S/EOC: Other existing allocations on the edge of Cambridge

These are in danger of creating urban sprawl around Cambridge.

The Trumpington Residents' Association notes the reference in the text that the local developments in Trumpington are being built out and do not need a policy framework (R42, page 95). However, we stress that construction work is still underway in 2021 and there is a need for continued support for residents from all councils to ensure that the developments continue to become part of an integrated Trumpington community.

Section 2.3: Edge of Cambridge

OBJECT

The strategy for the edge of Cambridge is focussed on the delivery of strategic allocations, but ignores the sustainable villages such as Fen Ditton that are also located in this area. It is considered that the growth of the more sustainable villages must be part of the development strategy for emerging GCLP, and particularly those villages that contain a good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village.

Paragraph 79 of the NPPF seeks to promote sustainable development in rural areas and acknowledges that housing can enhance or maintain the vitality of rural communities and support local services. Paragraph 69 acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Paragraph 104 expects transport issues to be considered at the earliest stages of plan-making, and includes opportunities to promote walking, cycling and public transport use.

As set out in the representations to Policy S/DS: Development Strategy small scale housing allocations should be made in the more sustainable villages such as Fen Ditton for the following reasons: it is accessible by walking, cycling and public transport to services and facilities and employment opportunities, including within Cambridge; there is a need to support the existing services and facilities within the village; and, and there is a current identified need for 12 affordable dwellings in Fen Ditton for those with a local connection to the village, which would not be met via other means.

Mr Francis’ representations to the assessment of the land off Ditton Lane in Fen Ditton in the HELAA (Site Ref. 48148) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed. In summary, the land off Ditton Lane does not meet the criteria for designation as an Important Countryside Frontage because there are no views of the surrounding countryside and existing and planned development will further erode any relationship with the countryside. It is considered that with careful design and layout, and by locating development towards the southern part of the site, it would be possible to avoid impacts on heritage assets.

Requested Change

It is requested that the development strategy for the edge of Cambridge includes an additional residential allocation in Fen Ditton at land off Ditton Lane, with the following policy requirements:

• Site Area of 0.7 Ha
• Capacity for approx. 12 dwellings, including affordable housing
• Retain trees and hedgerows within site boundary
• Design and layout to protect and enhance heritage assets
• Development located on southern part of site only
• Northern part of site retained as open space

The housing and employment 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. If they have not already been developed since the Local Plans were adopted there may be some issues in terms of their viability. As such the Local Planning Authority should not be reliant on these sites within their housing supply figures.

The housing and employment 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. If they have not already been developed since the Local Plans were adopted there may be some issues in terms of their viability. As such the Local Planning Authority should not be reliant on these sites within their housing supply figures.

Huntingdonshire District Council has no comment.

Cambridgeshire County Council as landowner supports the limited release of land on the edge of Cambridge. These allocations are mostly of a large scale, and are mostly already committed in the previous local plan. As noted in the representations to S/DS, North East Cambridge and Cambridge Airport both rely on the relocation of existing uses and the provision of significant new infrastructure. It is therefore important to continue to support allocation of greenfield sites, including smaller greenfield sites, which can be built out faster.

Cambridgeshire County Council requests the allocation of land at Chandos Farm (reference 40141) for employment uses. The site currently comprises low density development of residential dwellings, unused paddocks and a car workshop. It is surrounded by other more intensive and higher density uses including Arthur Rank Hospice and the former Focus School. It has no links to the wider countryside and is screened from the golf club to the east by mature trees. The site therefore makes little contribution towards the Cambridge Green Belt and could be better utilised as employment land. The County requests that the site is de-allocated from the Green Belt and allocated for employment development. It is estimated that the site could accommodate around 11,350sq.m (122,000sq.ft) of employment floorspace over a three floor development, similar to the scale of the neighbouring hospice.

Cambridgeshire County Council requests the allocation of land at Newbury Farm, Worts Causeway (reference 40139). This is a greenfield site that would be available for development in the short term. It is adjacent to land recently approved for development (site GB2 in the current Local Plan) and is close to the area proposed for expansion of the Biomedical Campus. As a result the site could provide new access links between Babraham Park and Ride, site GB2 and the Biomedical Campus. It could accommodate market and affordable housing, potentially including specialist and key worker housing for the Addenbrookes site. The site could also deliver new green infrastructure on the eastern parts of the site which are more visually sensitive, which would provide biodiversity gain and open up parts of the Green Belt for public recreation.

Requested Change
It is requested that the development strategy for the Edge of Cambridge includes an additional employment allocation at Chandos Farm, as promoted by Cambridgeshire County Council, with the following policy requirements:
• Site Area of 0.76 Ha
• Capacity for approx. 11,350sq.m (122,000sq.ft) of employment development (commercial, R&D, office)
• Provide open space and green infrastructure
• Upgrade existing vehicular access from Cherry Hinton Road

It is requested that the development strategy for the Edge of Cambridge includes an additional residential allocation at Newbury Farm, Worts Causeway, as promoted by Cambridgeshire County Council, with the following policy requirements:
• Site Area of 16.34 Ha
• Capacity for approx. 300 dwellings, including affordable housing and self/custom build plots
• Retain and enhance existing trees and hedgerows at site boundary
• New pedestrian and cycle links between Babraham Road, Worts Causeway, site GB2 and Cherry Hinton Road
• Provision of open space and green infrastructure

Policy needs clarifying. While Policy S/CE Cambridge East is shown on the map (page 94) there is no reference to either the housing or employment afforded by S/CE in the descriptions. It is important to include these developments to prevent encroachment on the Green Belt and to retain the individual character of Teversham village.

OBJECT

The strategy for the edge of Cambridge is focussed on the delivery of strategic allocations, but ignores potential small sites on the edge of Cambridge that are also located in this area. It is considered that the small scale release of land from the Green Belt in sustainable locations and well related to existing neighbourhoods must be part of the strategy for the edge of Cambridge in emerging GCLP. The promoted development by Dudley Developments at land off Limekiln Road in Cambridge, is located close to Cherry Hinton.

Paragraph 69 of the NPPF acknowledges the role that small and medium sized sites can make towards meeting the housing requirements, and that such sites are often built-out relatively quickly. Paragraph 104 expects transport issues to be considered at the earliest stages of plan-making, and includes opportunities to promote walking, cycling and public transport use.

As set out in the representations to Policy S/DS: Development Strategy, there are few small scale development opportunities within the urban area of Cambridge that are not already allocated for housing or that have been assessed for residential use. Small scale housing sites on the edge of Cambridge, currently located within the Green Belt, are always overlooked as potential housing allocations regardless of whether there are any significant constraints to development or what the level of harm would be to Green Belt purposes arising from development at those sites. These sites could make a contribution towards meeting housing and affordable housing needs, and they are typically in very sustainable locations.

Dudley Development’s representations to the assessment of the land off Limekiln Road in Cambridge in the HELAA (Site Ref. 40528) comment on the potential constraints identified with the promoted development and explain how those constraints would be addressed. In summary, the site is largely surrounded by development, with residential to the north and a caravan and motorhome site to the south. There is limited visibility of the site and the existing trees at the site boundary would be retained as part of the promoted development. The promoted development includes open space, and there is other parks and open spaces available in Cherry Hinton. It is noted that Policy BG/BG: Biodiversity and Geodiversity is likely to include a requirement for developments to provide mitigation measures to address recreational impacts on nature conservation sites.

Requested Change

It is requested that the development strategy for the edge of Cambridge includes an additional residential allocation at land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road in Cambridge, as promoted by Dudley Developments, with the following policy requirements:

• Site Area of 0.88 Ha
• Capacity for approx. 14 dwellings, including affordable housing
• Retain and enhance existing trees and vegetation at site boundary
• Provide open space and green infrastructure
• Upgrade existing vehicular access on to Limekiln Road

The plans for the access into Darwin Green is from Cambridge Road, Impington (NOT Histon Road, Cambridge as is often erroneously stated) and is completely inadequate and that the simple junction so close to the King Hedges Road junction on the same Cambridge Road, Impington will inevitably cause major traffic disruption, perhaps even affecting the traffic leaving the A14.

The drainage from the Darwin Green development must be designed so that the baseflow in existing drains is not diminished. The area drains to Histon, where the brook is a major feature at The Green and the watercourse also provides good environmental conditions elsewhere as it flows though the village and beyond. Reduced baseflow would cause environmental harm (visual, possibly stagnant water, smell and ecological). This important feature must not be a victim of landscaping Darwin Green nor simplistic flood drainage management.

Policy needs clarifying. While Policy S/CE Cambridge East is shown on the map (page 94) there is no reference to the either the housing or employment afforded by S/CE in the descriptions. It is important to include these developments to prevent encroachment on the Green Belt and to retain the individual character of Teversham village.

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

The plan should ensure the green hedgerow and tree lined footpath along Worts Causeway is maintained through the development of S/EOC/GB2.

The new student accomodation at Bell School, if it goes ahead, should be sensitive to the evolving local area and be held to the standards of the new plan.

Cambridge Science Park North offers the type of industrial technical jobs and a centre of excellence that woudl be a real asset. With the location in Impington it could provide this with a site accessed by active travel and public transport (as long as intelligence restrictions were implemented) I would like this site reconsidered.

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

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

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

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

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

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

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

Map Fig 31: shows Existing and Proposed allocations outside this broad location, including North East Cambridge (Policy S/NEC).
It is noted that the corresponding Waste Water Treatment Works relocation process set out in Policy S/NEC is being led by Anglian Water under a separate process. However, map Fig 31 should also display for reference the proposed relocation site for the Waste Water Treatment Works in a similar manner to the NEC area, to provide proper context for the S/NEC Policy in terms of future land use and corresponding Green Belt cost, or neither until the DCO is approved.

Must be sensitive to the landscape and impact on natural environment.

TMLC have promoted Trumpington South within the Call for Sites, Issues & Options stages of this emerging Local Plan. The vision document for the Call for Sites sets out the following proposals for the site:
• Up to 750 zero carbon homes in operation, with a commitment to reducing and reporting on the associated embodied carbon emissions in construction as defined by the UK Green Building Council
• 40% affordable homes
• Primary school
• Mobility hub and community concierge services
• Active travel networks and segregated paths
• Car free zones and centralised parking locations
• New community and co-working facilities
• In excess of double the public open space requirements (up to 23 Ha)
• 25% net gain in biodiversity
• Up to 10% of open space planted with native trees

The emerging Local Plan has declared a climate emergency and as TMLC own the site they more flexible over the proposed development. TMLC aspirations are in the accordance with the goals of this proposed Local Plan such as promoting sustainable travel, access to public open space, higher net gain in biodiversity than Policy BG/BG, net zero homes and generally a scheme which has sustainability and climate change at its core. The site is in agricultural use with tenant farmer Trumpington Farm Company operating under a rolling Farm Business Tenancy and can be developed within the first five years of the new plan period.

The site is in the Green Belt. We consider its location on the edge of Cambridge (e.g., by Trumpington Park & Ride, close to the new Cambridge South Train Station and close to Cambridge Biomedical Campus) would be an appropriate site to be released from the Green Belt. The Greater Cambridge Green Belt Assessment (August 2021) classed the site as being ‘Relatively Significant’ according to Purpose 1, and, ‘Moderate’ according to Purpose 2 and 3. The harm rating of losing this Green Belt is ‘high’, which is a degree of harm lower than the proposed allocation at Cambridge Biomedical Campus where the harm rating is ‘very high’. In addition to the Biomedical campus expansion the site allocation also includes possible affordable housing and enhanced landscaping. Trumpington South has a lower impact than this Site and will provide a mix of development.

The Councils’ Strategic Topic Paper (page 208, Appendix 1D) states that 23 sites were submitted within the Green Belt on the edge of Cambridge. The paper states that 14 sites did not seek to justify exceptional circumstances and 4 sites did but these 18 sites were discounted. 5 sites provided bespoke arguments for exceptional circumstances and of these two were allocated within the plan (Land at Cambridge Airport and Cambridge Biomedical campus). TMLC Issues and Options and Call for Sites Vision document stated that this site could demonstrate exceptional circumstances, but the Topic Paper does not state where the site sits within the 23. TMLC would like to understand where Trumpington South sits within the review of the 23 Green Belt sites, as the site is suitable for development.

The site assessment (Ref. 40048) has a summary of red for Suitable and green for available and achievable. The Suitable criteria of red is based on 13 issues (1 as red, 8 amber and 4 green). It is not clear if the ‘further constraints’ are part of the scoring for the suitable criteria either. Based on these individual scoring TMLC doesn’t understand how the Council have concluded that this site scores as red (especially if further constraints are not included). If further constraints are included then the site scores red on landscape, impact onto the strategic road network and the Green Belt (assuming that the proforma accidentally missed including this as red). We consider the following in respect of the two first points:

• Within the Councils’ Landscape Character Assessment (2021) the site is located within Character Area 3D - Cam & Granta Tributaries Lowland Farmlands. The site serves as part of an existing Southern Fringe Area Action Plan and is land retained as undeveloped, to create an enhanced gateway into the City between Hauxton Road and the River Cam inclusive of hedgerow planting, foot and cycle paths, wildlife habitat enhancements and noise attenuation. It is considered that development at Trumpington South would have a significant impact on the local and wider landscape character. The Landscape Character Assessment identifies Trumpington Meadows as a nature reserve and within the Local Plan call for sites feedback it suggests that the Trumpington Meadows development has been designed to include a distinctive urban edge with a green foreground providing a gateway to the city. Given the character setting of the area, the LPA’s are against development which will use the M11 as an enclosing boundary. TMLC disagrees with this assessment given that the site will be designed taking into consideration and enhancing its surroundings. In addition, the vision document makes it clear that TMLC will provide double the amount of open space required, plant native trees and will have a 25% net biodiversity gain which is 5% larger than the proposed policy. TMLC aspirations is for sensitive development which enhances its surroundings.

• Highways England have considered the site to be unsuitable for development due to falling within Zone 8 (M11 North) which states that the site would need to ensure no net increase in vehicle trips onto the strategy road network. The Councils’ Housing and Economic Land Availability Assessment (HELAA) 2021 states (page 54) that this ‘does not rule out sites at this stage. However, to be acceptable in planning terms development proposals within these zones will need to demonstrate (through a Transport Assessment and Travel Plan) no net increase in vehicles trips on the strategic road network’. TMLC consider that an amber score would be more considerable given this position from Highways England. This is also based on the pending planning application for the relocation of the ‘Trumpington Park and Ride’ to the south of the M11, that Highways England consider the principle of development to be acceptable, under the assumption there will be a ‘trip budget’ approach to minimise vehicle traffic, resulting an acceptable minimal impact on the Strategic Road Network. Furthermore, the TMLC vision document sets out how the site will aim to reduce vehicle trips due to the location to key public transport nodes which TMLC consider will help mitigate vehicle trips onto the M11.

In terms of the Green Belt assessment undertaken by LUC, there are a number of important points that appear to be overlooked (in addition to the points above) and in conjunction with the landscape character of the site, which are as follows:

• Trumpington South is located within parcel TR6. This parcel includes part of Trumpington Meadows Country Park as well as the agricultural land within which the development is proposed. Previously we have argued that this area should be subdivided into two parcels reflecting the distinctive and well-defined landscapes of the country park and agricultural land. We maintain this view, especially given this distinction is incrementally becoming more pronounced as the park establishes. Notwithstanding this important point, what is undisputable is that by including the county park the scoring of how this land contributes to Green Belt purposes increases, given it form part of the River Cam corridor, a defining feature of the Cambridgeshire Green Belt. In the scoring for Cambridge Purpose 2 (setting), the LUC assessment specifically references the Country Park as part of the reasoning why this parcel is important to this Green Belt purpose.

• Further, much of the agricultural land within parcel TR6 is not proposed to be developed and will be retained as designated Green Belt. This is fundamental point as it will establish a wide and permanent green zone between the M11 and the development edge. Given a new Park and Ride is proposed south of the M11, in combination this would establish a permanent land use arrangement between Trumpington and Hauxton. This would not only meet the obligation that once a new Green Belt boundary is established it shouldn’t be altered at the end of the plan period, but also ensure sprawl (National Purpose 1) and encroachment (National Purpose 3) could not occur. Indeed the masterplan for Trumpington South has be configured to specifically to achieve this objective.

• It is relevant to note that the overall assessment for this parcel has determined that the level of harm is less than the surrounding land. This reflects parcel TR6 immediate relationship to the existing urban edge and the strong existing boundaries that are readily recognisable and permanent, fully in accordance with policy 143 of the NPPF. When considering the additional point highlighted above it is considered that the overall harm assessment of High for parcel TR6 should be reduced.

TMLC consider that the site has been incorrectly scored as per the points set out above and consider that it is suitable for development.

OBJECT

As highlighted in the North BRLOG representations to Policy S/DS: Development Strategy, the key parts of the development strategy for emerging GCLP comprises the delivery of extensions to Cambourne, the planned new settlements at Northstowe, Waterbeach and Bourn Airfield, and the new communities on the edge of Cambridge at North East Cambridge and Cambridge East. These are all complex developments that also require the delivery of transport and community infrastructure. The predicted housing delivery rates at these developments are challenging. Most of these developments will provide less affordable housing than required by policy, at least in the initial phases, to reflect the amount of infrastructure that is needed. It should be a concern for emerging GCLP that most of the strategic sites will not provide enough affordable housing, particularly in an area such as Greater Cambridge which has significant housing affordability issues. In contrast, there is sufficient residual value in strategic greenfield sites on the edge of Cambridge to support planning obligations and policy requirements in full, including affordable housing. The proposed redevelopments at North East Cambridge and Cambridge East are complex and involve the relocation of the existing uses.

Paragraph 140 of the NPPF allows land to be released from the Green Belt through the plan-making process where exceptional circumstances exist. It is considered that exceptional circumstances exist to release land from the Green Belt around Cambridge, which are related to the significant need for housing and affordable housing in Greater Cambridge, and the need for additional housing to support the economic growth of Greater Cambridge. The cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely a large proportion of those journeys are undertaken by car this would add to traffic congestion and air pollution.

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport.

The promoted development by North BRLOG at South West Cambridge would include market and affordable housing, it is accessible by sustainable modes of transport, and is well-related to employment opportunities.

Therefore, it is considered that the development strategy for emerging GCLP should also include additional allocations on the edge of Cambridge at South West Cambridge.

The following reports were submitted with the North BRLOG representations at Issues & Option stage to support the promoted development at South West Cambridge:
• Vision Document (David Lock Associates)
• Landscape and Visual Appraisal and Green Belt Review (The Landscape Partnership)
• Initial Noise Assessment (WSP)
• Air Quality Constraints Report (WSP)
• Archaeological Desk Based Assessment (Cambridge Archaeological Unit)
• Preliminary Ecological Appraisal (The Landscape Partnership)
• Flood Risk and Drainage Appraisal (Peter Brett Associates)
• Initial Heritage Impact Assessment (Bidwells)
• Transport Technical Note (WSP)

The benefits of the promoted development include the following:
• the provision of housing and affordable housing for key workers and others, including but not limited to University and College staff;
• the provision of residential accommodation for the elderly, including care provision;
• the provision of new tenures such as ‘Build to Rent’, co-living and intra-generational housing;
• accessible parkland with potential connections to Coton Countryside Reserve offering significant scope for biodiversity enhancement;
• delivery of green infrastructure in the form of publicly accessible open space providing access from the City to the countryside to the west of Cambridge;
• other green infrastructure and strategic landscaping, including new woodland planting to address visual impact and provide a buffer with the M11 to address noise and air quality impacts;
• improvements to walking and cycling routes to encourage travel by non-car modes of transport, which is far more attainable for an edge of City Centre site;
• potential to provide land for the Cambourne to Cambridge Bus Strategy and the Comberton and Barton Greenways which are Greater Cambridge Partnership projects;
• the creation of additional north south public transport and cycle routes, connecting Barton Road to Madingley Road, and the provision of connections to existing developments at NW Cambridge, West Cambridge and Addenbrookes/Cambridge Biomedical Campus;
• the provision of a new local centre for the west Cambridge area as well as additional health and education facilities.

The promoted development would be consistent with the relevant policies contained in Section 3.1: Climate Change, Section 3.2: Biodiversity and Green Spaces, Section 3.3: Wellbeing & Social Inclusion; Section 3.4: Great Places; Section 3.6: Homes and Section 3.7: Infrastructure of emerging GCLP.

The landowners - Corpus Christi College, Jesus College, St John’s College, Downing College and the University of Cambridge - have a long-standing commitment to Cambridge and its future and will continue to be neighbours of the promoted development. North BRLOG are committed to the identified benefits and policy aims and their long-term stewardship of the site will assist in delivering these.

For all these reasons, the site at South West Cambridge should be allocated for a landscape-led urban extension in the emerging GCLP. The Vision Document for South West Cambridge could form the basis for a site specific policy and additional allocation on the edge of Cambridge. The key policy requirements for the promoted development are set out in the requested changes.

Requested Change

Additional Allocation at Edge of Cambridge: Land at South West Cambridge

A landscape-led urban extension to Cambridge of high-quality, with high sustainability standards and delivering a net gain in biodiversity.

The promoted development contains the following mix of uses:

• Between 2,500 and 2,800 dwellings including market and affordable/social housing with a range of tenures and densities to include housing for University and/or College staff, housing for elderly people (including care) and student accommodation;
• A comprehensive new green infrastructure network comprising open space and sports pitches, a new country park with connections to Coton Countryside Reserve, wildlife areas and biodiversity enhancement, and strategic landscaping including new woodland planting;
• Creation of new flood meadows and the potential re-wilding of Bin brook in certain locations to enhance capacity and its ecological benefits;
• A green landscape edge to the M11 to provide a landscape setting to the South West of Cambridge;
• A community facility including primary school, community centre, health centre;
• A neighbourhood centre including food store and other shops, services and facilities to serve the local community, nearby residents and the West Cambridge campus;
• Enhanced pedestrian and cycle connections to the existing and planned walking, cycling and public transport network in the local area, and a development which places the needs of pedestrians and cyclists ahead of car users;
• A network of streets and spaces that are diverse in their function and character;
• A public transport corridor that will link the site with other service and routes and to other City destinations;
• High levels of energy performance in building design that follows best practice in energy and carbon reduction; and
• Sustainability measures including a water recycling system, district heating system and underground waste collection system.

As set out in our comments on Policies S/DS and H/SH, we do not consider that sufficient sites are identified to meet the objectively assessed housing need within the Plan period, predominantly due to the uncertainty surrounding the anticipated delivery rates and timescales for a number of the proposed allocations.

The land to the east of Ditton Lane, Fen Ditton (Site Reference: 40217) was assessed as an Edge of Cambridge: Green Belt site, although not selected for allocation. The site has been promoted by Scott Properties through the Plan process to date for specialist accommodation for older people, on a small part of the northern area of the site, with the southern half of the site proposed as open space and landscaping.

The site received a ‘red’ score within the HELAA in respect of suitability, on Townscape and Landscape grounds. Within this part of the assessment, the site is described as ‘an important green separation between Cambridge and the village of Fen Ditton. Development of this site would have an adverse effect on the landscape character for the setting of both Cambridge and Fen Ditton and contribute to their amalgamation. It is considered that there are no options for even limited development on this site.’

We dispute this conclusion. Firstly, limited development of the site would not result in the amalgamation of Cambridge and Fen Ditton, as demonstrated both within the Call for Sites submission and the accompanying Masterplan Concept Layout. The proposals for the site include development of a northern section only, extending to approximately 1.6ha, which would leave the majority of the site open, retaining the separation between the two areas, and providing considerable biodiversity and recreational benefits.

Further, development in the northern area of the site as identified within the Masterplan Concept Layout would not result in an adverse effect on the landscape character. This area is closely related to the existing residential development along Ditton Lane and High Ditch Road, with existing and planned landscaping acting as a considerable buffer to provide effective visual screening from the wider area.

We are unsure therefore, how it can be concluded that there are no options for limited development on the site. For the above reasons, we consider that the site should have received an ‘amber’ score for suitability, recognising that very few sites, including those proposed for allocation, received a ‘green’ for suitability within the HELAA. There are a number of other elements within the site’s assessment which we believe have been unreasonably scored ‘amber’.
We are unclear why sites have been assessed against their compliance with existing policy, particularly when the reason for this process is to produce a new Plan which will supersede existing policy.

We consider that scoring sites ‘amber’ due to being outside of the Development Framework is unnecessary; the purpose of the plan is to identify additional sites for allocation, and it has been established through the initial work undertaken that this will need to include sites outside of existing settlement boundaries.

The site receives an ‘amber’ score for Flood Risk due to the identified small risk of surface water flooding in a small area within the south-eastern corner of the site. However, as detailed within the site’s submission to the Call for Sites and Issues and Options consultation, and the Masterplan Concept Layout accompanying these representations, this area is proposed for landscaping and open space, therefore there would be no development within this area, and as such the site should have received a ‘green’ score.

The site scores ‘amber’ in relation to Historic Environment. This erroneously states that the site is within a Conservation Area. We would refer to the Fen Ditton Conservation Area (Draft Council policy (Ref: DCV 0029) (2005) as well as the South Cambridge Adopted Policies Map, neither of which show the site within the Conservation Area. The conclusions state that ‘development of the site could have a detrimental impact on a designated or non-designated heritage asset or the setting of a designated or non-designated heritage asset, but the impact could be reasonably mitigated.’

The nearest listed asset is noted as being within 100m. There are three Grade II listed buildings along High Ditch Road to the north of the site, however, these buildings are clearly visually separated from the site by considerable existing landscaping to the boundaries of these properties, therefore we agree that any impact on the heritage assets could be reasonably mitigated. As such, and given the site is not located within the Conservation Area, the scored should be ‘green’.

We question why the site received an ‘amber’ score for site access, despite stating that the proposed site is acceptable in principle subject to detailed design. An Access Drawing was submitted in support of the site to the Issues and Options Consultation and accompanies this submission, which shows that a safe and suitable access could be achieved from Ditton Lane. As such, we consider that there are no potential access constraints and therefore this score should be ‘green’.

The site scores ‘amber’ in respect of transport and roads, despite concluding that any potential impact on the functioning of trunk roads and/or local roads could be reasonably mitigated. The assessment also states that passenger transport, walking and cycling links and links to the public transport corridor should be considered. It is detailed with the assessment of accessibility to services and facilities that the site has good accessibility to key local services, transport and employment opportunities, which includes public transport less than 450m from the site. The site could provide connectivity into the existing public rights of way network immediately surrounding the site, which includes a cycle path to the south. This provides alternative and sustainable methods of transport and provides ease of access into the surrounding areas, including the public transport network thereby reducing the reliance on the car. As such, the site’s score should be ‘green’.

In relation to noise, vibration, odour and light pollution, the site scores ‘amber’ with the assessment concluding that the site will be affected by road noise from nearby main roads. We question how a definitive conclusion on this has been reached in the absence of any noise studies having been undertaken on the site. Given that built form on the site would be focused within the northernmost part of the site, adjacent to existing residential development along Ditton Lane and High Ditch Road, with additional landscaping to the south, there would be limited risk of road traffic noise affecting the site. A such, we consider this should be ‘green’.

The Strategic Highways Impact assessment identifies the site as being within Highways England Zone 3 – A14 Cambridge Northern Bypass, which has no capacity for growth. Annex 2 to the HELAA Report confirms that:

‘This assessment was based upon the capacity of junctions, as these are the pinch points on the road network which causes traffic congestion. A catchment area or zone was agreed with Highways England, as shown on the map below. These zones are drawn around each junction on the strategic road network to reflect the catchment area or roads which feed into those junctions.’

The site is located on the very southern edge of Zone 3, and on the border with Zones 1 and 4; Cambridge and the A14 East, both of which have a ‘green’ RAG score, and capacity for growth. The arbitrary approach taken fails to recognise that sites located within the outer proximities of the Zones may actually relate better in transport terms to the adjacent Zones, which have capacity for growth.

We consider that reassessment of the land east of Ditton Lane, Fen Ditton (Site Reference: 40217) shows that it represents a suitable, available and achievable site for development, and as acknowledged within the HELAA, it benefits from close proximity to a number of key services and facilities, as well as public transport links, owing to its location on the edge of Cambridge. It is also closely located to the land north of Newmarket Road, which alongside new homes will deliver community facilities and a food store, in addition to a number of additional cycleways and footways, which run along the southern boundary of the land east of Ditton Lane, and connect into the existing public right of way through the eastern part of the site.

The land east of Ditton Lane (Site Reference: 40217) falls within Parcel FD7 within the Green Belt Assessment. The majority of the area within which built form is proposed falls within an area assessed to have a ‘moderate high’ rating for release from the Green Belt, one of only three parcels within Fen Ditton assessed as such, the lowest of the harm ratings within the settlement. The remainder of parcel FD7, the majority of which is proposed as open space, is assessed as having a ‘high’ harm rating, although this parcel is combined with a parcel of land to the west of Ditton Lane. We question why the assessment fails to recognise the presence of Ditton Lane, which clearly separates the two areas both physically and visually, owing to the presence of mature trees to both sides of Ditton Lane. Neither parcel is visible from Ditton Lane, therefore there is no relationship between the two areas, which the assessment fails to recognise.

Parcel FD7’s contribution to the three Cambridge Green Belt purposes is assessed to be ‘moderate’, with the impact on the contribution of adjacent Green Belt assessed as being ‘minor-moderate’ (for the west and southern parts) and ‘minor’ for the northern part. As such, we question how the assessment could arrive at a conclusion that the overall harm of Green Belt release would be ‘high’ in the absence of any assessment of harm being greater than moderate. As such, the harm rating should be amended to ‘moderate’ to reflect the conclusions of the assessment, which would make it the most suitable parcel within Fen Ditton for release from the Green Belt.

Further, we dispute the accuracy of the conclusions that the release of land within only the north-eastern part of this parcel would still result in the removal of the settlement gap between Fen Ditton and Cambridge (Barnwell). Whilst this is true if development of the entirety of this parcel were to occur, development of part of this area would enable the separation to be maintained, which the assessment fails to recognise. The Masterplan Concept Layout accompanying this submission shows how development of the land east of Ditton Lane could be achieved whilst maintaining a sizeable area of openness to the south, therefore resulting in no merging of Fen Ditton and Cambridge (Barnwell).

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.

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 would OBJECT if any of these developments encroach on the Green Belt or endanger the individual character of Fen Ditton, Horningsea and Teversham villages.

Cambridgeshire County Council as landowner supports the limited release of land on the edge of Cambridge. These allocations are mostly of a large scale, and are mostly already committed in the previous local plan. As noted in the representations to S/DS, North East Cambridge and Cambridge Airport both rely on the relocation of existing uses and the provision of significant new infrastructure. It is therefore important to continue to support allocation of greenfield sites, including smaller greenfield sites, which can be built out faster.

Cambridgeshire County Council requests the allocation of land at Chandos Farm (reference 40141) for employment uses. The site currently comprises low density development of residential dwellings, unused paddocks and a car workshop. It is surrounded by other more intensive and higher density uses including Arthur Rank Hospice and the former Focus School. It has no links to the wider countryside and is screened from the golf club to the east by mature trees. The site therefore makes little contribution towards the Cambridge Green Belt and could be better utilised as employment land. The County requests that the site is de-allocated from the Green Belt and allocated for employment development. It is estimated that the site could accommodate around 11,350sq.m (122,000sq.ft) of employment floorspace over a three floor development, similar to the scale of the neighbouring hospice.

Cambridgeshire County Council requests the allocation of land at Newbury Farm, Worts Causeway (reference 40139). This is a greenfield site that would be available for development in the short term. It is adjacent to land recently approved for development (site GB2 in the current Local Plan) and is close to the area proposed for expansion of the Biomedical Campus. As a result the site could provide new access links between Babraham Park and Ride, site GB2 and the Biomedical Campus. It could accommodate market and affordable housing, potentially including specialist and key worker housing for the Addenbrookes site. The site could also deliver new green infrastructure on the eastern parts of the site which are more visually sensitive, which would provide biodiversity gain and open up parts of the Green Belt for public recreation.

Requested Change
It is requested that the development strategy for the Edge of Cambridge includes an additional employment allocation at Chandos Farm, as promoted by Cambridgeshire County Council, with the following policy requirements:
• Site Area of 0.76 Ha
• Capacity for approx. 11,350sq.m (122,000sq.ft) of employment development (commercial, R&D, office)
• Provide open space and green infrastructure
• Upgrade existing vehicular access from Cherry Hinton Road

It is requested that the development strategy for the Edge of Cambridge includes an additional residential allocation at Newbury Farm, Worts Causeway, as promoted by Cambridgeshire County Council, with the following policy requirements:
• Site Area of 16.34 Ha
• Capacity for approx. 300 dwellings, including affordable housing and self/custom build plots
• Retain and enhance existing trees and hedgerows at site boundary
• New pedestrian and cycle links between Babraham Road, Worts Causeway, site GB2 and Cherry Hinton Road
• Provision of open space and green infrastructure