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Object

Land North of Cherry Hinton SPD

Representation ID: 31780

Received: 26/09/2017

Respondent: Anderson Group

Agent: Savills

Representation Summary:

The City Council, the Environment Agency and other local stakeholders are aware that The Anderson Group intend to bring forward shortly comprehensive proposals for its land holdings as part of the wider regeneration of the Land South of Coldhams Lane AMC. At present, the draft SPD does not make any obvious reference to the adjacent LSCL AMC. It thus presents an incomplete picture to the reader of the strategic plans for the area. It is considered that the draft SPD should include due consideration of the LSCL AMC. This deficiency can be remedied by minor modification of the SPD.

Full text:

David Henry BA (Hons) DipTP MRTPI FRICS FRGS
AIEM
Unex House
132-134 Hills Road
Cambridge CB2 8PA
savills.com

Registered office: 33 Margaret Street, London, W1G 0JD
Dear Sir/Madam,
RE: LAND NORTH OF CHERRY HINTON, DRAFT SUPPLEMENTARY PLANNING DOCUMENT:
REPRESENTATIONS MADE ON BEHALF OF ANDERSON DESIGN & BUILD LIMITED.
We write, as agents, on behalf of Anderson Design & Build Limited, an operating subsidiary of The Anderson Group ('Anderson Group' hereafter), to provide you with representations in respect of the above draft Supplementary Planning Document (SPD).
As you will be aware, land south of Coldham's Lane (LSCL) is proposed within the emerging replacement Cambridge Local Plan as an Area of Major Change (AMC), and is identified for that purpose on both the Key Diagram and the Policies Map of the emerging Local Plan. A specific policy, Policy 15, then sets out the City Council's intended approach towards supporting the wider regeneration of this area. This AMC neighbours the land to the north of Coldham's Lane which is subject of the draft SPD.
Principal Comment
The City Council, the Environment Agency and other local stakeholders are aware that The Anderson Group intend to bring forward shortly comprehensive proposals for its land holdings as part of the wider regeneration of the LSCL AMC. At present, the draft SPD does not make any obvious reference to the adjacent LSCL AMC. It thus presents an incomplete picture to the reader of the strategic plans for the area. It is considered that the draft SPD should include due consideration of the LSCL AMC. This deficiency can be remedied by minor modification of the SPD. The following representations propose how this might be undertaken.
Paragraph 1.4: Support in Principle
The purpose of the SPD is stated as being to support policy in both the draft Cambridge City Local Plan and the draft South Cambridgeshire Local Plan. If that is so, then it is appropriate to take into account the adjacent LSCL AMC as a material consideration in the preparation of the SPD. Failure to do so would result in the SPD being deficient in terms of the 'plan led' requirements established by national planning policy.
Paragraph 1.8: Support in Principle
The vision for the land north of Cherry Hinton is described as being to create a vibrant, high quality and distinctive extension to the existing settlement, reflecting and enhancing the special character of the surrounding area, whilst working in synergy with Cambridge as a whole. This vision is supported in principle, although it is considered reasonable for the development in seeking to fulfil these aims to have due regard to both its current and proposed surroundings, including the AMC just metres away south of Coldham's Lane.
26th September 2017
CAPL401107/A3/DH/BW
Planning Policy
Cambridge City Council
PO Box 700
Cambridge
CB1 0JH
By post and email
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Paragraph 2.6: Support in Principle
The acknowledgement that national and local policy has evolved since the adoption of the Cambridge East Area Action Plan February 2008 is supported. So, as stated within paragraph 1.4 (see above), the draft SPD ought to have due regard to the more recent policies and proposals of the draft City Local Plan, including the adjacent AMC, as well as its South Cambridgeshire counterpart.
Paragraphs 2.8 - 2.13: Suggested Amendment
Whilst no objection is made in principle to the allocation of the land north of Cherry Hinton for development, this section of the SPD, headed 'Local plan policies', is considered to be incomplete. It fails to make reference to other significant, material policies and proposals within the emerging Cambridge City Local Plan, contrary to the aims of the SPD set out in paragraph 1.4 of the document, for example.
Policy 13 of the emerging Cambridge City Local Plan, and the associated Proposals Map, identifies a number of AMCs and Opportunity Areas in and around the City. These are described in Paragraph 3.18 of the emerging Cambridge City Local Plan as being "extensive areas of development comprising defined and known sites collectively shaping the spatial structure of Cambridge". No reference is yet made within the draft SPD to one such neighbouring extensive, defined and already known AMC. Policy 15 of the emerging Local Plan then goes on to describe that the aim of the City Council is to encourage the regeneration of the LSCL AMC, which is directly adjacent to the area covered by the SPD.
To remedy this omission, an additional sentence should be added within this section of the SPD to inform the user that; "The emerging Cambridge Local Plan also allocates adjacent land to the south of Coldham's Lane as an Area of Major Change, under Policies 13 and 15 of the draft City Local Plan".
Figure 5: Object
Neither Figures 4 nor 5 of the SPD present the reader with the important, relevant contextual information to be found within the Key Diagram of the City Local Plan and on its associated Policies Map. In short, the draft SPD makes a significant "jump" between the Area Action Plan (Figure 4) and the partial information provided by the Proposed Modifications to the emerging Local Plan (within Figure 5). It does not show the proposals of the emerging City Local Plan itself.
The Key Diagram to the Local Plan, or the relevant part thereof, as proposed to be modified, should be included as an additional Figure.
Paragraphs 3.1 - 3.3: Suggested Amendment
This section of the draft SPD is titled 'Surrounding areas and adjacent uses'. Regretfully, it fails in this aim by not acknowledging existence of the important AMC immediately to the south of Coldham's Lane, and only metres away from the area covered by the SPD.
It is proposed that a new paragraph is added, as paragraph 3.4, to say that 'Land to the south of Coldham's Lane is allocated under Policy 15 of the emerging Cambridge Local Plan as an Area of Major Change. Here regeneration is being encouraged by its appropriate redevelopment and the creation of an urban country park to serve the east of the City'.
Paragraph 3.47: Suggested Amendment
Objection is made to the description that the southern edge of the site made within this paragraph. Although it is predominantly characterised by residential streets, this is an incomplete description. Part of the southern edge of the SPD area abuts Coldham's Lane, and is proposed to gain access from it. This frontage faces onto the AMC, which at this point is of a distinctly and prominent commercial character. Therefore, it is proposed that 3.47 should be modified to add at the end of the sentence "except where it abuts Coldham's Lane".
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Paragraph 3.54: Suggested Amendment
This paragraph is headed 'Safeguarded Land'. Correctly, it identifies the area immediately to the west of the site as having long term potential for further development. However, it fails to identify the LSCL AMC to the south of the SPD's location. Since the AMC is a similarly important policy consideration, this is a significant omission.
It is proposed that the heading to the paragraph should be altered to say 'Safeguarded Land and Area of Major Change'. An additional sentence should then be added to the end of the paragraph to say "Land to the south of Coldham's Lane is identified within the emerging Cambridge Local Plan as an Area of Major Change, for regeneration, appropriate redevelopment, and the creation of an urban country park". This should be shown accordingly on Figure 28 and the title of the Figure modified likewise.
Paragraph 5.11: Suggested Amendment
Although the principles set out in this paragraph are supported, the first bullet point could be misleading by implying that there is only a need to reduce travel by car 'within the development'. This aim should apply both to trips within and beyond the development. The phrase 'within the development' should be deleted in the interests of clarity.
Paragraph 5.13: Suggested Amendment
It is clearly important that a balanced and inclusive view is taken of possible traffic impacts arising from the development of this area. Hence, in acknowledgement of the commitment to the LSCL AMC, for completeness, the list of local junctions that should be included within a Transport Assessment ought to include the junction between Coldham's Lane and Norman Way. This provides an access into both an existing Protected Industrial Site and the AMC. Similarly, it is proposed that the important local junctions at Brooks Road/Brookfields Road, plus the Cherry Hinton High Street railway crossing, should likewise be included.
Paragraph 5.19: Suggested Amendment
This section concerns main vehicular access points to the site. Yet it fails to have regard to the implications of the adjacent strategic AMC. To remedy this omission, it is proposed that an additional sentence is added at the end of the paragraph to read: 'Similarly, the design of the access point will need to have regard to the implications of the forthcoming regeneration of the Area of Major Change on the opposite side of Coldhams Lane'.
Paragraph 5.24: Object
Objection is made to the suggestion that a bus gate is a 'possibility 'on the spine road to restrict through connections between Cherry Hinton Road and Colham's Lane. If this were implemented, then traffic from the proposed development could have a greater impact on Coldham's Lane, especially at the High Street signalised junction. In the absence of sufficient justification, it is proposed that this option is omitted.
Paragraph 5.29: Suggested Amendment
The intention of connecting the proposed development to the wider cycle network mooted in paragraph 5.25 is, of course, supported, as is the requirement to demonstrate an appropriate walking and cycling strategy. Figure 44 suggests indicative pedestrian cycle routes, including a connection to the TINS route. To achieve this, in a safe and convenient manner, a crossing point would likely be required over Coldham's Lane to Norman Way. Although this is supported in principle, again, this needs to acknowledge the requirement to integrate such proposals effectively with other significant committed and planned developments. In this case, the connection to the TINS route will need to also have regard to the continued operation of the Protected
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Industrial Area and the intention to regenerate the Area of Major Change. Therefore, it is proposed that an additional phrase is added, after 'the proposals' to say 'where practicable'.
Paragraph 5.33: Suggested Amendment
The proposal that any strategy for public transport must be lead by the County Council in partnership with local authorities, bus companies and developers is supported. The reference to 'developers' is capable of misinterpretation as being only the developers of the NCH site. It is important to acknowledge that there is need to harmonise proposals with the emerging strategy for the surrounding area as a whole, including the adjacent LSCH AMC. Therefore, it is proposed that after the term 'developers' the phrase is added 'of the NCH site and adjacent strategic proposals'.
Summary
The Anderson Group remain highly supportive of the proposed development of land north of Cherry Hinton, the vision for it and the general principles set out within the draft supplementary planning document. These representations are provided with the positive intention of assisting the process of bringing forward this vibrant and distinctive extension to the existing settlement. Support is given where appropriate, therefore. However, objections and suggested amendments are also made. This has been done with the aim of improving the document, particularly to ensure that it recognises other nearby strategic development proposals. This will make it an even more practical, accurate and up to date delivery tool.
The Anderson Group and their team remain keen to continue to engage with the Local Authorities and other stakeholders to explore and explain any of the points made in further detail. To that end, please contact the undersigned in first instance to continue these discussions.
We look forward to hearing from you shortly and thank you for the opportunity to provide these comments.
Yours sincerely
David Henry
Director

Object

Land North of Cherry Hinton SPD

Representation ID: 31849

Received: 18/09/2017

Respondent: Cambridgeshire County Council

Representation Summary:

The SPD is compared to the New Housing Developments and the Built Environment Joint
Strategic Needs Assessment (JSNA) for Cambridgeshire.

The JSNA contains evidence review of the built environment's impact on health and has distilled the evidence into the following themes:
* Generic evidence supporting the built environment's impact on health.
* Green space.
* Developing sustainable communities.
* Community design (to prevent injuries, crime, and to accommodate people with disabilities).
* Connectivity and land use mix.
* Communities that support healthy ageing.
* House design and space.
* Access to unhealthy/"Fast Food".
* Health inequality and the built environment.

It is welcomed that the SPD recognises that "where necessary, appropriate mitigation of environmental and health impacts will be required within any proposal to ensure future residents are provided with a satisfactory living environment".

Full text:

Each representation is prefixed with 'support', 'object' or 'comment' to clarify the status of each comment.

EDUCATION

SUPPORT: Education officers generally support the principles set out for education provision and the locations of the schools. However, there does remain a need to retain appropriate flexibility around the building location for the primary school. Both in terms of the site itself, and the surrounding area.

COMMENT: The gas main should not run under any part of the school sites, and any agreed school site will need to meet the site specification requirements set out by the County Council.

COMMENT: The 2.3 hectare primary school site is sufficient to accommodate a 2 form of entry (420 place) school, and sufficient to meet the needs of the proposed development on this site. Officers have encouraged the inclusion of additional safeguarded land to future proof the primary school site for expansion, should the adjacent land come forward for development in the future.

SUPPORT: The principle of secondary school playing fields in the green belt is acceptable to the Education Place Planning team, although it is recognised that there will need to be a balance between providing appropriate boundary treatments, and maintaining the character of the green area.

COMMENT: The local planning authority should satisfy themselves that the greenbelt tests will be met to not prejudice the deliverability of a secondary school.

COMMENT: For completeness, the map of surrounding schools, on page 18 of the SPD, appears to omit Abbey Meadows Primary School, which is within the 1600m isochrone and St Philip's Church of England Primary School, just outside of the 1600m isochrone.

COMMENT: It seems unnecessary, in paragraph 5.94, to state that the secondary school will be a minimum of 6FE to ensure it is educationally and financially viable. Simply state the secondary school will be a minimum of 6 forms of entry (900 places) to serve the SPD site and surrounding areas.

COMMENT: The primary school will include provision for early years. Officers would encourage any development of this nature to also consider provision for a commercially operated nursery. This could be ensuring the appropriate use class designation is included in any planning applications.

MINERALS AND WASTE

OBJECT: The SPD omits to include the planning policy of the adopted Cambridgeshire and
Peterborough Mineral and Waste Core Strategy (2011), and the Cambridgeshire and
Peterborough Mineral and Waste Site Specific Proposals Plan (2012); both of which are part of the adopted development plan for the area.

COMMENT: The adopted Core Strategy seeks to make adequate provision for waste management to meet Cambridgeshire's needs over the period to 2026, and makes allocations for this purpose. The Cherry Hinton site which is the subject of this SPD forms part of a larger Area of Search for the potential location of waste management facilities allocated by Policy SSP W1E of the Site Specific Proposals Plan; and this allocation is safeguarded through Policy SSP W8H which designates a Waste Consultation Area over and around the Area of Search.

COMMENT: Policy SSP W1E allocates the Area of Search at Cambridge East for a range of waste management uses which potentially includes recycling facilities, a Household Recycling Centre, Temporary Inert Waste Recycling, Materials Recovery Facility, and suitable new waste management uses.

COMMENT: Policy CS30 of the Core Strategy provides the overarching policy for Waste Consultation Areas and this states that development will only be permitted where it is demonstrated that this will not prejudice existing or future planned waste management operations.

COMMENT: These policies will need to be included in the policy section of the SPD and addressed in due course. It should also be recognised that the wider Area of Search for the potential location of waste management facilities has been subject to development elsewhere, and has therefore been reduced in size.

FLOODS and WATER

COMMENT: Page 20, Paragraph 3.21 is incomplete ' ...onsite attenuation provided to mitigate risk to the wider catchment. Maximise and incorporate existing'.

TRANSPORT

OBJECT: Page 52 - 5.18 -The SPD should highlight that the requirements of the final spine road design will be determined by CCC and Local Authorities prior to submission of a Planning Application. The wording in the consultation version is that this will be decided through the planning application process, but the County Council require this to be decided prior to a planning application is submitted, therefore wording should be altered to prior to submission of a planning application.

COMMENT: Page 46 - Movement - the 'vehicular access points' on figure 39 are not very clear, these need to be made clearer.

COMMENT: Page 47- 5.13 should refer to Coldham's Lane/ Barnwell Road not Drive.

COMMENT: Page 51 - 5.16-The spine road design speed should be agreed with Highways
Development Control - 20mph seems most appropriate This should actually refer to Highways

Development Management or the Highway Authority or County Highways rather than Highways
Development Control.

COMMENT: Page 53- Figure 45 is small and not clear to read.

COMMENT: Page 59 -car parking provision should be compared to needs assessment e.g. car ownership levels. This has not been addressed.

PUBLIC HEALTH

The SPD has been compared to the New Housing Developments and the Built Environment Joint
Strategic Needs Assessment (JSNA) for Cambridgeshire1.

The JSNA contains an evidence review of the built environment's impact on health and has distilled the evidence into the following themes:
* Generic evidence supporting the built environment's impact on health.
* Green space.
* Developing sustainable communities.
* Community design (to prevent injuries, crime, and to accommodate people with disabilities).
* Connectivity and land use mix.
* Communities that support healthy ageing.
* House design and space.
* Access to unhealthy/"Fast Food".
* Health inequality and the built environment.

The SPD has therefore been reviewed against these themes to ensure the SPD has identified possible areas which can impact human health and wellbeing and therefore should be mitigated through design and master planning.

For ease of reference the comments on the SPD have been grouped under the nine themes contained in the JSNA as mentioned above.

COMMENT: A. Generic evidence supporting the built environment's impact on health. It is welcomed that the SPD recognises that "where necessary, appropriate mitigation of environmental and health impacts will be required within any proposal to ensure future residents are provided with a satisfactory living environment" (Page 2- 1.3 of the SPD). And that the SPD acknowledges both the emerging Cambridge Local Plan, and South Cambridgeshire Local Plan in that in section "2.9 Proposals for residential development will be supported if... "acceptable mitigation of environmental and health impacts (including noise) from the airport can be
provided... " In addition the 5.71 of the Open space and recreation section within the SPD states
that the development should "also encourage healthy lifestyles and the use of sustainable travel modes, such as cycling."

1 http://cambridgeshireinsight.org.uk / joint-strategic-needs-assessment/current-isna-reports/new-housinq­
developments-and-built-environment

COMMENT: B. Green space.
There are concerns that the provision of green space may not be sufficient, although the SPD references the policies within each local plan, the labels for pocket parks on the indicative map on page 63 do not match the description on the indicative map on page 43 where they are classed as green corridors, these are not the same and should be clarified.

In addition the dry swales should not be included within the allocation for green space as these may not be available for recreation depending on the condition of the swale e.g. in exceptional flood circumstances.

COMMENT: C. Developing sustainable communities.
The provision of electric charging points within the development is welcomed, however, the provision needs to be more specific and it is suggested the SPD reflects the need for EV charging points in different settings e.g. Residential, Commercial, Carparks etc. also the SPD should reflect the different types of EV charging points (standard and rapid).

It would be beneficial if the SPD had an aspiration that all dwellings are provided with EV charging points.

The acknowledgement that air quality needs to be considered at the design stage (Page 56) is welcomed and the SPD should also consider domestic use of energy as well as energy production i.e. combustion sources within domestic dwellings

The statements regarding s106 monies for 'primary health care facilities' on page 75, needs to be wider. The category of infrastructure should be 'health care facilities' rather than 'primary health care facilities' in order to allow different sectors of the NHS to decide what type of provision would best suit that location i.e. primary and community care provision. In addition the location of any expansion, or new facility may not be within Cherry Hinton so it might be better to reword the requirement to allow a flexible location.

COMMENT: D. Community design (to prevent injuries, crime, and to accommodate people with disabilities).
The SPD does reference the need for "a wide choice, type and mix of housing will be provided to
meet the needs of different groups in the community, including families with children, older people and people with disabilities." However this seems only to apply to housing. The needs of disabled or older people and other marginalised groups should be taken into account in all aspects of the masterplan including, but not limited to, the design of green space, transport connectivity etc.

There is no aspiration within the SPD to tackle crime through innovative design.

The aspiration for encouraging developers to incorporate a traffic calmed environment is welcomed. Particularly the reference to using street design, intersecting cross routes to create a natural reduction in speeds, and setting the spine road speed limit to 20mph. The SPD could consider making the entire development a 20mph zone.

COMMENT: E. Connectivity and land use mix.
The incorporation of cycle links, and the access to public transport is welcomed but the s106 requirements (page 75) could be widened to increase the uptake of cycling and walking within, and from the development. For example, any emerging travel plan should include personal travel plans, cycle purchase vouchers etc. In addition the connectivity considerations need to relate to the provision of adequate cycle parking facilities in both commercial buildings and domestic dwellings.

COMMENT: F. Communities that support healthy ageing.
Although the SPD references the need for "a wide choice, type and mix of housing will be provided to meet the needs of different groups in the community, including families with children, older people and people with disabilities." It does not address the needs of older people specifically.

The SPD should make it explicit that the needs of older people, particularly those with dementia should be taken into account as part of the overall design and master planning.

COMMENT: G. House design and space.
The requirement that the development should include a mix of dwelling sizes, types and tenures to meet projected future household needs within Cambridge including integrated housing, and dwellings designed to provide adaptability and flexibility is welcomed.

The SPD could go further and recommend the proportions of dwellings that are built to the Government's 'Approved Document M' standards to ensure that people are able to access and use buildings and their facilities.

COMMENT: H. Access to unhealthy/"Fast Food".
The SPD could reflect the need to address obesogenic environments that encourage people to eat unhealthily and not do enough exercise by encouraging healthy lifestyle choices through innovate design.

COMMENT: I. Health inequality and the built environment.
The SPD needs to address the need for local employment opportunities further.

ARCHAEOLOGY

COMMENT: The site has been subject to a programme of archaeological evaluation, the results of which indicate that significant archaeological remains survive in the area. Any planning
application will require a programme of archaeological excavation, secured by condition, as appropriate methodology for mitigating the development impact.