S/BRC: Babraham Research Campus

Co-locate the research campus where the majority of new homes are - e.g, in Cambourne. It makes no sense to develop the majority of the new housing north of the city and then create new emploment clusters south of the city.

This is in the green belt and needs protection from excessive development.

(Minerals and Waste) All within a MSA for chalk; nearly all is within a MSA for sand & gravel. MWLP Policy 5 applies.

Huntingdonshire District Council agree with the proposed policy if the release of green belt does not impact on important landscape features, biodiversity and heritage. It is agreed that development should be restricted to research and development (use class (E(g)(ii) Research and development of products or processes) and appropriate supporting ancillary uses and infrastructure.

The listed buildings here are an important part of there heritage. Again, supporting research important but that also includes affordable homes for those supporting the research generally (eg lower level staff who's services are still required).

Given the proximity to various footpaths around Babraham village and the river Granta, it would be good if the plan could include publically accessible footpaths through the campus and similar opening up of the campus to members of the public like Hinxton.

Removing this site from the Greenbelt will remove very important constraints on planning and should not be allowed. The Close is adjacent to the village - a conservation area - and must remain under the strictest planning constraints to make sure that development is extremely sensitively handled. There has been enormous development in the Babraham Research Campus already, despite its greenbelt location, so removing this could be extremely detrimental to the village character, housing density and infrastructure. Removing the Campus from the greenbelt will undoubtedly invite over-development.

I have major concerns about removing this land from the green belt because of the impact this will have on the settings of Grade 1 and 2 listed buildings, particularly Babraham Hall's historic open parkland setting within the village and as well as the impact on wildlife habitats and impact of water abstraction requirements from thriver Granta which will damage the ecological balance the chalk streams and associated habitats. This will also put excessive pressure on the infrastructure and amenities of a village of 130 houses. Please see detailed submission from Patrick Axon.

Support the work done here, but concerns over availability of suitably priced housing

The same principles should be applied to this green belt release as for Policy S/CBC: Cambridge Biomedical Campus, namely that “National Planning policy requires that the impact of removing land from the Green Belt to be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”.

The Preferred Options documents do not seem to recognise that this site is located within the Cambridge Nature Network (www.cambridgenaturenetwork.org) and that it is adjacent to two strategic green infrastructure areas making it an important site (Green Infrastructure Strategic Initiatives: Gog Magog Hills (3) and River Cam Corridor (2c)). We would expect the proposals in the policy area to reflect this with a very strong emphasis on biodiversity enhancement within or adjacent to the grounds of the campus combined with better public access/benefits. We note that google earth seems to show an area of exposed chalk in the south-west corner which could provide an opportunity for ecological restoration of priority calcareous grassland habitat.

The proposals for this policy area must recognise that the area identified for development would be on much higher ground than those buildings that have already been built on the campus (which are sunk into the hillside). This location is sensitive in landscape character terms, being visible from the higher ground of the Gog Magog Hills, including from the Roman Road Schedule Ancient Monument. There is a potential conflict between the development of this site and policies designed to protect landscape character. To be acceptable in planning terms, any new buildings would need to be below tree height as viewed from the Gog Magog Hills (including any chimneys or rooftop plant), they should also be designed to blend into the landscape when viewed at distance.

One of the newer buildings on the campus has already had a very negative impact on landscape which is contrary to planning policy and, in our view, should not have been granted permission (see attached photos taken from a public right of way on the Gog Magog Hills). We request that before any future development of the site takes place there is a requirement for retrospective action to screen this building and/or better blend it into the landscape when viewed at distance.

The identification of Land at Babraham Research Campus to be allocated as a proposed Policy Area for employment development, comprising the existing built area of the Campus and further areas adjoining the existing built area of the Campus, and the release of land within the Policy Area from the Green Belt is supported.
The identification for expansion of the Campus, comprising redevelopment of existing areas of the Campus and development of land adjoining the Campus is also supported.
The Council’s Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) provides a detailed understanding of potential future employment change for all jobs in the area, including exploring the key sectors that drive employment growth in the Greater Cambridge area.
The Study confirms that Life Science cluster in Greater Cambridge continues to grow with a need for additional research and development laboratory space identified. Businesses are looking for flexible workspace where new and growing businesses can locate and, with time, expand. Life science companies tend to prefer to cluster together and close to research institutes and, in some cases clinical medicine, in order to benefit from the exchange of ideas, information, resources.
Appendix H of the Councils Employment Land and Economic Development Evidence Study provides a summary of land availability in Greater Cambridge. The Babraham Institute (the historical name for the Campus) is included under site reference 45 and the summary notes that “intensification opportunities are limited given greenbelt sensitivities”. The Policy Recommendation within the summary is subsequently confirmed as “the site should be
considered for employment designation”.
This growing need for additional research and development laboratory space is further evidenced by the Socio-Economic Assessment undertaken by Bidwells LLP on behalf of BRC Ltd (Appendix 3). This confirms that the Babraham Research Campus continues to be hugely successful and has seen rapid growth over the last five years, with a considerable amount of interest recorded by BRC Ltd by both existing tenants wanting more space and others wanting to be relocated to the Campus.
As a distinct co-location of academic research and commercial bioscience enterprise, the Campus has been highly successful in attracting companies to the site and is driving investment in the Cambridge Southern Research Cluster.
In practice, these distinct set of characteristics are not available anywhere else in the sub-region, or indeed the UK. The key point of difference when compared to other science and R&D centres in the country is the support infrastructure offered to start-ups, which gives the Campus its unique role within the life science research and development ecosystem.
The existing Campus is fully occupied and continues to experience high demand for space from both existing and prospective occupiers, with demand significantly outstripping supply. The Campus is operating with either no or virtually no void.
The rapid success of the Campus has now stalled and this has become a significant barrier to growth. Therefore, a key priority for the Campus is to enhance support to enable companies to continue to start-up, scale-up, grow and be retained in the UK.
For this to happen, further expansion is required, across all stages of the life science discovery and development lifecycle – from communal lab space to enable lone entrepreneurs and small ventures to test their science through to bespoke buildings to facilitate scale-up without the need to relocate. Such an approach is entirely consistent with the objectives of both national and local planning policy to support economic growth and particularly clusters of knowledge-driven, creative and high technology industries.
Specific to BRC, there is also a need for additional dedicated housing at the Campus. The BRC thrives in attracting the brightest minds in the biotech sector. Many are initially doctoral graduates of Cambridge University but originate from outside of the UK, do not have specific ties to the UK and will receive offers from across the world. If they are to be retained in the Greater Cambridge area, they need initial accommodation – a first step on the housing ladder. There is also a need for dedicated housing at the Campus for key underpinning support staff that operate the facilities at the Campus.
If this housing is not co-located with the Campus and provided only for employees at the site, those the BRC is seeking to attract will need to compete with the rest of the housing market.
While the Greater Cambridge Local Plan will facilitate higher rates of housing delivery, it will be sometime before this has a meaningful effect on house prices and availability. The BRC needs the accommodation now otherwise the rapid growth of the Campus seen in recent years is likely to stall. Co-locating housing with the employment will also reduce the need for staff and visitors to travel to/from off-site and therefore increase the internalisation of movements generated by the site. This will reduce the expansion’s impacts on transport infrastructure and services in the wider area.
In order to achieve the identified development aspirations it is appropriate to release the developed area of the Campus and adjoining land from the Green Belt. The area proposed for release from the Green Belt consists of the existing developed part of the Campus, in addition to two parcels of undeveloped land immediately to the south and north-west of buildings B940 and B950.
All other reasonable options for meeting the identified development needs have been explored and exceptional circumstances have been demonstrated to justify the release of land from the Green Belt.

Boundary of proposed Policy Area
The boundary of the proposed Policy Area is broadly supported but it needs to exclude the Church and Church Lane as that falls outside of the Campus estate.

Proposed Policy Direction
Remove the developed area of the Campus from the Green Belt.
The removal of the developed area of the Campus from the Green Belt is supported.
A Cambridge Green Belt Study (2021) has been prepared in support of the First Proposals consultation. The focus of the Study is to identify the contribution the Green Belt land makes to the Cambridge Green Belt purposes and the harm that is likely to result from expanding existing inset settlements (or settlements bordering the Green Belt’s outer edge).
The purposes of the Cambridge Green Belt are set out in Policy S/4 of the adopted South Cambridgeshire Local Plan, namely to:
● Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre;
● Maintain and enhance the quality of its setting; and
● Prevent communities in the environs of Cambridge from merging into one another and with the city.
The developed area of the Campus is identified within the Study as falling within Parcel BA2.
The Study concludes that the parcel has ‘low harm’ if released from the Green Belt. The parcel scored Limited/No Contribution to the first Purpose of the Cambridge Green Belt and Relatively Limited to the remaining two.
A Landscape and Visual Appraisal (LVA) and Green Belt Study has also been prepared by Bidwells LLP (Appendix 4) in support of these representations. The Green Belt Study assesses the impact of the proposed Campus expansion on the qualities of the Green Belt and makes recommendations about the appropriateness of removing the site from the Green Belt together with recommendations to inform the ongoing refinement of the design proposals.
The Site is largely well screened by the existing vegetation; the woodland density would also filter views during winter months. Furthermore, the proposed siting of the buildings preserves a compact built form, avoiding inappropriate sprawl. However, it is acknowledged that the proposed buildings will be visible in some views from Bridleway 12/12 close to the Campus. As seen from this location, the proposed development would reduce the gap between the existing buildings, resulting in some loss of a sense of openness within the Campus.
The Bidwells Green Belt Study concludes, in alignment with the Cambridge Green Belt Study (2021), that the proposed Campus expansion would result in a low level of harm. The analysis of visual and landscape aspects of the effects on the Green Belt found that the overall qualities and openness of the Cambridge Green Belt would be preserved, and the proposal will not cause harm. Where adverse effects are identified, these are limited to a very local scale (i.e. the Campus and its immediate context) and a restricted group of receptors (i.e. users of the Campus and nearby PRoWs).

Remove from the Green Belt and allocate an additional area for employment development (research and development) of 17.1 hectares within and adjoining the existing built area of the campus
The removal of the built area of the Campus and land adjoining the existing built area of the Campus from the Green Belt is supported.
It is not clear how the Council’s have calculated 17.1 hectares and BRC Ltd would welcome a discussion to clarify this. At this stage, the additional employment land (research and development) proposed to be delivered as part of the Campus expansion, through both redevelopment of the existing built area of the Campus and on land adjoining the Campus equates to 9.4 hectares (and circa 28,870 sqm of floorspace).

Identify the whole site release from the Green Belt as a Policy Area, requiring any proposals to:
− Restrict development to research and development (use class (E(g)(ii) Research and development of products or processes) and appropriate supporting ancillary uses and infrastructure.
This is Supported.

− Protect and enhance the landscaped setting of the site
BRC Ltd are committed to sustaining and improving the landscaped setting of the Campus.
An ecology and landscape-led approach has been taken within the emerging Campus expansion masterplan with health and wellbeing also playing an important role within the design process.
The masterplan responds to the existing strong landscape structure and important ecological features found within the Campus and wider area.
The masterplan also illustrates the diverse landscape typologies proposed within the vision, enhances screening to the existing and proposed built form and incorporates biodiversity enhancements. The strategy is to deliver at least 20% Biodiversity Net Gain.
The emerging illustrative masterplan for the Campus has also been informed by a Landscape and Visual Appraisal of the site (Appendix 4). This concluded that the proposal would not result in adverse visual effects on the overall openness of the Green Belt and there would be no adverse effects on the wider qualities of the Cambridge Green Belt, as the proposal would not alter the existing landscape character.
Notwithstanding this, the following design principles are recommended to be applied to future detailing of the Campus expansion in order to protect and enhance the landscaped setting of the site;
● Dense planting around built development to the west and north-west in order to mitigate visual effects experienced by receptors on the bridleway 12/12, road users on Babraham Road and residents at the edge of Sawston;
● Larger tree specimens to the north of the proposal to filter possible glimpses of the proposed built form and flues in views from the Roman Road recreational footpath (E2 European Long Distance Route);
● Retention of open, grassland landscape to the west of the Site to preserve the river landscape character and retain the capacity to improve and support the River Granta GI corridor;
● Internal green gaps between the existing and proposed built form to retain some local sense of openness.
It is noted that the mitigation of visual effects would be reliant on the successful establishment of proposed planting. Therefore, appropriate landscape maintenance plans can also be prepared to ensure the planting will thrive and grow successfully.

− Preserve the appearance of the conservation areas, and the setting of the Grade II Listed Babraham Hall and the Grade I Listed St Peters Church.
An initial Built Heritage Appraisal has been prepared by Bidwells LLP in support of these representations (Appendix 5). The Appraisal identifies the heritage assets which may be affected by the proposed allocation with reference to Section 66(1) and 72(1) of the Planning (Listed Buildings & Conservation Areas) Act 1990 and the National Planning Policy Framework (NPPF) where the impact of development on built heritage assets or their settings is being considered (Paragraphs 194-207).
The Appraisal also includes a site sensitivity plan, relating to built heritage only, which has been used to guide the potential approach to the location of development zones and inform the emerging illustrative masterplan for the Campus expansion. This takes into account the significance and setting of the identified built heritage assets as well as views in, out and across them.
The Appraisal concludes with an assessment of the initial impacts in terms of built heritage in the context of the emerging illustrative masterplan. This concludes the following:
● Key views to, from and across Babraham Hall are maintained. It is noted that some of the proposed developments are likely to be seen in the context of the Hall and as such, their detailed design, scale and massing will have to be carefully considered moving forward. This is also the case for the sited which are in proximity to the Parish Church of St Peter and the Babraham Conservation Area.
● A significant landscape is retained around the site maintaining a clear sense of the open and green landscape setting it currently holds. As such, the historic functional and visual contribution the site makes to the setting of the listed buildings within the site and the Conservation Area (and the assets this holds) is maintained. This also ensures a retained connectivity between the assets and the wider countryside which contributes to their wider
setting, context and understanding.
● Additional woodland, individual trees, copses planting, scrub planting, orchard and grassland planting are all proposed to strengthen the biodiversity of the site and enhance its green character. This is further reinforced with the addition of a proposed wetland and restored pond.
● Where areas of additional built form are proposed, the placement and location of these have been carefully considered. As shown on the illustrative masterplan, these are limited to areas which are either already developed or within areas that are in close proximity to developed areas. This creates a clear grouping to the built form within the site, providing a clear understanding of the evolution of it and allows for its continued growth to be achieved in
a manner which respects the heritage and landscape setting in which the site is located.
The Appraisal concludes that, at this early stage, if masterplanning is further developed to ensure impacts on built heritage assets are mitigated or removed altogether these impacts are likely to be at the level of “less than substantial” harm in terms of the policies of the NPPF – although it is not possible to define any more precisely the levels of impact at this stage until more detail is available.

− Protect and enhance the corridor of the River Granta (recognised as a county wildlife site)
BRC Ltd are committed to protecting and enhancing the corridor of the River Granta.
A priority for BRC’s approach to nature is, in the first instance, retaining the existing ecological value such as the flood plain which provides flood alleviation and locks up carbon. Overall, Campus expansion will enhance ecological value by delivering at least a 20% biodiversity net gain (BNG) in line with Natural Cambridgeshire’s Vision of doubling the nature conservation value of the area by 2050. This will consist of wider enhancements to the campus, including improvements to the river systems.
The biodiversity enhancements proposed specific to the corridor of the River Granta include:
● Restoring minor watercourses to a more meandering profile; reduce bankside gradient to a shallow cross-sectional profile and remove overhanging/shading trees;
● Allowing the river to overflow into low lying areas of chalk scrapes;
● River enhancement works including creation of riffles, bed-raising, localised regrading of banks to a more shallow profile, adaptation or removal of weir to enable fish passage and sensitive management of riverside trees and shrubs (in liaison with Wild Trout Trust).
Further detail on biodiversity enhancements are provided in the Preliminary Ecological Appraisal prepared by The Landscape Partnership which accompany these representations (Appendix 7).

− Take steps to include sustainable travel opportunities, including the opportunities provided by the planned Cambridge South East Transport Scheme (CSET).
A Transport Strategic Overview and Access and Movement Strategy has been prepared by Stantec and accompanies these representations (Appendix 8).
The Strategy sets out the access and movement ambition and commitments for BRC and has been used to inform the emerging Illustrative Masterplan for the campus expansion. BRC’s strategy is based on a sustainable expansion that integrates with existing and committed walking, cycling and public transport networks, such as the CSET scheme, so that the expansion has excellent connectivity with surrounding areas by these modes, as well as continued permeability through the Campus site.
The Strategy embraces a change in focus away from “highways” to a much more holistic “transport” approach, where mobility is provided by sustainable travel modes. This will ensure that the expansion of the Campus meets employees’ needs to travel to work by a choice of sustainable travel modes, along with promoting healthy lifestyles and delivering a sustainable, vibrant, and socially inclusive workplace. The key elements of the Strategy are summarised below;
Reducing the Need to Travel by Car and Build in Healthy Lifestyles
● The expansion in R&D facilities will be combined with additional on-site residential dwellings, for campus staff key workers, visiting scientists and PhD students at the Campus, which will reduce the need for staff and visitors to travel to/from off-site and therefore increase the internalisation of movements generated by the site. This will reduce the expansion’s impacts on transport infrastructure and services in the wider area;
● The expansion will include a comprehensive network of foot and cycle paths to provide safe, logical, convenient, and attractive links internally to the existing Campus’s R&D facilities, facilities and also residential dwellings;
● The existing and proposed expansion’s internal layout will create a high-quality development, engendering the feeling of a sense of ‘place’ in which staff and visitors experience pleasant landscaping, outdoor social areas and ‘shared accesses’ not ‘roads’ within the site. This will help with the vision of creating a healthy, socially inclusive, and well-connected campus.
Maximising Opportunities for New Types of Mobility
● New technologies, changing travel patterns and the focus on zero carbon will play a pivotal role in how we plan new developments. The transport strategy and planning for the campus expansion will need to be flexible and resilient so that it is responsive to these changes in order to maximise the resulting opportunities for new types of mobility. One example is that the developing masterplan includes for EV Charging bays and the ducting infrastructure to potentially connect more bays with a charging point in the longer term future to meet demand.
Prioritising Walking and Cycling for Local Trips
● The campus expansion will provide high quality walking and cycling connections to the surrounding countryside and committed sustainable infrastructure, including the Linton Greenway, and the numerous footpaths and bridleway surrounding the campus.
● Walking and cycling will be encouraged as part of a Travel Plan that will be prepared for the expansion and this Travel Plan will build on the existing successful Campus Travel Plan.
Maximising the Use of Public Transport
● As part of the expansion, Babraham Research Campus will work with the Greater Cambridge Partnership (GCP) to develop a public transport strategy that makes full use of the committed Cambridge South East Transport Scheme (CSET) public transport strategy and infrastructure. This could include new and / or extensions of the CSET committed bus services into the site;
● To maximise the use of public transport, the strategy for the campus expansion will include proactive encouragement to staff and visitors to use these improved bus services. This would be part of the continued updates to the existing Campus Travel Plan;
● Internal footways and cycleways will be connected up to the existing bus services operating along the A1307 that have and will continue to be improved as part of CSET Phase 1. They will also connect to the future committed public transport route that will run south of the site as part of CSET Phase 2.
Private Car Strategy
● The existing onsite theme of prioritising cyclists and pedestrians over motorised vehicles will be continued for each development zone, with cycle parking located close to main building entrances and linked to appropriate desire lines. The existing arrangement to direct all motorised employment traffic through the A1307 access roundabout will be continued to limit impact on the adjacent Babraham Village;
● Car parking provision will be balanced at a level which recognises likely demand, but also seeks to deter habitual car use for journeys that could be made by non-car modes. To meet this balance the existing campus parking/ floor area ratio will be continued into the expansion, or reduced, to allow levels much lower than current / future maximum local policy ratios;
● Car club spaces should also be provided as part of the expansion, so that staff can have access to a car but do not need to own one.
As referred to above, the Greater Cambridge Partnership (GCP) are planning transport improvements along the A1307 corridor between Cambridge and Haverhill as part of the Cambridge South East Transport (CSET) scheme. These commitments provide a significant opportunity to align and support the Campus plans for expansion. The transport improvement measures will help to ensure that the expansion is deliverable and accords with national and local transport policy guidance.
Phase 1 includes for the Linton Greenway, part of which runs through the Babraham Research Campus along the north-eastern boundary and provides a high quality, segregated connection for pedestrians and cyclists between Linton and Cambridge. It includes a new Toucan crossing of the A1307 immediately southeast of the site access roundabout, and a new shared footway / cycleway running northwest of the site access roundabout towards Cambridge. The crossing allows a safe crossing of the A1307 for users of the bus services that stop on the A1307 for Campus users and the shared footway / cycleway aids pedestrian and cycle connection with Cambridge.
Phase 2 of CSET is a major public transport, walking and cycling infrastructure scheme. It is made up of three key elements:
● A dedicated public transport link between the A11 and the Cambridge Biomedical Campus, running immediately to the south of the Babraham Research Campus, with potential connections into the Babraham Research Campus itself;
● A new Travel Hub facility near the A11/A1307 junction; and
● New cycling, walking and equestrian facilities running alongside the public transport link
A Transport and Works Act Order (TWAO) application for the scheme is planned to be submitted to the Secretary of State for Transport in Autumn 2021, with planned opening in 2025.
The CSET Phase 2 scheme will transform the accessibility of the existing Babraham Research Campus and therefore proposed expansion site by non-car modes. It will provide a high quality public transport link with Sawston, Stapleford and South Cambridge, including the proposed Cambridge South railway station at the Cambridge Biomedical Campus. The public transport services would be unaffected by congestion, enabling more reliable journey times and allowing public transport to compete more effectively with the private car.
The latest Babraham Research Campus annual travel survey asked the question whether staff would use “an off road public transport route as currently under review by Greater Cambridge Partnership for the A1307 South East corridor”. Of the responses, 52.1% of staff said they would use the GCP public transport scheme, which provides confidence that existing and future staff at the Campus would reduce their dependence on the private car by uptake of the CSET public transport scheme.
The Strategy concludes that there are no transport nor highways reasons why the Babraham Research Campus Expansion should not be allocated for development in the Greater Cambridge Local Plan.

− Retain the area of The Close as key worker and affordable housing to support the needs
of the Campus. Any future renovation or replacement should retain the low density character, which responds to the sensitive village edge location
BRC Ltd supports the area of The Close being retained as affordable housing for key workers to support the needs of the Campus.
The Campus expansion includes for the area known as ‘The Close’ which currently comprises 40 houses to be retained in residential use but redeveloped to consist of up to 60 new energy efficient dwellings and 100 new student apartments to ensure BRC can accommodate existing and anticipated future housing requirements for those who have a direct link with the Campus. The redevelopment will retain a low density character and respond appropriately to its village edge location.
The incorporation of suitable housing provision responds to the critical importance to recruit and retain staff in an increasingly competitive global market. It will also enable BRC to support staff in finding accommodation and reduce travel associated with the Campus for those living within walking distance
See attached Planning Representations for further detail

The identification of Land at Babraham Research Campus to be expanded and allocated as a proposed Policy Area for employment development, comprising the existing built area of the Campus and further areas adjoining the existing built area of the Campus, and the release of land within the Policy Area from the Green Belt is supported.
The boundary of the proposed Policy Area is broadly supported but it needs to exclude the Church and Church Lane as that falls outside of the Campus estate.
See attached Planning Representations for further detail

The identification of Land at Babraham Research Campus to be expanded and allocated as a proposed Policy Area for employment development, comprising the existing built area of the Campus and further areas adjoining the existing built area of the Campus, and the release of land within the Policy Area from the Green Belt is supported.
The boundary of the proposed Policy Area is broadly supported but it needs to exclude the Church and Church Lane as that falls outside of the Campus estate.
See attached Planning Representations for further detail

Please see attached representation

The identification of Land at Babraham Research Campus to be expanded and allocated as a proposed Policy Area for employment development, comprising the existing built area of the Campus and further areas adjoining the existing built area of the Campus, and the release of land within the Policy Area from the Green Belt is supported.
The boundary of the proposed Policy Area is broadly supported but it needs to exclude the Church and Church Lane as that falls outside of the Campus estate.
See attached Planning Representations for further detail

This submission is from 26 villagers of Babraham. We would like this document to be regarded as 26 individual submissions. The list of signatory names and addresses are found on an accompanying document "signatories".

We believe that the BRC submission needs to be placed in context of other sites brought forward and listed in Appendix 4: proformas for all HELAA sites (Part A) including: 51604; 51604a; 40297; and 40509. All sites together surround Babraham village. We do not feel that this process adequately explains the risk to our village as demonstrated by earlier accepted developments in our Parish including the GCP Babraham P&R and automated bus route; the soon to be completed Hawthorns; and S/RSC/H1 (c).

These individual sites taken both individually and together will have a significant adverse impact on Babraham village character, its surrounding environment, local wildlife habitat and historic interest. Specifically, these submissions, if accepted, will:
1. Amalgamate the villages of Sawston and Babraham to create a ribbon of housing stretching from Trumpington village, through the Shelfords and Stapleford. The new proposed housing would extend out to the A11 and A1307 to connect with the proposed Babraham P&R, Granta Park, Abbington and Pampisford.
2. Increase the current housing stock of a village regarded by Greater Cambridge Partnership as suitable for “infill only” by 2650% from 130 houses to 3710 houses.
3. The most recent Housing Needs Assessment (November 2021) advises that Babraham village should accommodate 10 additional houses over the next 10 years. The proposals far exceed this advice.
4. Take no account of the historic importance of Babraham village, its link to farming through the Bennet and Adeane family who built Babraham Hall and also introduced numerous agricultural innovations leading to a rich farming heritage. Their insight and commitment to the village over the 17th, 18th and 19th Centuries created the unspoilt parkland setting surrounding Babraham Hall and the unobstructed open farming landscape in which they sit.
5. Build on land once farmed by Jonas Webb, who first created the Babraham enclosures and then became a world renowned farmer in the Parish of Babraham. He pioneered early animal husbandry winning all major farming prizes. A Grade 2 listed statue commemorating his life stood for over a Century in the Cambridge Corn Exchange before being relocated to the centre of Babraham village.
6. Build on the few open landscape windows within the linear settlement, not least an ancient water meadow running alongside the River Granta to the South East.
7. Destroy important wildlife habitats in the form of river systems, riverine habitat corridors, floodplain grasslands and ancient water meadows.
8. Build around and adversely affect the setting of the 13 Grade 1, 2* and 2 listed buildings within the village and wider Parish.
9. Surround Babraham Hall’s historic open parkland setting on all sides with new housing and laboratories, destroying the open, rural landscape character entirely.
10. Take no account of the numerous and important archeological findings including Anglo Saxon settlements and graves only recently identified during exploratory digs in preparation for the Greater Cambridge Partnership guided bus route between Babraham and Sawston.
11. Place a considerable number of houses and research facilities on and close to floodplains stretching along the River Granta.
12. Put overwhelming pressure on the already overburdened river Granta in the form of additional water abstraction requirements, and damage the ecological balance of Cambridges chalk streams and associated habitats.
13. Place unsustainable and excessive pressure on limited village amenities, dominate a small historic village and infrastructure designed for only 130 houses.
14. Add to what has already been a large programme of building over the last 5 years within Babraham Parish including:
a. 120 house Hawthorns development near completion to the North of Sawston Road
b. Doubling in size of the Babraham Research Institute between the A1307 and River Granta.
c. 260 houses over 12 hectares of Green Belt to the South of Sawston Road planned for completion in 2020-2041.

Accompanying documents include a list of signatories and an overview of Babraham and what the villagers of Babraham hold dear.

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure with four different authorities claiming responsibility for some aspects of transport planning and delivery, coupled with the divided responsibility for rail infrastructure between Network Rail and East West Rail Company Ltd is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Babraham Institute withdrawal from the Green Belt provisos.
This is a local issue so one close to our hearts. Babraham Institute wishes to withdraw from the Green Belt. A wish we are not in agreement with. In the draft Local Plan some rather vague provisos and assurances are made which we feel need tightening up to safeguard the interests of Babraham residents and those in the wider environment. We therefore request that the following provisos are incorporated into this Local Plan

1. The same principles should be applied to this green belt release as for Policy S/CBC: Cambridge Biomedical Campus, namely that “National Planning policy requires that the impact of removing land from the Green Belt to be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”.

2. The Preferred Options documents do not seem to recognise that this site is located within the Cambridge Nature Network (www.cambridgenaturenetwork.org) and that it is adjacent to two strategic green infrastructure areas making it an important site (Green Infrastructure Strategic Initiatives: Gog Magog Hills (3) and River Cam Corridor (2c)). We would expect the proposals in the policy area to reflect this with a very strong emphasis on biodiversity enhancement within or adjacent to the grounds of the campus combined with better public access/benefits. We note that Google earth seems to show an area of exposed chalk in the south-west corner which could provide an opportunity for ecological restoration of priority calcareous grassland habitat.

3. The proposals for this policy area must recognise that the area identified for development would be on much higher ground than those buildings that have already been built on the campus (which are sunk into the hillside). This location is sensitive in landscape character terms, being visible from the higher ground of the Gog Magog Hills, including from the Roman Road Schedule Ancient Monument. There is a potential conflict between the development of this site and policies designed to protect landscape character. To be acceptable in planning terms, any new buildings would need to be below tree height as viewed from the Gog Magog Hills (including any chimneys or rooftop plant), they should also be designed to blend into the landscape when viewed at distance.

4. We would strongly oppose any expansion of Babraham Institute outside of their land and into the surrounding Green Belt.

5. One of the newer buildings on the campus has already had a very negative impact on landscape which is contrary to planning policy and, in our view, should not have been granted permission (photos available on request). We request that before any future development of the site takes place there is a requirement for retrospective action to screen this building and/or better blend it into the landscape when viewed at distance.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.

Rural Southern cluster
28. CPRE objects strongly to Policy S/GC: Genome Campus, Hinxton. The proposed policy area is many times the area of the existing campus and the majority of it is on productive farm land on the opposite side of the
A1301. To hide this attempted sprawl into the countryside by badging it as a potential expansion of the
Wellcome research business, when that business has room for expansion on its existing site, is less than
honest.
29. This area of land may be close to a significant road junction but Hinxton is a rural community with a long
history in a countryside location and this should be respected. We find this proposal doubly surprising
when it was only just over two years ago that CPRE supported the District Council in its rejection of a
similar proposal in the countryside near Hinxton, rejection which was upheld by the Planning Inspectorate
on appeal.
30. CPRE objects most strongly to Policy S/BRC: Babraham Research Campus. The proposed policy area would approximately double the size of the existing site. It is unacceptable to withdraw this area from the Green
Belt. Withdrawal is not consistent with the National Planning Policy Framework. The Babraham site is
located within the Cambridge Nature Network and adjacent to two strategic green infrastructure areas
(Green Infrastructure Strategic Initiatives: Gog Magog Hills (3) and River Cam Corridor (2c)).
31. Vague terms such as these used by the Shared Planning Service:
• Protect and enhance the landscaped setting of the site
• Preserve the appearance of the conservation areas, and the setting of the Grade II Listed Babraham
Hall and the Grade I Listed St Peters Church.
• Protect and enhance the corridor of the River Granta (recognised as a county wildlife site)
• Take steps to include sustainable travel opportunities, including the opportunities provided by the
planned Cambridge South East Transport Scheme.
• Retain the area of The Close as key worker and affordable housing to support the needs of the
Campus. Any future renovation or replacement should retain the low density character, which
responds to the sensitive village edge location.
provide no comfort that this Policy will not lead to further sprawl into the countryside.
32. The proposed Policy Area extension is on higher ground than the existing campus buildings and the location is sensitive in landscape character, being visible from the higher ground of the Gog Magog Hills, including
from the Roman Road Scheduled Ancient Monument. The landscape has already been damaged by one of
the recently constructed buildings on the campus. CPRE is very concerned by the further development of
this site towards Cambridge and we will request the Secretary of State to consider very carefully any
further attrition of the Green Belt at this location.

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.

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

Sustainability
94. In 1987, the United Nations Brundtland Commission defined sustainability as “meeting the needs of the
present without compromising the ability of future generations to meet their own needs.”
95. CPRE does not believe that the draft Local Plan meets this essential test. The use of greenfield land, the
effect of water supply on the Cambridge aquifer, the increased flood risk to the Fens caused by the Plan
and the lack of an integrated public transport plan are all examples of unsustainability.
Green Belt
96. We are appalled by the proposals to remove further land from the Green Belt, particularly at Babraham
and Hinxton. It is also inconsistent with the re-iteration of the purpose of the Green Belt in the statement
on Great Places in the Plan.
97. CPRE will strongly oppose all attempts to further erode the Cambridge Green Belt.
98. CPRE should not have to make this statement to planning authorities who should be ensuring full
protection of the Green Belt.