S/NWC: North west Cambridge

(Education) The intensification of the site, already identified for development, will place additional demands on infrastructure, and on the associated contributions to deliver it.
Based on the Council’s approved general multipliers, this level of additional development (1,500 dwellings), would generate approximately 300-450 early years’ children, 450-600 primary-aged pupils and 270-375 secondary-aged pupils. It may therefore be necessary for a 2-3 form entry primary school, with on-site early years provision.
In addition to early years and childcare provision on site at the new primary schools, it will be necessary to allocate and market additional sites suitable for full day care provision. This is partly to ensure sufficient places which would not be met by EY provision on the school sites alone, but also to promote choice and for families who are not entitled to funded childcare but still wish to access provision. Where possible, the Council would encourage the co-location of establishments to promote partnership working. The Council would also actively encourage developers to provide free plots of serviced land or purpose-built buildings.

(Minerals and Waste) Most of the site is within a MSA for sand & gravel. Policy 5. Southeast section of the site nearly all within a MSA for chalk and is within the settlement boundary.

(Education) The intensification of the site, already identified for development, will place additional demands on infrastructure, and on the associated contributions to deliver it.
Based on the Council’s approved general multipliers, this level of additional development (1,500 dwellings), would generate approximately 300-450 early years’ children, 450-600 primary-aged pupils and 270-375 secondary-aged pupils. It may therefore be necessary for a 2-3 form entry primary school, with on-site early years provision.
In addition to early years and childcare provision on site at the new primary schools, it will be necessary to allocate and market additional sites suitable for full day care provision. This is partly to ensure sufficient places which would not be met by EY provision on the school sites alone, but also to promote choice and for families who are not entitled to funded childcare but still wish to access provision. Where possible, the Council would encourage the co-location of establishments to promote partnership working. The Council would also actively encourage developers to provide free plots of serviced land or purpose-built buildings.

If additional dwellings are provided as part of this allocation, then the additional infrastructure must also include provision of strategic GI, including natural greenspace, as it is highly likely that the current on-site provision will represent a significant shortfall with the increased population.

Huntingdonshire District Council has no comment.

It has been questioned before if the Maddingly Road Park and Ride should be moved. This needs to be seriously considered.

The University supports the proposed policy for an additional 1,000 – 1,500 dwellings at North West Cambridge. The site has capacity for additional development within the existing settlement boundaries as defined in the local plans and the North West Cambridge Area Action Plan.

We support the policy direction for a minimum 50% key worker housing provision. The University’s housing needs assessment will be updated in order to support the evidence base for the new Local Plan.

We do not support the Councils’ proposals for a single policy approach with West Cambridge, however:
- North West Cambridge and West Cambridge are subject to separate outline planning permissions;
- North West Cambridge is a residential-led mixed use development, whereas West Cambridge research focus;
- The sites have separate identities, reinforced through design guidance that has already been endorsed by the local authorities;
- Identities are also supported by distinct marketing and branding strategies. Eddington is promoted as new area of Cambridge that is designed for twenty-first century sustainable living. The University’s intention to develop West Cambridge as an Innovation District – and to create an identity to match that of the Cambridge Biomedical Campus and the Cambridge Science Park - may be undermined if the local authorities have separate policy for an Innovation District that incorporates North West Cambridge.

No comments

This policy will guide the continued development of the North West Cambridge (Eddington). We find there is little basis to conclude that the site can accommodate the amount of additional homes identified in the development strategy.

It is acknowledged in the Plan that the reconsidered capacity of the site will need to be informed by a detailed review of the site wide masterplan. The capacity is anticipated to be in the region of 1,000 to 1,500 homes. It is surprising at this stage of Plan making that the capacity of the site has not yet been tested before consultation with the public.

S/NWC North West Cambridge (Eddington) Cambridge Existing mixed use (Research Institutes) Contains Ancient Tree Contains:
Tree Id: 96156 Oak

This development site contains an ancient tree at the location listed above. We therefore request that any development on this site take place with appropriate measures being taken to retain and protect this tree and its root system; ie by putting in place appropriate buffering around the tree.

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.

Eddington - development for Colleges and keyworkers. Total of 4,500 homes on the M11 side.

Water
We have yet to see data to evidence that Eddington as a benchmark development on sustainability is succeeding in maintaining water usage to 100 litres/person/day. We have asked for this data which we would expect to be available, but as yet have not seen the evidence.
We would like to know how the greywater will be managed and how much land use will be required to support an increase in 1000-1500 housing units.

Medical Centre
It is imperative that the medical centre and pharmacy are provided on site for the existing population of Eddington. We are concerned that Eddington cannot support an increase of housing 1000-1500 without this facility. We understand that the physical building is available, but the delay is with NHS provision. This needs to be resolved before consent is given to a further 1000-1500 dwellings.

Primary School at Eddington
We understand that the purpose-built primary school which was primarily built to support the new population at Eddington is now over-subscribed and residents of Eddington are not being provided with places. This needs to be resolved if the population of the Eddington district is to increase by 1000-1500 dwellings.

Affordable Housing
The First Proposals state that “The North West Cambridge Area Action Plan requires a minimum of
50% affordable housing to meet the needs of Cambridge University and College key workers in housing need”. We presume that the comment on page 83 of the First Proposals, “If need is not demonstrated, provision should be in the form of normal affordable housing” means that in this eventuality only 40% of the new homes would be ‘affordable’. We believe that all new developments over a certain size should provide a minimum of 50% affordable housing and ask that this loophole be taken out (see further comments under H/AH).

Ecologically Sensitive Area within the land parcel known as 'The 19 acre field' - private market housing development site
We ask for clarification on the status and proposed use of the area generally described as an ecologically sensitive area and which has had informal signage displayed for many years not permitting public access.
Will this area be opened for public access? If so, we would ask for safeguards to prevent any resultant threats to the wildlife or environment. We welcome initiatives to increase people’s access to quality green space; however if this is indeed an ecologically sensitive area we would be concerned that use could lead to a decline in the condition of the habitat.