currently includes provision for a 2FE Primary School (420 places i.e. 60 places in each of the 7-year groups of the primary phase) and a 2FE Wave 12 free primary school is in build, in conjunction with DfE, for Marleigh. The current expectation, given housing mixes understood at the time of writing, is that Marleigh Primary will open in September 2022 with a published admission number of 15 for entry in year Reception. It will accept in-year applications for all year groups and will build gradually to 1FE (30 places in each year group) and eventually 2FE (6 places in each year group) to meet the needs of the development as it grows.
Timing is also important to avoid surplus places at existing primary schools within the local area, factoring in demographic basic need, which could have implications for effective curriculum delivery and financial sustainability.
Timing of primary place provision is going to be critical for school sustainability both within Cambridge East and for schools in communities surrounding it.
For Early Years, additional sites would also need to be allocated and marketed for full day care provision. This is partly to ensure sufficient places which would not be met by the schools alone, but also to promote choice and for families who are not entitled to funded childcare but still wish to access provision.
Regarding secondary provision, a Wave 12 free secondary school is currently being planned in consultation with DfE, the Multi-Academy Trust (MAT) which will run the school and the developers (Bellway) at LNCH. The secondary school is to be located at the eastern gateway to LNCH, off Airport Way and will be south of the ‘green corridor’
DfE is proposing it will be a 4FE capacity (600 place) secondary to begin with. The Council has proposed that this should be built with the ability to expand on the same site to 6FE (900 places). The permitted development at LNCH, on current housing mix proposals, will see a demand of approximately 1FE, Marleigh potentially 2.5FE. Bearing in mind the 2,900 additional dwellings to 2041 of approximately 520-725 secondary-aged pupils, 3.5FE-4.8FE, this school, as currently envisaged, could potentially absorb much, but not all possible demand, with a possible deficit in places of 1-2.3FE by 2041, unviable for a second 11-16 school. However, the residual post-2041 build-out implies a further 1,600 dwellings still to come at Cambridge East. This would not yield a sufficient number of secondary age children for another viable secondary school, however the allocation of land for a second campus prior to 2041 would enable necessary expansion beyond the current 6FE envisaged to cover a 1-2.3FE deficit by 2041 and the additional need requirements beyond 2041, which could stretch that deficit to as much as 3-5FE.
In the immediate to short-term, the situation of other existing local secondary schools needs to be borne in mind, particularly in circumstances where basic need has dropped in the past few years.
Therefore, the Council recommends a further site for secondary provision should be identified at Cambridge East to accommodate capacity closer to 2041 and the post 2041 residual build-out.
Again, for school effectiveness and financial sustainability purposes, timing of both this first secondary and further 11-16 provision are critical.
Assuming the LNCH secondary school remains the main local secondary school for the majority of the period to 2041, consideration needs to be given to student, family and wider community access to it across the ‘green corridor’ from the northern part of the site and Marleigh. Public transport as well as walking and cycling routes will need to bear this in mind.
At this stage, all figures provided here are for illustrative purposes only. The Council will not be able to confirm its education requirements, land and contributions until later in the planning process when the housing mix is finalised.

(Minerals and Waste) All of the site is within a MSA for chalk; part within a MSA for sand & gravel. MWLP Policy 5.

The Policy for Cambridge East identifies that the site was originally identified for development in 2003 and the adopted 2018 Local Plans changed the allocation to an approach that safeguarded land for future development. This is a significant period of time for the site to come to fruition. There appears to still be some uncertainty in respect of the timing of the relocation of the airport related uses that is required before development of the site commences. The Local Plan suggests that the additional homes and jobs envisaged for the site are proposed to be located on the safeguarded land and delivery of these homes and jobs would start post 2030 to follow the relocation of the airport activities. It is considered that there may be further unforeseen delays in respect of the relocation of the airport and that this may affect the delivery of housing within the plan period. The Council should therefore look at providing more of a range of smaller and medium sites that have the ability to come forward at a faster rate than strategic sites of this size.

The Policy for Cambridge East identifies that the site was originally identified for development in 2003 and the adopted 2018 Local Plans changed the allocation to an approach that safeguarded land for future development. This is a significant period of time for the site to come to fruition. There appears to still be some uncertainty in respect of the timing of the relocation of the airport related uses that is required before development of the site commences. The Local Plan suggests that the additional homes and jobs envisaged for the site are proposed to be located on the safeguarded land and delivery of these homes and jobs would start post 2030 to follow the relocation of the airport activities. It is considered that there may be further unforeseen delays in respect of the relocation of the airport and that this may affect the delivery of housing within the plan period. The Council should therefore look at providing more of a range of smaller and medium sites that have the ability to come forward at a faster rate than strategic sites of this size.

Huntingdonshire District Council are aware that delivery at Cambridge East will be a long-term allocation and is reliant on the relocation of Marshalls Airport. Relocation is currently anticipated to be in 2030. The mix of uses will enable a sustainable development and it is agreed that focus on high quality public transport connections will be essential to a successful scheme.

In the event that Marshalls Airfield does not relocate it is recommended that alternative sites are made available and identified as reserve sites within the plan.

This allocation is heavily reliant on major infrastructure either being relocated (the airport itself) or implemented such as the GCP Cambridge Eastern Access scheme. This allocation could leave the plan vulnerable at Examination stage due to deliverability and viability development risks.

This site is less complex than NEC in terms of ownership and contamination and could be developed more quickly with more open spaces and affordable homes. This site would not force people to live in high density alongside the A14 where noise and pollution will be a problem. Teversham and the surrounding Green Belt could be maintained and extended to create a green buffer between the development and conservation villages. A purpose of Green Belt which is being contravened by CWWTPR to an unspoilt area of Green Belt which protects the setting of Cambridge and villages.

The council should support Marshalls to move soon to release brownfield land especially for affordable housing as a priority.
It will be important to prevent encroachment on the Green Belt. The proposal for relocating CWWTP to unspoiled Green Belt at Honey Hill does not accord with the policy’s intention to provide additional wildlife habitat as part of Eastern Fens green infrastructure initiative. It is also contrary to Policy GP/GB
The policy proposals should not depend on the proposed NECAAP predicated on the relocation of CWWTP to Green Belt which is the subject of a DCO application.

A SERIOUS transport assessment is needed for Newmarket Road if 7,000 homes 9,000 jobs are planned. Furthermore, making all the radial access roads work to meet the objectives of encouraging use of public transport may result in some rat running into side streets, although on many of the routes there is little opportunity for this.

In the main supported. It is recommended a more ambitious target of 4000 homes during the plan period . This could be achieved with forward planning prior to Marshalls final departure. Ensuring protection and a green separation of dwellings from Teversham village is important . Opportunities to link cycle ways across Coldhams Common, through the airport and out towards National Cycle route No.11 & National Trails eg Harcamlow Way should be fully optimised as part of the development plan.
Enabling safe foot-cycle access to Quy Fen; Wilbraham Fen and wider network of surrounding PRoW’s.

What public transport solutions will be provided to link new housing at Cambridge East to employment centres like CBC to avoid excessive private car use across the city on already over stretched road network? Infrastructure upgrades should be a prerequisite to development of Cambridge East. I would oppose any large development before the transport plans are in place and delivered.

I would oppose a larger release of land from the green belt, the airport site is large enough already for significant development.

Policy S/CE appears to have the potential to provide sufficient and suitable housing within the Plan period without the corresponding capital carbon / climate change and Green Belt impacts of the proposed Waste Water Treatment Works relocation required by Policy S/NEC: North East Cambridge.This would benefit from further analysis.

No Comments

The Preferred Options consultation document rightly recognises the importance of Cambridge East to the growth strategy of Greater Cambridge through the allocation of the site for a significant mixed-use development. Marshall strongly supports the principle that the Local Plan should allocate Cambridge East and optimise the potential of the land to meet housing, employment and cultural needs in the City. Cambridge East is a development opportunity of national potential and importance and its scale and location make it a unique opportunity to establish the next chapter in the remarkable story of the City of Cambridge and Greater Cambridge area. It is the largest brownfield site and is the most sustainable opportunity to deliver significant growth embedded within the Greater Cambridge area. Cambridge East represents one of the key sites in the development of the Local Plan strategy based on its scale and its inherent potential to add to and diversify the City. It presents the opportunity to plan for forms of development that cannot be accommodated within the historic core and it is capable of providing the key missing links in a comprehensive sustainable transport network for the City.

Marshall is committed to delivering a scheme that is truly sustainable and of exceptional design quality. Through the work that has been undertaken and shared with GCSP so far, it is clear that a development of the scale of Cambridge East can have significant sustainability benefits in comparison to locating development over a series of smaller sites. The benefit of scale at Cambridge East can provide:
- A single integrated public transport and active travel solution to reduce carbon emissions and ensure local air quality improves;
- A single strategy to meet both biodiversity net gain and carbon sequestration, providing significant large-scale opportunities for major local environmental gains; and
- An opportunity to invest in sustainable approaches to water management, energy and biodiversity.

Marshall will continue to work collaboratively with the GCSP to undertake further capacity testing and prepare evidence base documents that demonstrate that the site is capable of developing into a high quality urban quarter, which can enhance the social and economic objectives of the Local Plan.

Marshall would like to take forward close joint working with the councils by entering into a PPA with the GCSP, which will facilitate further discussions around scheme design, mix of uses, the supporting transport strategy and other technical evidence, ahead of the preparation of a draft policy in Autumn 2022.

In advance of the next version of the Local Plan being published, Marshall is committed to:
- Engaging and working with the local community to understand their views and how those views should influence the content and development of Cambridge East. As part of this, Marshall is currently developing a plan to launch public consultation during the second quarter of 2022 to understand the issues of importance to the adjoining communities and other key stakeholders;
- Developing a clear, shared vision for the development of the land;
- Identifying ways in which the development of Cambridge East can help deliver wider objectives for the City of Cambridge and Greater Cambridge area;
- Undertaking further capacity testing which maps out the scale of development that can be accommodated consistent with enhancing access to the countryside and green infrastructure, whilst protecting important views and environmental assets;
- Developing the technical evidence base to support the delivery of the development;
- Planning the phased delivery of infrastructure, including green infrastructure and social infrastructure;
- Optimising sustainable transport measures and planning for a net zero development;
- Developing a detailed draft policy for Cambridge East that can be embedded in the local plan; and
- Creating the confidence which allows the GCSP to rely on the high quality and delivery of Cambridge East in favour of development proposed in less sustainable locations.

In relation to the following points
• To retain a green corridor through the development to link the countryside with Coldham’s Common and the heart of Cambridge, that lies within the and has a landscaping, biodiversity and recreation function whilst also maintaining the individual identity of Teversham village.
• within the site, and green infrastructure within and adjoining the area, including providing additional wildlife habitat land surrounding the designated nature sites to the east of Cambridge, as part of the Eastern Fens green infrastructure initiative.
Whilst we strongly support this approach in general, the relationship between the Cambridge Airport site, the adjacent countryside, future green space provision and future transport provision is complex. There is significant risk of recreational disturbance (harm) to nationally important species and designated nature conservation sites and this does not appear to be recognised. There are also differing ideas on where future “country park” type provision should be made in order to divert pressure from ecologically sensitive sites and also to tie in with plans of environmental NGO’s. In our view, significant work is still required in order to resolve these challenges and we are concerned that the best solution should not be constrained by over-simple policy statements and over simple maps included in the Local Plan. We are attaching a letter that we sent to Marshall’s in 2020 which sets out some of our views in relation to the future development of this site. We would welcome continued dialogue on this matter as the draft Local Plan is prepared.

We also believe that the future of the S/AMC/Policy 16: South of Coldham’s Lane should be linked to Policy S/CE: Cambridge East. It is our view that the challenge (and costs) associated with bringing Coldham’s Lakes into public use as a park is only likely to be viable as part of the Cambridge Airport development. Indeed, one of the main user groups of a new Coldham’s Lakes Park would be the future residents of the airport. The lakes could also divert recreational pressure from other more sensitive ecological sites.

Although the new biodiversity policy BG/BG will set out a 20% target, it would be worth cross referencing this requirement in any supporting text. In addition, although this is likely to be dealt with in more detail in a subsequent action plan, we believe that there should also be headline targets or objectives within the allocation policy related to water demand, green infrastructure and sustainable urban drainage, or appropriate references to requirements set out in the associated climate change and great places policies.

Axis Land Partnerships wish to object to the assumed housing trajectory lead in time and build out rates for site allocation S/CE. Please see Station Fields Representations Report December 2021 (submitted under response to Policy S/DS) - Section 2 Appendix 1 Tables 1 – 4 ID: 59040

I am opposed to development on Marshalls airfield to the East of Cambridge. Despite the various safeguards proposed it will be a major extension to the city resulting loss of the green belt and more congestion.

I support your policy and proposals.

I repeat my comment above that It is essential that all development is synchronised with the relevant infrastructure. This is particularly important for transport and connectivity. A comprehensive network of rapid, accessible and cheap public transport provisions is essential, as is full provision for those people for whom a car is essential, such as the disabled.

Encouragement of biomedical and other high tech opportunities could take advantage of the potential ease of connectivity with the existing clusters around the Cambridge Science Park, Cambridge Business Park and the Cambridge Biomedical Campus, while by-passing the City Centre. This approach will also relieve the pressure on the Southern Fringe resulting from any expansion of the Cambridge Biomedical Campus.

The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan, allocated in the 2006 Local Plan and safeguarded in the 2018 Local Plans for development should the site become available. We raise significant concerns over the delivery of this site within the timescales anticipated. As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030. The Topic Paper states at Page 116:

“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”.

There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, particularly noting that Cranfield Airfield is only expected to become available from 2030 at the earliest.

Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF (2021).

The Airport has long been earmarked for future development and was identified in the 2003 Structure Plan, allocated in the 2006 Local Plan and safeguarded in the 2018 Local Plans for development should the site become available. We raise significant concerns over the delivery of this site within the timescales anticipated. As stated within the Development Strategy Topic Paper (2021), it is understood that Marshalls has a signed option agreement for relocation to Cranfield Airfield, Bedford, for which vacant possession is anticipated by 2030.

The Topic Paper states at Page 116:
“This gives a reasonable level of confidence at this early stage in the plan process that the site is likely to come forward in time to help meet development needs in the plan period as well as beyond. It is important that there should be sufficient evidence to demonstrate clearly that the plan can be delivered by the time it reaches the later formal stages and so the position will be kept under review during the plan making process”.

There is clearly still a high degree of uncertainty regarding homes being delivered at Cambridge Airport within the plan period and even in the event that the site does come forward, it is ambitious that the site will start delivering 350 homes per year from 2031/32, as set out within the trajectory, particularly noting that Cranfield Airfield is only expected to become available from 2030 at the earliest.

Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF (2021).

The National Trust does not object to the development of this brownfield site providing appropriate green infrastructure can be delivered. This site provides opportunities to connect to the Wicken Fen Vision Area and create green infrastructure which would deliver on the high level ambitions of the Greater Cambridge Local Plan.

Outside the Local Plan area in East Cambridgeshire, the Trust owns and manages some 250 ha of land at Wicken Fen, a National Nature Reserve and designated SSSI, and an internationally designated SAC and Ramsar. At its closest point the Reserve is located approximately 4km to the east of the boundary between the two local authority areas, however the Trust’s plans for the Wicken Fen Vision Area would extend the area of land managed for nature conservation southwards to within 2km of the Greater Cambridge boundary. The Trust’s long term management strategy for the Vision Area extends across an area of approximately 5,300 ha and aims to alleviate the growing pressure on vulnerable habitats within the designated site, and to better protect areas at risk from the effects of trampling, recreational pressure and other harmful activities.

Edge of Cambridge
18. The development of Cambridge East is predicated on closure of Cambridge Airport. The airport area is one
of, if not the largest employers in Cambridge. Where will these skilled engineering staff find employment?
Additionally, if Cambridge is to be such a significant centre of international business, why would it not need
its own airport, providing flights to national and international hub destinations?
19. Further development in North West Cambridge will cause development to completely dominate this green
space between Huntingdon Road and the M11. This green space is important for the existing residents and
to the character of the area. Further major development in this area polluted by the M11 and A14 and
their major intersection is unwise.
20. With respect to Policy S/CBC, CPRE objects strongly to the release of further Greenbelt land, identified as
the area S/CBC-A. The existing allocation of land around the Addenbrokes site has not been built out. Land
that has been built on recently has been used profligately. There is indication that since BREXIT and the
move of the European Medicines Agency from London to Amsterdam, there will be less interest by major
pharmaceutical companies in moving to anywhere in the UK including Cambridge. The UK is now a
‘secondary’ market in the priority of new pharmaceutical product registrations. It is more likely that
companies based in the UK will move at least some of their activities to the Netherlands, especially now
that the EU and the USA have reached a Mutual Recognition Agreement for drug manufacturing
inspections.
21. CPRE agrees with the findings of the Greater Cambridge Green Belt Study (2021) which identifies that
release of the areas proposed would result in very high harm to the Green Belt and that there are concerns
regarding biodiversity and landscape impacts from the scale of development proposed by the Campus.
22. CPRE also objects to the apparent attempt to turn the “Proposed Area of Major Change” into some kind of
greenwashed country park as compensation. This appears to be an underhand attempt at carbon off-
setting on what is much needed, productive, farm land. Such “compensatory improvements” are a
developers’ myth. Once the released land has been developed it is gone.
23. With respect to Policy S/WC: West Cambridge, this area is already well developed and further infill within
the outlined boundary is sensible. However, CPRE is concerned to ensure there will be no further spread
south onto the green fields between Cambridge and the M11.
24. CPRE are concerned by the retention of the two allocations between Huntingdon Road and Histon Road
(Darwin Green). These are significant areas of green space on the northern edge of the city which help
retain the character of the city’s integration with its rural surroundings.
25. CPRE are concerned by proposed further development along Fulbourn Road on highly productive farm land at S/EOC/E/3: Fulbourn Road East, even though this is a retained policy.

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.

Policy S/CE: Cambridge East refers to the importance of the GCP Cambridge Eastern Access scheme Phase B being in place which will provide high quality public transport connections. Whilst the motives for this are well-intentioned, it has to be recognised that, despite every attempt, cars remain the preferred choice of many people to get to work, even if it means large traffic jams. Even if walking/cycling is an individual’s preferred means of transport, enthusiasm can disappear in the event of rain, wind, ice and snow and any transport plan must recognise the worst-case scenario. It is therefore imperative that road links between Cambridge East and the three southern campuses are improved. The road structure beyond the Robin Hood crossroads is simply not fit for purpose. Access to the Cambridge Biomedical Campus is limited to the use of Queen Edith’s Way, which is a comparatively narrow main road whilst access to the Babraham and Genome Campuses is via Lime Kiln Road, which was never designed for large volumes of traffic.
(Pages 85-90) Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital).
Whilst Policy Direction is driven from outside the local area, Queen Edith’s should be proud to be part of such a prestigious international development. I welcome the Proposed policy direction, provided the activities are closely monitored to avoid inappropriate development on the site.
Nevertheless, there are significant dangers associated with such a powerful neighbour and it is important that these are recognised and mitigated. The CBC Vision 2050 is still at an early stage of development, and it is essential that the Local Plan incorporates sufficient flexibility to respond appropriately to this. As a first step, I welcome the aim of CBC to be a good neighbour and to include members of the Queen Edith’s Community Forum on their Vision 2050 Liaison Group.
As mentioned in 3.1, I welcome the concept of key worker accommodation on site but would not support any housing which is offered to the general public.
Why is this Policy needed? (Page 89). I welcome the sensitive approach to the Green Belt issues. Whilst it is important that we respect and protect nature and our environment, it is important to recognise that, as a species, we also compete for survival and that nature can be hostile (not least in creating human diseases such as Covid via bats in a Chinese cave and Avian flu). It is therefore important to weigh the benefits of the life sciences against the importance of protecting the environment and I believe that the proposals for this Policy strike a good balance.
Whilst I appreciate the need for expansion, I believe that it would also be important, not least for residents of Trumpington and Great Shelford, to make it clear that there is no prospect of expanding across Granham’s Road and to initiate a discussion between CBC and the southern campuses, including Fulbourn East regarding alternative ways in which the life sciences can be accommodated in south-east Cambridge.
It will be important to explore with local life sciences businesses the nature of collaboration:
· Who collaborates with whom and why?
· How dependent is it on being on the same site?
· How is collaboration impacted by having sites a few miles apart?
· What proportion of the workforce benefit from close collaboration? How often should such collaborative action take place in an ideal world?
· How far have work practices changed as a consequence of Zoom and other features forced by the pandemic?
I also like the concept of a “green edge” to the city, which should not only be green on the ground, but soften the view, avoiding the current harshness of both Eddington and Trumpington Meadows as you approach.
The provision of water to the site, the high-water table and surface water flooding issues are critical and a potential show-stopper for further development unless and until they are fully resolved. These are addressed in 2.3 above and will not be repeated here.
(page 43) Transport strategy The willingness to work with other authorities to progress local plan evidence is welcome. Please ensure that, for reasons given in 2.3 and 3.2, the issues of Lime Kiln Road are fully addressed.
(page 94) Policy S/EOC: Other site allocations on the edge of Cambridge. Biomed Reality, which recently made an application for planning permission for the 6.9ha Fulbourn Road East site, indicated that were planning for 2,700 jobs and 1,362 parking spaces. The 4.4ha Fulbourn Road West (GB3 and GB4) is located nearby and simple scaling suggests that this might add a further 1,700 jobs and 868 parking spaces.
The Fulbourn sites are major developments and have the potential to create major traffic problems into and out of Queen Edith’s Way and Cherry Hinton Road, which will be greatly exacerbated when the Cambridge East development comes on stream. A full infrastructure assessment as part of Policy I/ID: Infrastructure and delivery must be made of the impact of traffic on these roads and at the Robin Hood junction.

Broadly supportive but it is important that these developments do not encroach on the Green Belt and retain the individual character of Fen Ditton and Teversham villages.
We have not resolved the spatial extents of CE/R45: Land north of Newmarket Road (within Cambridge) and expect to comment at a later date.
OBJCT to move of the Newmarket P&R since this appears to assume an alternative Greenbelt Site with potentially worse access links will be needed.
We have suggested alternatives to GCP including the NE corner of the Airport site since this would have direct access to the roundabout thus avoiding congestion.
OBJECT to move of Cambridge WWTW to Green Belt land immediately north of Cambridge East since such open space will become important to future residents.

The Cambridgeshire Development Forum brings together a diverse range of organisations with a shared commitment to the delivery of high-quality developments in the Cambridgeshire region. We include promoters, developers, housebuilders, housing associations, planners, advisers, law firms, design companies, transport planners and related professionals in our membership. We do not promote individual sites and are focused on achieving more effective delivery of plans in our region. We value the engagement we receive from local planning authorities, the Combined Authority and Central Government. We welcome this opportunity to respond to the consultation on the Local Plan.

These representations reflect shared views among our members but should not be interpreted as representing the views of any individual member organisation in membership of the Forum.

Responses:

Q1: the additional 550 homes a year should be regarded as a minimum figure, which should be reviewed regularly in relation to the growth in jobs within the travel-to-work areas

Q2: the spatial strategy for development should focus the larger development sites in locations which offer public transport options to reach major employment centres. Development in rural locations of an appropriate scale should not be deterred as and when more sustainable personal transport options are available, eg EVS using renewable energy.

Q3: The Cambridge East Development should be connected directly to the City centre and the inner urban ring of development at the Biomedical campus, North Cambridge and the Science Park, Eddington and West Cambridge. But it should not be a wholly residential development. It should be a mixed development including commercial, residential and leisure/ retail options. It should be envisaged as a distinct place, with its own character. It could include high-rise apartments suitable for the younger workers who comprise many Cambridge area workforces.

Q4: North-East Cambridge should offer a residential opportunity for those employed in the technology sectors around Cambridge, including a significant component of affordable housing for market sale, market rent, shared ownership, and social housing.

Q5: development in and close to the biomedical campus should be prioritised for the healthcare, research, and technology cluster; significant adjacent sites should not be developed for large-scale residential purposes.

Q6: Cambourne should provide jobs near the new homes and include more employment space potentially including a commercial hub based on any new railway station above the A428.
Outside this commercial and retail hub, Cambourne should be focused on the large-scale offering of homes for families of those working across the Cambridge area.

Q7: in the southern rural cluster, opportunities for development on brownfield sites and for rural diversification, with small business-related developments should not be excluded.
Related residential development on smaller sites should also be accommodated, taking account of the Neighbourhood Plans. A priority should be given to sites in villages on rail routes, at public transport nodes and within public transport corridors. Subject to the decisions to be made concerning the East-West Rail Link, the option for significant growth and/or new settlement in appropriate locations that maximises the use of all forms of public transport should be considered as additions to the sites proposed.

[Q8-13 omitted]


We have welcomed the engagement with the Greater Cambridge Shared Planning team, and look forward to this continuing through this process in future discussions.

Cambridgeshire Development Forum December 2021