Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?

They will not be kept maintained like
Most places

I would support all of these. I would prioritise neighbourhood level schemes connected through green corridors (that are walkable and cyclable) which then connect to the wider green space in Milton Country Park. I would not prioritise large scale (Parkers Piece type development) in the middle of the development as a priority.

I don't mind which of these are adopted; the key point is that the more green space is provided, the better.

I support all of these. I see green space as the NUMBER ONE means to make the area attractive and desirable to residents and businesses. It's a key element in the success of, say, the Science Park. ALL of the options outlined here seem important and are not mutually exclusive. If tradeoffs have to be made, I'd decrease the district scale green space a bit to provide connections and corridors (that are not merely cycle throughways, but are also peaceful walking routes (cycles segregated or taken a different way). These connections and corridors can link together small neighborhood green spaces. It's all good and all valuable in meeting all the objectives: health, community, attractiveness, etc.

Green spaces must include equestrian access. A link to MCP would be fantastic. Re. parking, how about a safe equestrian hitch rail in the shopping area?

Option C: biodiversity and ecological corridors, good for us and for wildlife if done well with input from local Wildlife Trust, balanced by some green areas on a neighbourhood scale to give residents and visitors some breathing space, see the sky. Again, plans should involve the local Wildlife Trust to advise. What is good for wildlife is also good for human health.

Options C & F are essential to deliver a high quality strategic green infrastructure solution.

We do not have a preference with respect to option A or B.

B.There are many smaller existing green spaces which are well used and there is much potential for more of these. Also there is a need for more play equipment. The playground in the green end road park is old and well used and needs replacing, for example. the splashpad at kings hedges is also somewhat tired. Vital to ensure new green spaces feel safe and are well lit.

I would support it all provided that urban parks or greenways are designed with social safety principles such as natural surveillance, meaning that buildings, activity and street life all face the parks and people find it natural and sensible to be present and passing through the parks at all times of day and well into the night. This doesn't apply to nature reserves but only to urban spaces where people are expected to walk and cycle at any time, and it is to ensure that people feel safe and welcome in these spaces.

Option A - A large green space would be very good. But there should be green spaces visible wherever you are.

Particularly B, C and E

C and D. I've already said Milton Road should be fronted by trees in an earlier answer. Making green space all linked to provide habitat for wildlife is far better than bits of park surrounded by concrete. Also children need space near where they live, not somewhere they have to be escorted to.

I would support all of the following options - enhanced green space throughout the area is really important.

In favour of A: a large district-scale green space, as this brings people together and can be used for small or large events. Other options for green space also have benefits, and it is important to have green space in some form.

Green space is essential and including blue space (water features). The large scale proposal (A) does not feel appropriate as I envisage mixed use with a fine grain more compatible with options B and C. Option D is good too.

As for option E I have described elsewhere the need to turn Milton Road from a five lane highway into a forest of trees. It should have a character more like Brooklands Avenue and less like the M1.

Making a connection to the Country Park and the Cam corridor is a no brainer.

A

Thank you for consulting Natural England on the above in your email of 11 February 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. However, this is subject to the inclusion of robust policies within the Area Action Plan (AAP) to ensure delivery of a truly sustainable development including provision of strategic high quality multifunctional open space, with a long-term management strategy, to meet the needs of people and wildlife. We would expect the scale of development to deliver a green infrastructure network along the lines of similar developments elsewhere such as Cambourne, Trumpington Meadows and Waterbeach New Town. Development through the AAP should be guided by an established green infrastructure and biodiversity framework to ensure the NEC Area is capable of delivering the range of environmental services and natural capital required to meet the needs of the scale and nature of proposed development.

We note that the planning process for the future location of the Water Recycling Centre is outside the scope of this AAP and that this will be progressed by the County Council as the Local Planning Authority for waste matters.

Natural England welcomes proposals to undertake further environmental assessment work to inform preparation of the AAP, including air quality and noise assessments and habitat surveys. Whilst the majority of the NEC Area is brownfield land it supports significant local biodiversity interest and opportunities for enhancement. Advice should be sought from relevant sources including the Council ecologists and the Wildlife Trusts. Retention of all existing biodiversity interest and identification of opportunities for environmental enhancement should be a priority for the development of the green infrastructure and biodiversity framework and long-term enhancement and management strategy for the AAP.

The NEC Area Today
Figure 4.8 shows the extent of existing green and blue Infrastructure across the NEC area. However, we believe there may be additional areas of green infrastructure that are not included on the map. This should be confirmed and amended if necessary through the proposed ecological survey work.

We welcome recognition of ecological constraints in section 4.13; however, these are positives, not negatives, and should be seen as significant areas for retention and enhancement and the focus for development of a green infrastructure and biodiversity framework for the AAP. The AAP provides a unique opportunity for the enhancement, extension and improved connectivity of areas such as Bramblefields Local Nature Reserve (LNR), the protected hedgerow on the east side of Cowley Road (City Wildlife Site) and the First Public Drain wildlife corridor and other habitats including ponds and areas of woodland, scrub and grassland. The AAP should take every opportunity to retain and enhance as much of the natural environment as possible and to provide biodiversity rich green corridors across the site and beyond.

Section 4.20 and 4.22 acknowledge the requirement to deal with potential contaminated land and other environmental issues such as minimising light pollution which we fully support.

Vision and Strategic Objectives
Natural England supports the AAP vision and objectives for 'a socially and economically inclusive, thriving, and low carbon place for innovative living and working; inherently walkable where everything is on your doorstep'. We welcome the objective for green spaces to be a core part of the place structure extending, connecting and improving biodiversity to achieve a net gain and integrating Sustainable Drainage Systems within the development. As mentioned above, we believe the AAP should be developed around a robust green infrastructure framework for the site to ensure delivery of the full range of environmental services required to meet the needs of the proposed scale and nature of development: recreation, health and well-being, biodiversity, landscape, drainage, flood management, sustainable travel, climate change and adaptation. We note the following statement:

"Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life."

Whilst we fully support the above we would expect a development of this magnitude to deliver significantly greater than 'district scale' green infrastructure, although we are unclear what this really means. We have provided further advice on green infrastructure provision below.

Place Making
Sections 6.14 and 6.15 discuss creating a healthy community which we fully support. Our advice is that a strategic level of high quality greenspace provision will be key to creating a healthy community and enhancing people's physical and mental wellbeing. The extent of accessible natural greenspace provision (i.e. excluding formal sports areas) should be proportionate to the scale of development, for example 8ha 11000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance to meet people's needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site. Whilst quantity of provision should be broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including the minimum standard of 2ha informal open space within 300m of everyone's home.

Further consideration should also be given to significantly enhanced green infrastructure corridors to improve connectivity of green infrastructure within the site and beyond, including green linkages with Milton Country Park. Green infrastructure provision should seek to contribute towards the delivery of the objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and improved connectivity. The AAP should not rely on existing green space such as Milton Country Park to meet people's recreational needs; the AAP should seek provision of similar area of open space to complement and connect the Country Park.

Natural England agrees that the development of the NEC Area presents an opportunity to create a new network of streets and open spaces that will support and improve movement of people throughout the area. Creation of sufficient informal open space for outdoor recreation, enjoyment of the countryside, walking, cycling and adequate public transport provision will be critical to this. A network of green corridors should provide connectivity to areas off site including the Country Park, the Chisholm Trail and Waterbeach Greenways.

We note and welcome Option C to upgrade connections to Milton Country Park by both foot and cycle, including improving access to the Jane Coston Bridge, the Waterbeach Greenway project including a new access under the A 14. We would welcome consideration of options for a crossing of the railway line and the use of green bridges.

Issue: Green Space provision - Natural England advises that this needs to be addressed through a combination of options A -F to provide strategic high quality, biodiversity-rich multi-functional greenspace. This should seek to meet SANGS standards and be connected through substantial green corridors to open spaces across the site and beyond, including connectivity with Milton Country Park, Waterbeach Greenways and the Chisholm Trail, as discussed above.

Transport
Natural England advocates a focus on sustainable, non-car travel including cycling, walking and public transport.

Retail, Leisure and Community Services & Facilities
We welcome recognition of the multi-functional benefits of open space provision including biodiversity enhancement, landscape, drainage, flood management and health and wellbeing. A development of this scale should provide open space to accommodate formal and informal requirements: informal open space in accordance with SANGS, as discussed above, to provide biodiversity net gain and meet people's informal recreation, physical and mental health needs.

Climate change
We support proposals to contribute towards mitigating and adapting to climate change including the application of sustainable design and construction standards detailed in section 11.7. Natural England welcomes proposals outlined in section 11.14 for policies to integrate a SUDs network into the Fen edge landscape that could help to enhance opportunities for specified species as well as providing a sense of place.

Biodiversity
Natural England supports proposals to achieve measurable biodiversity net gain in accordance with national planning guidance and the Defra 25 Year Environment Plan. Natural England advises that the Council's should not simply strive to meet this target, through encouragement of quick wins such as green roof provision; the AAP should ensure significant long-term gains through development of a biodiversity and green infrastructure framework, delivery and long-term management strategy for the area, to guide wider development. Ecological surveys should identify key habitats for retention, buffering and enhancement and opportunities for creation of a wide range of additional habitat to complement, extend and connect existing habitats.

These areas should incorporate a wide range of environmental services including informal open space, landscaping and SUDS provision. The advice of relevant stakeholders including the Council ecologists, Wildlife Trust and Natural England should be sought on the preparation of a Biodiversity and Green Infrastructure Strategy and its delivery secured through robust plan policies.

Please note that Natural England's Impact Risk Zones (IRZs) have been published since this site was originally allocated for development in the Local Plan, a number of years ago. The IRZs are currently being updated to take into account evidence for recreational pressure risks to designated sites such as Stow-cum-Quy Fen and Wicken Fen. The provision of adequate level and quality of alternative accessible open space within large developments is crucial to mitigating the adverse effects of those developments, through increased recreational pressure, to sensitive designated sites.

We note the statement in section 11.17 that off site improvements may be required if biodiversity net gain cannot be fully achieved on site. Whilst we welcome this we believe that a development of this scale can deliver significant biodiversity net gain within the area boundary subject to proper planning and design from the outset.

Implementation and Delivery
We note and welcome the proposal to prepare a North East Cambridge Infrastructure Delivery Plan to provide a broad assessment of the social and physical infrastructure needed to support the planned development and regeneration of NEC and how these requirements could be met. Natural England advises that this should include identification of green infrastructure needed to deliver the range of environmental services required by the development including recreation, drainage, landscape and biodiversity enhancements.
Natural England supports the intention through the AAP to put in place a Section 106 regime to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements. We trust that this will include provision of green infrastructure including informal open space and biodiversity.

Interim Sustainability Appraisal
Natural England is satisfied that the Interim Sustainability Appraisal (SA) objectives and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the effects of the AAP on key aspects of the natural environment including designated sites, biodiversity, landscape, green infrastructure and soils. The assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and to take into account the findings and mitigation recommendations of the outstanding environmental assessments.

Other advice: Priority habitats, ecological networks and priority / protected species populations The AAP should be underpinned by up to date environmental evidence including an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England . Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation , protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Water Quality and Resources and Flood Risk Management
Natural England expects the AAP to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The AAP should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The AAP should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.

***Please note that this representation was received after the submission deadline***

Thank you for the leaflet about the North East Cambridge area action
plan, which I picked up on my morning commute from Cambridge North
station. Please find below some feedback. It is structured according to
the question statements in the consultation booklet.

'Do you agree with the proposed vision and broad objectives? What
changes would you make?'

Cambridge needs to be carbon neutral before 2050 if the UK is to meet
it's obligations under the Paris agreement. One major source of CO2
emissions from construction is concrete, released during the production
of concrete. Require that contractors reduce or eliminate the use of
concrete during construction to reduce the carbon footprint of the
development.

Broad objective 1 talks about the economic success of the local area,
and talks about social justice and equality. The social justice and
equality statement deserves its own broad objective.


'Have we identified all the key challenges and constraints? How should
we respond to them?'

Transport and connectivity - this is an equality and social justice
issue. Allowing people to travel by active modes (walking / scooting /
cycling) reduces their household costs. The aim should also be to reduce
the number of cars as a result of the development, not aim for no net
change, because 1) building more roads results in more cars (see various
papers), and 2) cars reduce house prices, health, and increase stress
(see the Appleyard study).


'What sort of homes and jobs should we be planning for?'

Homes that can store multiple bikes, and are not on busy roads but
'home-zone' style roads.


'What are your views on the potential future land uses, including type
and mix? What sort of greenspaces should there be?'

The commons and green corridors (Midsummer, Stourbridge, Ditton,
Grantchester) are heavily used throughout the year for recreation and
commuting. Green corridors will be essential for commuting and for
physical and mental health of new inhabitants. These corridors should be
generous. There will be no option to put them back in once construction
is complete.


'What are your views on the indicative concept plan'

More green corridors. Prioritize over roads. Keep separate from roads.

***PLEASE NOTE THAT THIS REPRESENTATION WAS MADE AFTER THE SUBMISSION DEADLINE***

Q24: Access to the Cam, via Fen Road.
But this must, of course work recipically to give access to the NECAAP development to those who live and work East of the Railway (EotR). The many residents and workers in the area to the East of the Railway line are increasingly remote from Chesterton, partly because of the distance and partly because of the increased down times of the level crossing (see my comments on Q2) caused by the increasing train movements and train lengths at Cambridge North. EotR residents and workers, particularly those in the Northern part of the area, may well be attracted to facilities in the NECAAP area as they are developed, including shops and schooling.
Those west of the line will want decent access to the river; the greenbelt area may lend itself to recreational facilities and perhaps playing fields for NECAAP residents; the waste transfer station might lend itself to conversion to, say, gym or other facilities, thereby avoiding the less social need for waste lorries to access the area.
However, the inclusion of a pedestrian and cycle bridge over the railway line offers the opportunity to **turn this also into a road bridge** and so offer a solution to the problems posed by the level crossing and the need for heavy lorries to access EotR via Chesterton, with the pollution and congestion that that entails. See my response to Q17

Q50: The proposal that I made re including the aree East of the Railway (EotR) in the NECAAP area (for Q2) does not imply that EotR should be fully integrated within the NECAAP for land development. The travellers sites can be left and arguably the industrial sites. Much of this area is in any case green belt.
However, the opportunity should be taken to bring mains drainage to this EotR area of Fen Road, if only under the NECAAP's obligations to its neighbours. It is appalling that this area is left off mains drainage because the inhabitants are predominantly travellers, who do not count in the arithmetic of who deserves mains sanitation!

It will be appalling if there is to be an area without mains sanitation within yards of the new NECAAP area.

Q72: Yes, the Section 106 Regime should be specifically used, along with a contribution from Network Rail, to support the enhanced roadbridge with the cycle and pedestrian bridge proposed to access recreational facilities in the green belt on Fen Road and the Cam.

Q 2. Is the proposed boundary the most appropriate?

No. The proposed boundary should include the area to the East of the railway line, along Fen Road.

This area has suffered for years from a range of well-known social and related problems. Closure of the level crossing would require that part of Fen Road to be connected to the northern end of Milton Road, or directly to the Milton Road/A14 junction with a bridge over the railway line.

Q 3. Have the physical characteristics of the area been correctly identified

No. There is no mention of the lack of Secondary Schools, and those matrked onb the map are incorrectly positioned.

Q 11. Are there particular land uses that should be accommodated?

Yes, there should be a Secondary School and as much as possible of the area between the railway line and the river should be designated as a Riverside Country park

Q 15. Should clusters of taller buildings for part of the design

Not without very specific constraints on height. Six storeys should be set as an absolute limit.

Q 17. Explore delivery of a cycling and pedestrian bridge over the railway line?

Yes, certainly, but there should also be a new road and bridge to link with Fen Road so that the level crossing can be closed

Q 20. and 21. a and b
No I do not agree with proposals to include low levels of car parking. They will cause the surrounding residential streets to be swamped with displaced cars belonging to residents of the proposed new development.
Car parking provision should be close to one parking space per residential unit. Until adequate public transport is provided it is not feasible to reduce the number of car parking spaces on the Science Park.

Q. 24. Green space
The provision of adequate green space must be explicit, controlled by the City Council and not delegated to developers.

I strongly support combination of all of the proposed elements and rigorous enforcement on developers.

Q. 27. Trip budget and reduction of car use
This can only be affective where a proper system of public transport is in place. That means something other than buses, for example a tram, or if a proper tram cannot be achieved then the 'CAM'. Buses, especially conventional diesel buses, do not provide a viable, sustainable or attractive alternative to cars.
The integration of the AAP with a tramway or CAM is an essential prerequisite. The guided busway in its present form is almost completely irrelevant to what is proposed, other than for a small number of trips from Northstowe, Histon/Impington and Darwin Green/Eddington to the Science Park.

Q. 28. Low and reduced car parking ?
No, see above

Qs. 29 and 30
Yes, cycle parking must be prioritised and made obligatory

Q. 33 Innovative connections between Cambridge North and the Science Park
The guided busway is not adequate or attractive. A tram or CAM is needed.

Q. 37 Industrial uses to be retained?

Existing light industrial uses should be moved next to the A14, facilitated by a new road connection along the top of the site connecting to Milton Road on the A 14 junction. That could include the bus depot. Railway sidings should also be retained for future needs.
Q. 38 Mix of dwelling sizes
Yes, a mix of sizes, and family units should be included. That is essential to achieve a balanced stable community

Q. 39, 40,41 Housing for essential local workers
Yes, certainly. Absolutely vital and should be adhered to and enforced. No side deals for substitution with student accommodation etc.

Q. 43 HMO?
I am not at all convinced by this, so without further detail, no.

Qs 44- 46 PRS
I recommend involving a local housing association.

Q. 51 and 53 and 54
The highest/best local and national standards should be applied, so that no compromises are made away from the largest possible internal space, best direct access to private amenity space, and highest standards of accessibility.

Q. 55
There must be adequate provision for independent retail, which should be prioritised over national chains. There is no need to attempt to duplicate city centre/other major leisure and retail provision.

Q. 57
Use the Trumpington/Eddington models for community centre/library/medical. Include a secondary school. Faiths should be given proper allocation of space.

Q. 59 Space provision: Quality and functionality not quantity
No. Adequate quantity is essential, see above re riverside park.

Q. 67 Net gain in biodiversity ?
Go to Eddington for methods. Appoint an ecology chief for the area from the start.

Q.69 Underground waste system
Yes, again use the Eddington example.

Q. 84 Any other comments
The AAP proposals have evolved into a massive addition to the urban fringe of Cambridge.
There is no acceptable reason why residential building density and height need to be imposed on a scale that is out of character with the rest of Cambridge, on a site which will be visible from various places including the historic and invaluable riverside, parts of the city and Chesterton, and Fen Ditton.
If excessive height and density is the only basis on which funding can be obtained to move the Sewage Works, then it would be better to leave the Sewage Works where it is until an appropriate alternative approach can be found to redevelopment that is not alien to Cambridge.

1. The WTC should not be relocated to a greenbelt or greenfield site, flood risk area or an existing or planned community. Existing rules on safe-guarding must be complied with. If the decision is taken to relocate the WTC to an acceptable brownfield site, CPRE would like assurance that contamination on the vacated site can be fully remediated before development commences.

2.The height and scaling of buildings should be sympathetically arranged to ensure that the view from the East from open countryside and the River Cam towards the development is not compromised.

Air traffic using Cambridge Airport should not be compromised by building heights. The existing Milton Road corridor and community should not be surrounded by overbearing tower blocks or industrial buildings. Nevertheless, the development needs to include suitable employment space, for businesses which may be spawned from the nearby Science Park and St Johns Innovation Centre as well as businesses capable of providing services to those research and development clusters. The area should be developed to reflect this.

3. Air quality, light, and noise pollution should not intrude on or be detrimental to the tranquility of the open countryside and the River Cam corridor. Green space and wildlife corridors should be strategically arranged thoughout the development to enhance biodiversity and for the wellbeing of community. Consideration should be given to creating a green fringe between the River Cam towpath and the development.

4. CPRE supports the use of non motorised vehicular travel. However the towpath along the River Cam should remain predominately an area for pedestrians and those who wish to enjoy the tranquility of the river bank and the Fen Rivers Way that runs along the river bank from Cambridge to Ely in a more leisurely and peaceful fashion. Safeguarding this unique public space and biodiversity should be a priority.

5. The necessary infrastructure and transport links for this development and Waterbeach New Town need to be funded,considered and strategically delivered together as a cohesive plan and not in a piecemeal fashion or to the detriment of surrounding communities.

6. Climate change and water stress need to be fully considered to ensure that the proposed development is sustainable, viable and "future proof" taking into account the availability of water as Sir James Bevan has recently warned:
https://www.gov.uk/government/speeches/escaping-the-jaws-of-death-ensuring-enough-water-in-2050.
Concerns have been raised by local bodies regarding the potential for over extraction of water from the River Cam and local aquifers which are currently licensed at their safe extraction limits. It is feared that over populating the course of the River Cam may hugely exacerbate water stress and have a negative effect on the agricultural businesses that rely on a combination of river water and borehole water to irrigate their crops during the dry summers which charcterise this area.

7. An inclusive approach to community development should be followed which is designed to benefit the new and existing communities, particularly the deprived areas of Arbury and King's Hedges, other existing communities within the proposed AAP boundary and the villages that will sit alongside it.

The Environment Agency welcomes the consultation which re-launches the process we left off in about 2014. We welcome the fact that the AAP is largely starting afresh with issues and options stage.

We also recognise that the context has changed substantially with new planning policy, fresh climate change projections and longer horizons for higher levels of growth in the Non-Statutory Spatial Plan.

As a result we consider that our response to the AAP consultation dated 18 June 2014 is also largely obsolete, and is replaced in full by our advice to this consultation. In summary, our comment s below should be classified as 'comments' (rather than support' or 'object') whilst we await the flood risk evidence base, Water Cycle Study updates and information on how the AAP team plans to working with the County Council and other key partners - see below under joint working.

Evidence Base and Impartiality:
We could not find an up to date Strategic Flood Risk Assessment (SFRA) or Water Cycle Study (WCS), which are essential evidence base for a development plan of this scale and nature. If any are available (a FRA is mentioned in the AAP), please could these be shared asap, including the consultants briefs - we may then need to update our advice.

A SFRA and WCS is needed to identify realistic and challenging issues and options for the AAP. Whilst we can support an issues and options only consultation on the strength of older SFRA and Water Cycle Studies, we advise that options appraisal, selection and policy formulation will need an up to date evidence base to be considered justified. The LLFA may have a view on this. The Cambridgeshire-wide Water Infrastructure Study currently being considered by the constituent LPAs would be a timely and positive tool to progress the AAP with.

Water companies normally play a lead role in evidence preparation as impartial statutory undertakers of water infrastructure. This AAP site is somewhat unusual in that the water company is also the primary landowner/developer promoting reuse of the site with substantial commercial advantage. Anglian Water also states that there is no operational reason to move Milton WRC. OFWAT has some rules around this. As environmental regulator, the Environment Agency has a role to be satisfied that our interaction in this process is managed with propriety, and in recognition that Anglian Water is also the sole provider of the relevant water infrastructure in the area. We would like to discuss and agree our respective ways of working so that we can manage this interaction consistently and maintain the necessary impartiality.

Joint working
We welcome the consultation on the Issues and Options, and see this as the kick starting of a process of ongoing and meaningful consultation with neighbouring LPAs, the Minerals and Waste LPA, Natural England and the Environment Agency (amongst others) as prescribed bodies in the Localism Act 2011.

The Environment Agency can help to scope and inform the relevant evidence base and plan the overlap with future flood risk management and environment permitting regimes for waste, water quality and water abstraction. We can also help ensure some related consistency with other local plan documents such as the emerging Minerals and Waste Plan.

We are especially mindful of the extent of overlap with the Minerals and Waste Planning Authority who are preparing a Minerals and Waste Local Plan on broadly the same timescales/trajectory. Therefore the scope and importance of joint working to ensure consistency is especially important. There is also scope for important matters to 'fall between the stalls', so we are keen to support the duty to cooperate process to help ensure that both plans are reflective of overlap and sound in evidence and approach. There is of course scope for joint evidence base preparation to make this process efficient and facilitate joined up planning, which we support.

SEA Report:

We appreciate that the SA is in interim stage and welcome the consultation.
We welcome the fact that primary sustainability objectives relate to ensuring that the protection of people and wildlife from flooding and pollution is sustained and improved. Climate change is also listed as a long term context to plan for.
We consider this especially important for the context because the sole purpose of the existing site is to protect people and wildlife from flooding and serious health risks from the Cambridge's foul water.

Clearly, displacing that infrastructure poses an enormous potential risk to the sustainability of Cambridge and the River Cam. A redevelopment is a once in a few generations opportunity to sustainably plan the relocation. Given the scale of the risks, all options should be robustly tested with a high degree of certainty before the AAP commits to irreversible directions or decisions. We therefore recommend that suitable weight is afforded to these water, health and climate change objectives, and that the AAP tackles the relocation and related phasing.

SEA: Missing Issue: Relocation options and implications

There is a section aimed at relocating existing industrial uses, but no apparent substantive consideration of the issues, options and impacts of relocating Milton WRC itself. This is most likely to be the biggest direct and indirect water impact of all, and is a highly significant impact in any event, pre-mitigation. Our advice is very clearly that the impact of relocation is potentially highly significant, and that is falls to be appraised as an impact arising from the plan. It also features cumulative effects with other projects, such as Waterbeach New Town. The SEA/SA should address this.

We believe that there is also a duty to cooperate with the minerals and Waste LPA, South Cambridgeshire and environment regulators - ideally in the same forum, and on an ongoing basis. This would help enable sound plans and Sustainability Appraisal, whilst ensuring a realistic delivery process. We look forward to working with your authority to this end.

We advise similarly with the Habitat Regulations Assessment (HRA) which has more detailed assessment to consider habitat and species specific potential impacts arising. There is also strong potential for impacts on the Cam Washes SSSI - again cumulative assessment should be carried out with nearby projects such as the Waterbeach New Town.

4.1 The existing site: constraints and opportunities

Climate change section

The draft AAP is located within Flood Zone 1 but on the edge of Flood Zone 2. The railway line appears to provide a barrier to flood waters entering the development site from the River Cam. However, the First Public Drain runs across the site and enters the River Cam to the east and north of the site. The Sustainability Appraisal has identified that there is some surface water flood risk within the site and states that this risk can be mitigated against through good design and careful master planning. We consider that opportunities should be sought to reduce flood risk both on the site and elsewhere through the use of sustainable drainage systems. The Lead Local Flood Authority (LLFA) should be consulted at an early stage on the design of any proposed surface water drainage scheme to ensure that such opportunities are incorporated into the design.

We consider that an assessment of the impacts of climate change on flood risk associated with the River Cam should be undertaken to ensure the proposed development will not be at risk of flooding from the River Cam in the future. Please note that the climate change allowances shown in our 'Flood risk assessment: climate change allowances' guidance on the gov.uk website will be updated later in 2019 following the publication of the UKCP18 projections, which have replaced the UKCP09 projections.

As our hydraulic model covering the River Cam does not include appropriate climate change allowances, we would expect detailed modelling of the River Cam to be undertaken as part of any flood risk assessment to assess the impact of climate change on flood risk at the site. The revised climate change allowances will also need to be used to assess the impact of climate change on any proposed surface water drainage scheme.

Chapter 11 focuses on sustainable design in relation to carbon reduction rather than sustainable drainage systems.

The section on 'Site Wide Approaches to Sustainable Design and Construction' makes reference to taking an integrated approach to water management which should give consideration to reducing flood risk. In addition to supporting this approach, we consider that there should be greater emphasis in this section on the importance of taking a site wide approach to integrated water management from the outset, rather than developers retrofitting water as an afterthought.

Context to site groundwater

The majority of the North East Cambridge site (middle and eastern parts) is underlain by superficial deposits comprising of sands and gravels which are designated as a Secondary A aquifer. Secondary aquifers are permeable geological strata capable of supporting water supplies at a local rather than strategic scale, and form an important source of base flow to rivers, wetlands and lakes and private water supplies in rural areas. The Secondary A aquifer is underlain by Gault Clay Formation which is designated as unproductive stratum. A small part of the site (between Cambridge North Station and the River Cam) is underlain by bedrock geology (West Melbury Marly Chalk), designated as a Principal Aquifer which underlies the Secondary A aquifer. Principal aquifers are geological strata that exhibit high permeability and provide a high level of water storage. They support water supply and river base flow on a strategic scale. Based on previous reviews of other planning applications for sites located within the wider North East Cambridge Area, we are aware that groundwater is shallow beneath the site. The area is not located within a groundwater source protection zone. We are aware of one groundwater abstraction, located approximately 1 Km west of the site, used for agricultural purposes. The soils across the area have varying degrees of permeability meaning that they could readily transmit pollutants to groundwater. The River Cam is located approximately 250 metres south east of the site. We consider the current uses of the site, including the presence of Anglian Water's Water Recycling Centre (WRC) currently occupying approximately 40% of the eastern part of the area, Cambridge Science Park, St Johns Innovation Centre and Cambridge Business Park and the site's location and adjacent to railway lines to be potentially contaminative. Furthermore, there is an active landfill site (Milton Landfill Site) located within 100 metres of the northern site boundary.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

The site boundary obviously only covers the re-development itself, but currently makes no provision for the relocation of the Milton WwTW. This means that the issues, options, impacts, merits, mitigation and phasing for the plan cannot be assessed or planned. It also means that the scope for a successful duty to cooperate with the Minerals and Waste LPA is prohibited to such an extent that the AAP could be considered unsound. This is particularly significant in the context of an absence of any Milton relocation provision or overlap with the emerging consultation draft Minerals and Waste Local Plan, which shares a similar timetable, but runs ahead.

The Environment Agency finds it unorthodox that both plans (The Northern Fringe AAP and Minerals and Waste Local Plan) are progressing without having had conversations with statutory consultees or apparent evidence base around the Duty to Cooperate, when these plans have enormous potential to overlap and impact locally. We would welcome a rapid commencement of such discussions and ongoing cooperation. A resolution of this point would help partners to agree and justify what the scope and boundary of the respective plans should be.

Paragraph 3.6 states the reasons why the area of land to the east of the rail line is not included within the AAP area. Although we support the exclusion of this area from the developable area of the site, due to the flood risk posed by the River Cam, there may be benefits in including this area of land within the AAP boundary.

This area contains some existing 'highly vulnerable' development (i.e. caravans intended for permanent residential use) within flood risk areas. The AAP could therefore be a mechanism to provide wider community flood risk benefits though the provision of mitigation measures that reduce the flood risk to existing developments and make them more resilient to the future impacts of climate change (e.g. though the provision of floodplain storage areas on the edge of the existing floodplain).

The consultation document frequently uses riverside examples to illustrate the AAP's vision or the options presented. This indicates that the water environment is a key consideration and we therefore consider that the river corridor should be included within the AAP area.

On the basis of the above comments, we strongly recommend that the addition of this area of land within the AAP boundary is considered. Even though it will not add any additional developable area, it will allow for a strategic framework to be put in place for the management of flood risks impacts on the local community and the transport infrastructure.

Question 4: Have we identified all relevant constraints present on, or affecting, the North East Cambridge area?

Flood risk/Drainage
Climate change allowances have changed (worsened) significantly since the 2014 flood risk assessment. This means that with increased rainfall intensity, the land-take of surface water flooding reduction measures will increase. A review of the FRA should capture this.

Affecting the site is the suitability and feasibility of relocation sites for Milton WRC as could be picked up through an update to the Water Cycle Study (WCS). This is not currently addressed, and can be done so through the broadening of the scope of the AAP and accompanying SEA, HRA and WCS evidence base in cooperation with the Minerals and Waste Planning Authority and relevant statutory consultees.

We look forward to working with the City and District Council on this.

The section on flooding has identified all the relevant flood risk constraints at the development site. The requirement for development to mitigate flood risk through carefully designed sustainable drainage systems and other design measures has been highlighted. We consider that this section should also refer to the need to seek opportunities to reduce flood risk overall through the use of such measures.
Land Contamination
As a significant proportion of the site has previously been developed, we support the approach outlined in paragraph 4.2 (Contamination) of the Issues and Options 2019 Consultation. Potential contamination should be given due consideration together with any impacts of the development on groundwater and surface water quality it may have during construction and operation. We would recommend that Milton Landfill is included as an additional potentially contaminative off-site land use.

It should be included in the Area Action Plan that development proposals will only be permitted where it is demonstrated that the identified contamination is capable of being suitably remediated for the proposed end use.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

We welcome the vision for the site to include green infrastructure and blue infrastructure generally, and to plan for climate change.

There is a reference to HIF funding and this this would remove the constraint of the WRC occupying the site. Whilst HIF approval is of course helpful, it is the planning system planning for a new facility that also has a significant and rather less certain role to play. We suggest adding this for completeness and to manage expectations. Effective liaison between LPAs and Waste Planning Authorities with Statutory consultees should mitigate the uncertainty we raise, so we suggest adding some wording committing to partnership working.

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

We would add: NEC will enable the relocation of a nationally significant advancement in water recycling that is both resilient to long term climate change and serves the city whilst mitigating the causes and impacts of climate change.

Question 7: Do you support the overall approach shown in the indicative concept plan? Do you have any comments or suggestions to make?

We support the overall approach shown in the indicative concept plan, in particular the use of green infrastructure and a water management network that improves the First Drain. One of the aims of the green infrastructure and water management network should be to reduce flood risk within the site and elsewhere.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?

The LLFA will comment on this and the relationship between SUDS.

We would support options A, B and C as these would all provide opportunities for sustainable drainage to be incorporated into the green spaces.

There is the opportunity to improve habitats and ecology within the area through associated improvements to land around the First Public Drain. This will also afford the potential to contribute to wider objectives of water quality improvement in line with the principles of the EU Water Framework Directive.

This will be both in terms of the water quality within the drain (and further downstream within the catchment of the River Cam) and also through habitat creation associated with the vicinity of the drain. This could incorporate any adjoining SuDS which could form strategic green infrastructure within the site offering multi-functional, amenity, rights of way / access and integral Green Infrastructure links.

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water?

There is enormous scope for exemplar standards of water use and re-use along with SUDS with Anglian Water being landowners (or through CPO where the Councils bringing land forward), because the necessary implementation, management and aftercare can be written into land transactions. This could provide national excellence in rainwater and grey water harvesting. NB this is not normally achievable due to the complexity of regulation and reluctance/inexperience of landowners to take some ownership. This site provides a unique opportunity to go further than the NW Cambridge site where the Universities' ambition as landowner achieved some acclaimed results.
We should add a caution about SuDs and land contamination: From paragraph 11.13 we understand that SuDS are proposed for surface water management across the site. The Environment Agency supports the use of SuDS where they do not present a risk to controlled waters. The impact of potentially contaminated surface water drainage on the quality of controlled waters across the site should be considered - e.g. Infiltration SuDS in contaminated ground could promote the mobilisation of contaminants and give rise to contamination of groundwater or surface waters. A high level of remediation (and relevant controls) may be required to achieve this. The AAP should make it clear that planning applications (including outline) will need to carry our full investigations prior to planning permission being granted, to verify the locations and characteristics of SuDS. The AAP should be clear that this cannot be left to planning conditions if site layout is to be fixed.

It should also be noted that SuDS may not be applicable in areas where the groundwater level is close to the ground surface. The groundwater level should be assessed in determining the most suitable surface water drainage system for each development.

Deep infiltration SuDS are generally not acceptable in areas where groundwater constitutes a significant resource. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.

The Environment Agency supports the use of SuDS where they do not present a risk to controlled waters. Infiltration SuDS need to meet the criteria in Groundwater Protection Position Statements G1 and G9 to G13.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Yes - Integrated Water Management (see imminent CIRIA Guide to Integrated Water Management) to tie together SUDS, GI and water use/re-use in an integrated way on site with innovative management techniques that break the usual barriers to these happening on the ground.

Information about groundwater resources should be included in the Area Action Plan.

We have no further comments at this stage with the information currently available.
Please contact me if you have any clarification or discussion needs arising, and to further the various joint-working with related plans and relocation issues when more is known. We look forward to recommencing the ongoing process of working with your team and relevant partners.

1. There is very little mention of facilities and access for disabled people who cannot walk far or cycle. What are your plans to meet these needs?

2. It seems that there is only one bus route servicing the station - there needs to be many more routes from the station into Cambridge and surrounding villages. The buses need to be more frequent as well, especially on the weekends.
The buses could be smaller and run more frequently which could ease the journey into Cambridge.

3. More staff

4. Open up routes across the river for pedestrians, bikes, cars and public transport.

5. More security at night

6. More facilities - cafes, shops, bigger sheltered waiting areas

7. More people friendly environment - trees, flowers, water features, shade, shelter, use of renewables

8. Truly affordable housing, with adequate infrastructure for health, schools, shops

We are responding to the North East Cambridge Area Action Plan:
www.cambridge.gov.uk/north-east-cambridge-area-action-plan
We note the overarching objectives under three headings:
1. A place with a strong identity that successfully integrates into Cambridge, bringing economic growth and prosperity that is delivered with social justice and equality.

2. A high quality, healthy, biodiverse place which will be a major contributor to achieving zero carbon in Greater Cambridge by 2050.

3. A City Innovation District which will deliver affordable homes, a diverse range of quality jobs and excellent neighbourhood facilities.

Note that we have not provided answers to Questions 9, 10, 11, 12, 34-54, 57-83.

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?
The name should identify strongly with "Cambridge". However, we believe this area should also strongly identify as a "transit based" development and thus should be linked to the already well known "Cambridge North" rail and bus stations. The name should reflect this 'transit basis' and be known as the Cambridge North Area Action Plan and ultimately just as "Cambridge North".
In other words
"A place with a strong identity that successfully integrates into Cambridge, bringing economic growth and prosperity that is delivered with social justice and equality.
A high quality, healthy, biodiverse place which will be a major contributor to achieving zero carbon in Greater Cambridge by 2050."
Historic Cambridge must be protected by a series of strong identifiable districts. It must become poly centric.

Issue: North East Cambridge AAP Boundary
Question 2: Is the proposed boundary the most appropriate one for the AAP?
Fen Road East and River Cam towpath has been excluded between the level crossing and the A14 river bridge. This slither of land NE of the AAP (as the map shows clearly) is central to it as access to the river bank will be needed and be carefully managed and planned.

Leaving out the community established along Fen Road East is neither socially inclusive nor inclusive in terms of the physical planning for the AAP.
The success of the new AAP development may well depend on not creating "left behind" communities along its eastern edge.

Issue: The physical characteristics of the North East Cambridge area
Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Question 4: Have we identified all relevant constraints present on, or affecting, the North East Cambridge area?
Fen Road Level Crossing could become a real problem to train service development. The plan aims for "a high quality, healthy, biodiverse place which will be a major contributor to achieving zero carbon in Greater Cambridge by 2050". Without further train service development that enables more services to serve North Station those aims cannot be met. The level crossing should be closed with pedestrian and cycle traffic diverted by way of the adjacent riverside underpass. Road traffic along Fen Road East should be reversed and diverted by way of a new road that bridges the railway further to the north and crosses the AAP to join Cowley Road. The suggested bridge could be used jointly by the segregated users of bridge suggested in Q17.
Other measures to increase the capacity of Cambridge North Station should be consider such as making platform 2 the terminating platform and platform 3 the through platform with a cross over from platform 2 to the Southbound line close to the South end of the platforms.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?
Yes, agree.

Question 6: Do you agree with the overarching Objectives? If not, what might you change?
Yes, we do agree.

Question 7: Do you support the overall approach shown in the Indicative Concept Plan? Do you have any comments or suggestions to make?
Yes, we do agree.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?
Yes, we do.
Questions 9 to 12:
No answers provided.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?
Yes, it should together with active travel principles that show the development of pleasantly/interestingly designed footpaths and cycleways centres on North Station.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC?
Way mark the cycleways paralleling the Busway from the North Station together with a cycleway protected crossing of Milton Road. See question 16 also.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?
Yes they should. Places of employment of high quality design should focussed on transport hubs in particular near North stations.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?
A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.
B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.
D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.
E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.
Yes to all of A,B,C,D....bearing in mind the importance of focusing on North Stations as the primary transport hub.
E. Cambridge Business Park is of particular significance as it has effectively "turned its back" to all sustainable transport facilities. It is effectively a gated and 'policed' community that is inaccessible to public transport users. It must opened up and made more porous with routes such as those suggested in B and links to C.

Question 17: Should we explore delivery of a cycling and pedestrian bridge over the railway line to link into the River Cam towpath?
Yes you should. This should be explored in conjunction with our answer to Q4. This bridge should also allow vehicle access to Fen Road East to allow the suppression of Fen Road level crossing. The different uses of the bridge should be clearly demarcated/ separated. Depending on its location the new road on the west side of the railway it could be linked to railfreight terminal so that heavy goods vehicles carrying building materials from the terminal could get separate from other movements across the area under review. This new road could link into the north end (the dead end) of Cowley Road.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)
A,C

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high-quality frontage to help create a new urban character for this area?

Issue: Managing car parking and servicing
Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?
Yes

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?
Yes with emphasis on quality public transport (mainly quality frequent bus) linked to frequent train services serving North Station and buses on the guideway.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?
Yes...see above Q21a.

Question 22: Should the AAP require innovative measures to address management of servicing and deliveries, such as consolidated deliveries and delivery/collection hubs?
Yes. Consolidation of deliveries should be considered not only for this area but from this area for the whole city. A consolidation centre close to the railfreight terminal accessed by the extension of Cowley Road mentioned in Q4 and 17 could use emerging plans from railfreight operators for the development of a national rail based express packages/parcels network. Distribution of parcels across the city from such a terminal by cycle couriers and other developing sustainable technologies etc should be developed. Land should be set aside for this consolidated centre.

Issue: Car and other motor vehicle storage
Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?
Yes

Issue: Green Space provision
Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide 24th March 2019 Railfuture East Anglia - North East Cambridge Area Action Plan Page 6 of 9

flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.
Wherever and in what form, open spaces must be created with users of active travel in mind. They must be obviously safe places to travel through from stations to home, to leisure and cultural events and to work at all times of the day. Open spaces are essential but barriers to easy movement by pedestrians and cyclists they must never be.

Issue: Non-Car Access
Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?
a) North Station should be developed as the main hub of train and bus services.
The station itself should be further developed to be more user friendly with the installation of escalators, longer canopies over the platform and a more welcoming entrance hall.
b) The railway track layout must be further developed to enable more trains services to pass through and terminate and start at the station. The present station and layout sub optimal. Best practice from elsewhere must be studied and adopted to make intermodal transfer easy and very user friendly. 24th March 2019 Railfuture East Anglia - North East Cambridge Area Action Plan Page 7 of 9

The whole development area must be active travel friendly with easy to use high quality safe dry supervised cycle storage, easy to use footpaths and cycle ways.
c) Remove the guideways from the ends of the busway extension bus only road so to enable all buses, not just guided buses, to use the busway extension to serve the station. This would enable nonguided buses to access Cambridge North Station along the bus only road and allow through routing of bus services to the station via Cowley Road and leaving via the bus only road and vice-versa.
Run more bus services to and from Cambridge North Station both along this bus only road and from Cowley Road and Milton Avenue.
Build a new footpath/cycleway on the East side of the East end boundary fence of Cambridge Business Park to provide a shorter connection between Nuffield Road and Cowley Road.

Issue: Car usage in North East Cambridge
Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?
Yes.

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

Issue: Car Parking
Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?
Yes.

Issue: Cycle Parking
Question 29: Do you agree that we should require high levels of cycle parking from new developments?
Yes

Question 30: Should we look at innovative solutions to high volume cycle storage both within private development as well as in public areas?
Yes.


Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?
Yes.

Issue: Innovative approaches to Movement
Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?
A route (s) should be protected for emerging light rail (or other similar technology) networks; a route for local autonomous mass transit vehicles say between North Station and the Science Park.

Issue: Linking the Station to the Science Park
Question 33: what sort of innovative measures could be used to improve links between the Cambridge North Station and destinations like the Science Park?
Autonomous small vehicles running at frequent intervals better North Station and The Science Park...early to very late everyday.

Questions 34 to 54:
No answers provided.

Issue: Retail and Leisure
Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?
Yes, we agree. Such developments should be located around the transport hubs.

Question 56: Should the Councils be proposing a more multi- dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?
Yes

Questions 57 to 83:
No answers provided.
Issue: Any other comments
Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.
Ensure that construction materials for the development should be as far as possible be delivered to and through the modern multi user railfreight terminal already on site. This currently receives large quantities of differing types of aggregate from various parts of the country by rail. Large quantities of varying types of cement will be required. The developers should be encouraged to set up a rail served cement terminal for use locally and throughout the district.

Q2: We note the justification in section 3.6, however, CambridgePPF believe that extending the boundary of the site east of the railway would offer greater potential for wildlife and ecological enhancement. However, we appreciate the constraints that Network Rail may place on its inclusion. We would also be interested to see how better access to the river can be achieved from within the site.

Q7: CambridgePPF agree the development should be mixed commercial, housing and retail with recreational opportunities. However, do not want to see sections of the site turn into a ghost-town in the evening when the office commuters go home. The site should provide a balanced approach that enables the business and residential use to support the retail and recreational offerings, and housing that supports office and other key staff, plus provides sufficient truly affordable homes. This site could be used solely for affordable to prevent
its location being taken over by commuters wanting to live close to the train station.

At this stage, it is still unclear how the site is to be developed. We understand the relocation of the water treatment plant will enable its area to be redevelopment (based on how much space is required for a pumping station and other equipment onsite). But the area within the Science Park, St John's Innovation Centre, the Cambridge North station development, etc. are already built out (or in the process of being).

Therefore, how and where are the additional new homes and jobs going to be located?
For example, there are opportunities in the Science Park for increased densification by replacing the wide expanses of surface car-parking with a multi-storey carpark to release land for further development. A even more optimum solution would be to locate the parking underground and improve the aesthetic of the site as a whole.

The existing open amenity spaces (natural environment, green and amenity spaces) should be retained and enhanced as much as possible.

Q8: CambridgePPF believe that before deciding what should go where within the AAP site, a study of the site as a whole from within and without the site is vital to assess the impact of higher density in particular locations. This should include understanding what exists, what percentage is commerial/industrial, business, etc. to then indicate what the remaining space would be best used for. The mix and balance of business versus residential is vital for a successful community and at the moment, the majority of the site is business. But that does not automatically mean that the remaining space available should be residential.

For example, the Science Park already has multi-storey buildings and has the capacity to cope with higher density. Typically, along rail lines developers prefer a variation of heights that work as sound barriers to the site. But every site is different. In addition, the location of taller buildings/more density will impact upon its adjacent neighbours- which could result in a reduction in amenity space and natural light, or visual harm from overbearing buildings that are not contextual to the site and surroundings.
Without further information it is difficult to determine which parts of the site could accommodate higher density/taller buildings and which areas will it have the least impact. Considerations should include views from within and without the site, the views from the A14, impact to the ecology, etc.

We also believe that careful consideration should be given to what is located adjacent to the Cambridge North station. It is an ideal location for residential and commercial for quick access to other cities. However, we would want some assurance that the ownership would prioritise locals first.

Q9: Refer to question 8

CambridgePPF believes that whilst relocating the existing businesses in this area might be advantageous in order to redevelop the brownfield land, these businesses would need to find a new location to relocate to.

Would they be given assistance to do this? It is not feasible at this stage to assume that they will either want to move or be able to move.

This became a significant issue during the last local plan call for sites because the Council wished certain sites would become available, but the existing businesses could not find new premises and therefore could not move. Without assurances, this can be a gamble.

However, there is definitely an opportunity to improve and enhance the visual appearance of this part of the site, make it more user friendly to access, rationalise the open spaces, etc.

Q11: CambridgePPF support the inclusion of a variety of community use facilities, to be explored, such as nursery, GP surgery, community hall space, cafes, etc. to ensure that the new town creates a sense of place and provides facilities that the new residential and commercial units would benefit from. Their inclusion within the site also reduces the reliance on cars, which is necessary.

Whilst we note that many of these uses are already provided for within the Science Park, having to cross Milton Road to access them could prove a challenge. It is likely then that some facilities and uses may have to be duplicated.

Q12: CambridgePPF highly recommend that several of the recent developments around the city- both residential and commercial- be assessed and reviewed to create a 'lessons learned' document. This should highlight what has been successful, what has not, are there particular locations that work better for certain functions, what enables better community spirit, what creates better open space, which facilities should be included, the best environment to live and/or work in? Which site has created the best quality of life? Examples from other cities may also be useful. This will enable the Council to learn from the work of others without having to 'reinvent the wheel'.

One of the biggest challenges with the AAP site is the distinct division created by Milton Road- which bisects the two halves of the site. The railway line is another firm boundary that is immovable. These constraints could hamper the sense of inclusion and community- unless you plan your community using these distinct sections. However, the risk is that you then create two communities and double the provision.

Q15: CambridgePPF refers to question 8 in response to this question

Q17: CambridgePPF is supportive of creating a connection between the neighbourhoods via a bridge of some kind over the railway. It would enable better connectivity and hopefully create a sense of inclusivity.

Q18: CambridgePPF supports the principles proposed in question 18, however, raises concerns about the potential overlap or conflict with the other projects being proposed for this area. These include the GCP Milton Road improvements, the GCP Greenways project, the Combined Authority Metro proposals, the East- West Rail proposals, etc.

This section of Milton Road from the A14 to Kings Hedges/Green End Road is visually unattractive and difficult to navigate. Trying to cross Milton Road from east to west is problematic due to the number of lanes and levels of congestion. The introduction of formal pedestrian/cycle crossings could exacerbate this congestion. Studies should be done to determine what options there are and what the best way to achieve this is. The introduction of a bridge over Milton Road would create yet another physical structure in an already visually crowded and confusing corridor. Milton Road is one of the main arties into the city centre. It may be possible to go underground with a well designed and creative subway that links both sides of the road. This may be more costly, but visually and aesthetically it could be a preferred option.

Any opportunity to rationalise this stretch of the road should be sought, including improvement the landscape and environment alongside. There could be an opportunity to rework the existing pedestrian subway at the Guided Bus intersection as well. This should include street clutter, signage, etc. to improve the area. However, more information is required.

Q24: CambridgePPF support the proposals for green spaces throughout the site. These should include different uses and users from being able to kick a football, to having a picnic, to play areas for different age groups, to areas to address SUDS requirements, ponds or lakes, etc. for both residents and business occupants.

Again, looking at other large scale developments around the city to assess successful projects would be useful before trying to create something from scratch.

The Science Park hosts a variety of events within their site, including local businesses food trucks during the
week.

However, any new green spaces should facilitate cross corridors for wildlife and ecology to thrive. Through views should also be considered.

Q32: CambridgePPF supports the 'future proof' approach, however, would not wish to limit it to only technology based ideas. We recommend that spaces (both residential and commercial) are designed to be as flexible as possible. This could include the ability to easily convert two units into one and vice versa. This would enable the units to accommodate a variety of users as trends and needs change.

For example, the current housing needs that the local plan is based upon will change within the next 5 to 10 years. Therefore, if the Councils only allow one-bed properties to be built and the need for family houses surges, there is very little ability to address that need without substantial cost and disruption. This is true of garden and amenity space. Many large gardens are being developed for additional houses.

Whatever technologies there are to provide the flexibility to adjust to market trends (including variable sized commercial units) should be explored.

Q38: See answer to 32.

Q39: CambridgePPF believes that new developments should be required to ensure a percentage of residential units be made available to keyworkers. These include primary (office staff) and ancillary (cleaners, etc.) staff from adjacent business uses to be provided due to affordability issues. This also prevents long commutes for these workers from outside the city.

A successful new community is made up of a variety or users and needs. This includes typology as well.

Q40: CambridgePPF would like to see an increase from 40% to 50% of affordable units, including a wider mix of tenancy options and sizes of units. Included in this question is the caveat, 'subject to viability' which we consider to be a red herring and something that the NPPF and Central Government have been trying to address.

The construction of this development is quite a few years off and there is no way to know what the needs will be for the site, despite trying to establish guidelines now. In addition, it is very possible that the site will be built by numerous different developers and constractors, again creating some uncertainty of budgets and costings. The argument over what is viable is complex and based on many factors, including how much the land cost. Therefore, it would be all too easy for a developer to eventually say that they are unable to provide a higher level of affordable units because it is no longer viable and does not stack up. To ensure this does not happen, we challenge the Council to provide assurances over this issue.

We would want to see more certainty given to this vital issue and if the new town is to be exemplary, we recommend requiring 50% affordable be provided. The need for affordable units is only likely to increase over the next few decades- not decrease. Regardless of the price paid for the land or the numbers stacking up, this should be embeded in the development brief.

Q41: Refer to question 40

Q42: CambridgePPF supports the opportunity for people to develop and build their own homes. This could provide an exciting dynamic within a new community.

Q51: CambridgePPF has seen a worrying trend over recent years of developers trying to shoehorn as many units as possible within a site to maximise profit. The result of this is the units barely meet the minimum standards for residential space requirements. The approval of proposals like these does nothing for creating a high standard for quality of life if the size of the unit is barely above minimum.

Minimum does not mean optimum. Standards are a starting place, not the only place.

If this development wishes to be exemplar, then it should apply a higher level of standards. This not only goes for internal space requirements, but for external amenity space as well as accessibility standards.

Q53: Refer to question 51.

Q54: Refer to question 51.

Q62: CambridgePPF prefer option D.

Q67: CambridgePPF welcome the opportunity to ensure this new development results in a net gain for biodiversity and ecology. If it is not possible to do so within the development site framework, then alternative sites adjacent could be considered, especially for any mitigation.

Natural Cambridgeshire Local Nature Partnership has created a toolkit to assist developers in achieving a net gain in biodiversity and we recommend it be reviewed and considered for use in this new development as well as others: https://naturalcambridgeshire.org.uk/projects/developing-with-nature-toolkit/

Q69: CambridgePPF believes that prior to committing to any particular system, an assessment of the existing facilities used at Eddington- which includes the underground waste system- should take place. This should provide sufficient information to understand the benefits of the system, if any. It is impossible to answer this question without further information.

Q70: CambridgePPF understands that phasing and occupancy are complicated and have a significant impact on the success of new developments. There can be significant conflict between what development to provide first- housing, facilities, etc.

In order to meet targets, bringing forward available land for development would make sense. However, this should be caveated on the following: location available for staging, equipment, materials, issues raised from noise, dust, vehicle movements, etc.

The risks could include impact to adjacent properties, the location that comes available first may not be a strategic site, etc. A organised and scheduled approach for the site should be outlined as best as possible to ensure that it follows a logical end, minimising damage, disruption, etc. to all adjacent. This is especially true since the site will involve numerous different developers, architects and agents, at different times all who will have their own construction crews, etc.

This has the potential to become chaos without the Council, or someone, project managing the entire site.

Q71: CambridgePPF agree that a strategy would enable a more logical and controlled approach. It would be prudent to try and include this within the work being done on the new joint local plan. It would also facilitate a more joined up approach since the site straddles the boundary between the City and District Councils.


Q72: CambridgePPF believes that there is a lot of competition for Section 106 funds. But requiring it to be focused solely within the site is misguided. We believe that a broader approach to reviewing Section 106 funds should be taken for all new developments since the impact from new developments is becoming wider.

Once the required facilities are agreed and supported through Section 106 funds (such as schools, GP surgeries, nurserys, etc) then any remaining funds should be reviewed against this criteria.

For example, residents in new housing developments in and around Cambridge have fewer places go to on the weekends. It may be convenient to stay within the development and use their green spaces, but many seek to get out. Our sites- Wandlebury Country Park and Coton Countryside Reserve absorb many of these people and the impact from the additional numbers is evident. However, we do not benefit from any Section 106 funds.

We recommend Councils support local amenity sites in the context of spreading the funds more widely.

Q77: CambridgePPF acknowledge that this site has the potential to have dozens of owners and developers all trying to work at different stages. Refer to question 70.

As a result, it is highly recommended that all of the owners, tenants, etc. are brought together at an early stage and a working group created.

We have seen challenges with Waterbeach New Town and they have only two owners. But the potential for duplication of provisions, confusion over access through the site, and the ability to provide a single cohesive development is threatened if a joint working relationship is not created. A memorandum of understanding could be employed as a way of addressing this.

Q79: CambridgePPF supports the principle of 'meanwhile use' for sections of the site as appropriate. These could include pocket parks, viewing areas to watch construction as it progresses, staging areas for materials/concrete/etc. It should be a balanced mix of public benefit use and customer buy in against the requirements of a construction site.

Q84: CambridgePPF feels like there is an insufficient amount of information provided at this time to properly assess the benefit, impact, risk, etc. of the new development. We have the following concerns that do not appear to be addressed within the consultation information:

1. Whilst the Council has been given the funds to relocate the water treatment plant, there is still the question of where it would be relocated to. Due to the inherent constraints, we presume it is not capable of being relocated too far away due to the existing plant, pipes, etc. This is a vital piece of the puzzle and without this information you are unable to fully develop the site and create the new town being sought.

2. In addition, what is involved in relocating it and what works will have to be done to the existing site to make it reusable?

3. Even if the treatment centre is relocated, an amount of plant will still have to remain to access the existing equipment, for example a pumping station will be required, etc. This needs to be factored into the AAP process to ensure spatial requirements are met and any repercussions are understood upfront.

4. There is also the issue of noise/smell with the aggregates/bitumen workings on the railway sidings, bulldozer/lorry movements etc, smell of the bitumen. What are the provisions for this?

5. As a result of all of the above, less land may be available then assumed for development. This should be understood at this early stage.

6. The document focuses on those who live and work in the site, but what about those who come into the site just to access the rail station or hotel? How will they access and interact with the site?

7. There is very little in the document about transport issues, other than making the site less reliant on cars, promoting more cycle and rail use. This is very worrying as Milton Road is already heavily congested and the proposal would intensify this. We recommend that a clear vision on transport matters, including access, needs to be carefully studied and assessed to ensure the site delivers a sustainable development. This should include the current proposals from the GCP and Mayor on various provisions.

8. Constraints were mentioned in the consultation document, but any assessment of impact to the sites were not included. That is a critical omission, especially at this early stage. For example, the Bramblefields LNR is adjacent to the site and this proposal could result in harm to it. There are other designations which require further investigation.

Further response received via email: The NE Fringe sits adjacent to the river Cam valley and Fen Ditton. The rural setting of this area, with the countryside coming into the City is of great importance in planning terms, particularly with regard to the Cambridge Green Belt. Whilst the NE Fringe would not impact this directly, there is a danger that it may do so indirectly, by impacting the views (eg from Ditton Meadows). Therefore, building height and the location of any tall buildings would need to be considered very carefully in relation to the views and setting of the historic city.

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

Question 4: Have we identified all relevant constraints present on, or affecting, the North East Cambridge area?

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

Question 7: Do you support the overall approach shown in the Indicative Concept Plan? Do you have any comments or suggestions to make?

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

Question 17: Should we explore delivery of a cycling and pedestrian bridge over the railway line to link into the River Cam towpath?

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

Question 22: Should the AAP require innovative measures to address management of servicing and deliveries, such as consolidated deliveries and delivery/collection hubs?

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

Question 29: Do you agree that we should require high levels of cycle parking from new developments?

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

Question 30: Should we look at innovative solutions to high volume cycle storage both within private development as well as in public areas?

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

Question 33: What sort of innovative measures could be used to improve links between the Cambridge North Station and destinations like the Science Park?

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

Question 34: Are there specific types of employment spaces that we should seek to support in this area?

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

Question 38: Should the AAP require a mix of dwelling sizes and in particular, some family sized housing?

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

Question 40: Should the AAP require 40% of housing to be affordable, including a mix of affordable housing tenures, subject to viability?

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

Question 49: What type of management strategy is necessary to ensure high standards of ongoing management of PRS premises is achieved?

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

Question 51: Should the AAP apply the national internal residential space standards?

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

Question 53: Should the AAP apply External Space Standards, and expect all dwellings to have direct access to an area of private amenity space?

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

Question 54: Should the AAP apply the Cambridge Local Plan accessibility standards?

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

Question 59: Should open space provision within the North East Cambridge area prioritise quality and functionality over quantity?

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

Question 63: Do you support the approach to sustainable design and construction standards suggested for the AAP?

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

Question 69: Should the AAP require the use of an underground waste system where it is viable?

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

Question 72: Do you agree with an approach of devising a Section 106 regime specifically for the North East Cambridge area? If not, what alternative approach should we consider?

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

Question 77: Should the Councils actively seek to facilitate joint working between the various landowners/developers within the North East Cambridge area? If so, what specific matters could we target for joint working?

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

Question 80: Should there be any limit on the scale of a proposed 'meanwhile use'?

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

Question 81: Do you think it appropriate to set a maximum period for how long a 'meanwhile use' could be in operation?

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

I attended the Nun's Way Consultation last week and spoke with your Officers.

Having explained that I represent the British Horse Society (BHS), it became clear that equestrian access had been excluded from the project for a number of reasons including the fact that Officers were unsure what provision was needed and how it could be delivered.

I have provided a very detailed response, including information on why equestrian access should be included. I have provided this information to enable officers to understand what is required and how it can be provided.

I am aware that the project is at a very early stage but it is essential that the mindset going forward is for multi user access and not shared pedestrian and cyclist access.

I trust that this response is helpful but if I have not provided all the information you require, please let me know.

North East Cambridge Area Action Plan

Consultation Response on behalf of the British Horse Society


I am the British Horse Society (BHS) County Access & Bridleways Officer - Cambridgeshire. I would comment on the above consultation as follows:

Firstly, I would like to say that I am very pleased to see that equestrianism has been acknowledged in the Consultation document but very disappointed to see that no equestrian access has been included in the project. Having met with Cambridge City Planning and Development Officers at the Nun's Way consultation, I understand that this may be partly due to the fact that the project officers do not know how equestrian access could be provided and have asked for guidance from the BHS.

There are many reasons for the provision of offroad access for equestrians with that of safety being the most important.

What are the BHS seeking to be provided in this project:

* all routes linking to settlements or rights of way which are currently proposed as shared cycle and pedestrian should be delivered as multiuser (pedestrian, cyclists and equestrian) paths.
* peripheral routes around significant green spaces should be multi user routes.
* all crossings over, under or around barriers such as roads, railways or rivers should be multi user.

The obvious linking opportunities are:

* the Guided Bus bridleway at Milton Road to Waterbeach and Milton Country Park via the Waterbeach Greenway or any other proposed cycle and pedestrian routes
* Waterbeach to Byway 162/3 Milton via the Guided Bus bridleway via the Waterbeach Greenway or any other proposed cycle and pedestrian routes
* Links to Ditton Meadows or any other communities to the East.

The existing Guided Bus bridleway is shown on the above map which highlights how easily the site could provide a safe, off road link between the proposed Waterbeach Greenway and the bridleway.
Having reviewed the Consultation document, I would make the following specific comments:

Green infrastructure A network of multi-functional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities
This should include equestrian access. An advantage of the presence of equestrians has been reported by Landscape Architects is that including equestrian access around public spaces discourages antisocial behaviour - the appearance of a horse and rider has more impact on those engaging in antisocial behaviour than say a pedestrian or a cyclist.

Sustainable modes of transport: Any efficient, safe and accessible means of transport with overall low impact on the environment, including walking and cycling, low and ultra low emission vehicles, car sharing and public transport
Sustainable transport includes horse riding.

4.6. Milton Country Park, which provides access to woodlands and lakes, as well as a visitor centre and children's play areas, is located across the A14 to the north. The River Cam corridor, to the east of NEC, includes walking and cycling opportunities.
Equestrian access is also available at Milton Country Park.

NEC will provide a new model for low car dependency living, through maximising the use of and integrating with public transport, walking and cycling infrastructure.
Transport includes journeys for leisure which includes horse riding.

NEC will integrate with surrounding communities, spreading the benefits it delivers to surrounding areas.
The opportunity to link equestrians in Waterbeach to Histon and beyond would provide a benefit.

NEC will be a healthy place, with a focus on creating a new community with good health and wellbeing.
The health benefits of equestrianism is well documented and noted below.

6.3. The NEC Indicative Concept Plan (at Figure 6.1) begins to describe the kind of place that could be created with the successful regeneration of the area. Movement and the ability to do so easily on foot, by bike or on public transport is central to making the area a well-connected place that reduces the need to travel by car. A high quality green route that supports sustainable transport modes will improve connections from the Cambridge North Station to the Cambridge Science Park, and reduce the barrier that is Milton Road.
Access across Milton Road should be multi user.

6.6. Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life.
Linkages to the wider countryside hould include equestrian access - public money should be spent to benefit the widest range of users.

6.14. Cambridgeshire County Council has produced a Housing Developments and the Built Environment Joint Strategic Needs Assessment, which emphasises the relationship between planning and health and wellbeing of new communities. The draft AAP will need to include health related policies. A range of issues addressed in this issues and options report would contribute to making the NEC a healthy and safe place.
The health benefits of equestrianism are well known and noted in the Case for the Inclusion of Equestrian Access below.

6.15. Recently the new town of Northstowe has been part of the NHS Healthy Towns Initiative. This considered how health, and the delivery of healthy communities, could be a key driver in the planning and design process for a new community. It provided an opportunity to explore innovation and best practice. The principles it explored included promoting inclusive communities, good access to health services, walkable neighbourhoods, high quality public transport and cycling links, and opportunities for physical activity. There are opportunities to apply similar principles in North East Cambridge.
Planners and Homes England have worked closely with the BHS at Northstowe and a network of bridleways / multi user routes are included in this project.

Local movement and connectivity

6.21. Chapter 7 of this Issues & Options report considers the wider transport implications of the regeneration of NEC. At the local level, and intrinsically linked into the placemaking led approach, are decisions around movement and connectivity within the NEC area and linkages to the surrounding area. Improvements could establish new or upgraded walking, cycling and public transport connections between Cambridge North Station, the employment areas, Cambridge Regional College, and the surrounding neighbourhoods. In addition, leisure and active routes for walking cycling and equestrians which integrate with the wider countryside beyond are crucial in achieving a shift away from private car dependent forms of development, and towards a 'walkable district'. This would allow and encourage easy change between sustainable modes and influences the way that the place will work and meet the needs of those that live and work in the area.
Equestrian access which integrates with the wider countryside is identified in the report and mentioned in this Clause as 'crucial' yet it is not included anywhere in the project. This needs to be rectified.

6.22. A number of projects would help to establish improved connectivity to NEC, including the Chisholm Trail and Waterbeach Greenways. These would be delivered as part of separate projects and would connect Cambridge North Station with Cambridge Station, Cambridge Biomedical Campus and Addenbrooke's Hospital. In addition, they provide linkages to Northstowe and the planned new town north of Waterbeach.
Wherever links are proposed between communities for pedestrian and cyclists, equestrians should be included unless there is good reason for them not to be. The BHS is the authoritative body to make these decisions. The Greenways are multi user routes - it is very disappointing to see that equestrian access mentioned in the preamble has not been included at this level.

Issue: Local movement and connectivity Question 16:
Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.
Multi user access required not the provision of restrictive cycle and pedestrian access.

C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.
Multi user access required not the provision of restrictive cycle and pedestrian access.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.
Equestrian access required on the inter community links.

Issue: Crossing the railway line Question 17: Should we explore delivery of a cycling and pedestrian bridge over the railway line to link into the River Cam towpath?

Green Space
6.34. The site is in close proximity to Milton Country Park and the River Cam Corridor. There will be a requirement for development in NEC to improve pedestrian and cycle connectivity to these well used spaces. As part of this strategy, a strong green infrastructure network will be introduced through the site which will connect north towards Waterbeach new town, west through the Science and into Cambridge Regional College, and east to the River Cam and the fenland landscape beyond (see Transport Chapter).
Any such infrastructure must be multiuser - to do otherwise would be contrary to the Cambridgeshire Rights of Way Improvement Plan since the creation of restrictive pedestrian and cycle only access further fragments the already inadequate bridleway network.

6.35. If NEC is to make a significant contribution to Greater Cambridge's employment and housing needs, maximising the benefits to be realised from the new rail station and Guided Busway, it will be critical that the AAP requires enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.
This should be multi user for all the reasons already quoted.

6.36. Green Infrastructure provision will help to structure and soften this new city district. It has a key role in providing space for sustainable drainage systems (SUDS), which will be important in this area. They also provide social spaces which support community activities and healthy activities.
Must be multiuser for all the reasons already quoted.

F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

7.12. Comprehensive high quality pedestrian and cycle networks should permeate the area and link to the surrounding area. There are a range of connectivity issues within the North East Cambridge area that will need to be addressed.

7.13. NEC is well placed to link into the cycle network that crosses the city, as well as routes that serve destinations beyond the city, such as towards Northstowe. Improvements are already planned which will improve access to the area further:

* The Chisholm Trail, creating a mostly off-road and trafficfree route between Cambridge Station, via Abbey, and the new Cambridge North Station, and beyond to St. Ives and Huntingdon.
* Waterbeach Greenway. The Greenways will provide cycling, walking and equestrian routes into Cambridge from the larger villages surrounding the city. Route options for Waterbeach Greenway cross through the NEC site.

7.12 and 7.13 must be multiuser for all the reasons already quoted.

Issue: Non Car Access Question 25:

As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?
Include bridleway provision in the S.106 Agreement.
 
THE CASE FOR THE INCLUSION OF EQUESTRIAN ACCESS

The BHS (British Horse Society)

* The British Horse Society (BHS), together with the membership of its Affiliated Riding Clubs and Bridleway Groups is the largest and most influential equestrian charity in the UK.
* The BHS represents the interests of the 3 million people in the UK who ride or who drive horse-drawn vehicles.
* The BHS works for safer on and off-road riding and carriage driving through an improved public rights of way network, and seeking to create new opportunities of lawful off road riding and carriage driving, and safer use of our roads by all road users.

Between 2010 and 2017 the BHS horse accidents website has recorded:

230 horses died on the roads and 840 were injured, 5 severely

39 riders killed, 10 severely injured
* 3,863 horse riders and carriage drivers in England and Wales were admitted to hospital for 'animal-rider or occupant animal-drawn vehicle injured in transport accident' in 2016-17 (source: NHS Hospital Episodes Statistics)
* Only 1 in 10 horse related road accidents are reported (source: British Horse Society)

The regions with the highest number of incidents are: West Yorkshire, South West and the East of England

These figures demonstrate how important it is that planning authorities, developers, Highways and Strategic Transport understand the requirement for safe access for equestrians on the roads and the links to PROW (Public Rights of Way Network)

The Equestrian Industry's Impact on the Economy

* The contribution made by the equine sector to the UK economy in 2017 excluding the racing industry was £4.3 billion
(source: British Equestrian Trade Association).
* The Equestrian Industry is the second largest rural employer after the agricultural sector in the UK
(source: British Horse Industry Confederation 2017 Mid-Sector Manifesto).

Health and Well-being - Benefits of Horse Riding : Research undertaken by the University of Brighton and Plumpton College on behalf of The British Horse Society:

* The majority of horse riders are women (90%) with more than a third being over 45.
* Horse riding and activities associated with horse riding, such as mucking out, expend sufficient energy to be classed as moderate intensity exercise.
* Horse riders with a long-standing illness or disability who took part in the survey are able to undertake horse riding and associated activities at the same self-reported level of frequency and physical intensity as those without such an illness or disability

Active women raise active children.

Equestrianism falls into the category of 'Active Travel'

The importance and benefits of regular exercise and being outdoors are well known and established. The majority of horse riders are female whereas the majority of cyclists are male. Riding is a sport which you can participate in at any age. Despite the popular view that horse riding is elitist, the reality is that people from all walks of life ride horses with a strong social network.

Exercise as part of family life installs good lifetime standards. Getting back to riding their horse often motivates women to recover more quickly from serious illnesses and surgery.

For some disabled people, their only opportunity to access the countryside is on horseback or horse drawn carriage which gives them a freedom they cannot achieve in their everyday lives. On horseback, a disabled person is at the same eye level as other riders something which wheelchair bound people rarely achieve, giving a feeling of belonging and inclusivity.

The psychological and social benefits of horse riding :

* Horse riding stimulates mainly positive psychological feelings.
* Horse riders are strongly motivated to take part in riding by the sense of well-being they gain from interacting with horses. This important positive psychological interaction with an animal occurs in a very few sports.
* Many differently abled children, such as those coping with Autism, have also benefitted from working with horses.
* Being outdoors and in contact with nature is an important motivation for the vast majority of horse riders.

Research is showing that the old pun 'horse people are stable people' may be more factual than previously understood because of the positive psychological feelings which being around horses generates. One little boy in South Cambs refuses to speak although he will talk to the horse during his Riding for the Disabled session.

Riders and drivers often say that having the opportunity to spend part of every day outdoors tending their horses is their 'chill' time and allows them the opportunity to 'recharge their batteries' away from the stresses of daily life. As Winston Churchill, allegedly said: "There is something about the outside of a horse that is good for the inside of man."

The Guided busway St. Ives to Cambridge

The bridleway created alongside the guided busway which was instigated by Swavesey Bridleways Group was inspired - a fantastic facility created on a service track.

Just to be clear, bridleways have always been available to pedestrians and horse riders and since 1968, with the support of equestrians, bicycles were included as rightful users. On a bridleway, horse riders must give way to pedestrians and cyclists must give way to pedestrians and cyclists.

What is a good design of an NMU (non motorised user pedestrians, cyclists AND horse riders) path? Simple ....

Don't put the cycle path down the centre of the route leaving two narrow, useless grass verges either side, combine the two verges and put the cycle path to one side. It was established at the Cambridgeshire Planning Committee when the Que to Lode shared cycle and pedestrian path was being considered, that it costs no more to build an NMU path than a shared cycle and pedestrian path.

It really is that easy - on NMU paths we are not asking for new paths or new routes - simply a good design and not to be excluded.

The DNA path alongside the railway In Great Shelford was a good idea in its time but the flaws and lost opportunity are clear. The grass clippings from the mower fall on to the tarmac from both sides where it decomposes and allows herbage to establish and reduces the width of the hard top path forcing users on to a narrow section increasing the potential for conflict. The clippings on the path also become very slippery in wet weather and are a problem for cyclists.

Having a decent grass verge is a refuge for pedestrians to get out of the way of cyclists, is a more pleasant walk for dogs and is appreciated by runners who like horse riders, are concerned about the impact of a hard surface on joints.

The DNA path does raise another issue - that of maintenance. Failure to maintain a path is poor use of public capital expenditure. Clever design would take into account the optimum width for the mowers to ensure that the grass can be kept to a useful length.

Perceived barriers to including equestrians on NMU paths

* Horses pose a danger - No evidence
* Horse droppings - No danger to humans
* Potential Conflict - No evidence
* Landowners refuse equestrian access - we will check!
* Reality is that best use of public funds is for access facilities to be available to as many users as possible.

There are no recorded incidents of third party injury caused by horses being ridden on any public right of way.

Horse poo presents no danger to human health and quickly disperses. However, we do encourage riders to remove droppings from path.
Conflict with cyclists is often held as a reason to exclude us. This rarely has anything to do with the bicycle - its just an inconsiderate person who happens to be on a bike (or horse!) that day. Horse riders and cyclists as two vulnerable road user groups have far more in common with each other than differences.

Conflict with commuter cyclists who want to cycle quickly is also cited a reason to exclude horses however, commuter traffic is time of day related and tidal. Riders chose to avoid peak traffic times on paths in the same way as going into town in a car. According to CamCycle, there is a speed limit of 15 mph on cycle paths - bikes with motors are governed to 15 mph - any which have been altered to travel more quickly are not allowed on cycle paths.

Vulnerable Road Users

* Historically vulnerable road users have been considered to be pedestrians and cyclists.

* British Horse Society working at all levels to ensure horse-riders vulnerability is recognised. Horses are now recognised as the most vulnerable road user.

* November 2018 at the Parliamentary Debate on Road Safety in Westminster, the Under Secretary of State for Transport, Jesse Norman said: 'We should be clear that the cycling and walking strategy may have that name but is absolutely targeted at vulnerable road users, including horse-riders.'

Historically, vulnerable road users have been identified as pedestrians and cyclists. Highways, Rail Infrastructure Planners, Planners, Agents and Applicants, have been educated to cater for pedestrians and cyclists precisely because they are vulnerable road users. However, change is afoot.

Statistics demonstrate how vulnerable horse-riders are on the road. These aren't just theoretical examples. Conflict between horses and cars happens every day on the roads.

Personal examples are:
'a car drove by so fast and so close that the car hit my leg with its wing mirror as I was riding along the road.'

'a car was driving down a 60mph road so fast that the driver couldn't slow down sufficiently without hitting my horse on the road so the driver had to drive the wrong way around traffic calming bollard in the road - thankfully no one was coming the other way.'

Horse riders have to accept it could and probably will happen to them but with nowhere to hack out other than the roads, there is little choice but to take the risk. It shouldn't be like this.

The British Horse Society has been working at all levels to ensure this vulnerability is recognised.

In November 2018 Jesse Norman confirmed 'We should be clear that the cycling and walking strategy may have that name but is absolutely targeted at vulnerable road users, including horse-riders.'

The current RoW Network

* The length of the public right of way network currently amounts to 188,700km, consisting of
* 146,600km of footpaths,
* 32,400km of bridleways,
* 3,700km of byways and 6,000km of restricted byways.
* Horse riders currently only have access to 22% of public rights of way and horse-drawn vehicle drivers only 5%.
* The Cambridgeshire Rights of Way Improvement Plan - bridleway network is fragmented and in need of improvement. Development and the creation of shared pedestrian / cycle paths further fragments the network

Across the UK Horse riders are currently excluded from 78% of the Rights of Way network and carriage drivers are excluded from 95%.

Going forward, the only way to improve things for the future is to secure new inclusive rights of way which cater for pedestrians, cyclists and horses.

What needs to be included in the Project

* Joining up of any severed PROW's.
* All crossings of access barriers need to be NMUs.
* Optimise opportunities to provide missing links to improve the PROW network.
* Surfaces to be suitable for all users - the BHS can provide specifications and information.
* Consult with the BHS throughout the development process to ensure that riders' needs are included - public money must be spent to the benefit of as many users as possible.
* Where possible, ensure that PROW's are kept open or alternative routes provided during the construction period.

There are a great many local and national planning policies and strategies which support the inclusion of equestrians in new projects including:

NPPF: 92,96, 98, 141
The Government's Strategy for the Horse Industry in England and Wales
The Highway Code
Highways England Accessibility Strategy
South Cambridgeshire District Local Plan HQ/1:f, TI/1:2.b, TI/1:2.c; NH/6 Green
Infrastructure
South Cambs Design Guide 4.12, 4.13
Cambs ROWIP - Policies SOA1, SOA2, SOA3, SOA4, SOA5 and Future Programme


Should you wish the BHS to provide you with this further information, I would be happy to do so. This could be provided in the form of a presentation if you feel it would be of assistance.