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

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Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33276

Received: 25/03/2019

Respondent: Anglian Water Services Ltd

Representation Summary:

Please see our response to Question 79.
The types of 'meanwhile uses' which would be appropriate at the time of the application would be dependant upon the timing of the re-development of Cambridge North East development particularly when Cambridge Water Recycling Centre is expected to be relocated.

Object

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33683

Received: 25/03/2019

Respondent: U+I Group PLC

Agent: Carter Jonas

Representation Summary:

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.

Full text:

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 parkingcan 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).

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33759

Received: 25/03/2019

Respondent: Brookgate

Agent: Bidwells

Representation Summary:

Not necessary

Full text:

1.0 Introduction

1.1 These representations are made on behalf of Brookgate Land Limited and in response to the
North East Cambridge Area Action Plan (AAP) Issues and Options 2019 consultation. These
representations follow those previously submitted in respect of the 2014 Issues and Options
consultation.

1.2 Brookgate Land Ltd is the development partner of Network Rail and D B Schenker (and through
them Freightliner and Lafarge Tarmac) who own 21.18 hectares of land formerly known as the
Chesterton Sidings and who collectively form the Chesterton Partnership.

1.3 Brookgate Land Limited has been working as promoter for The Chesterton Partnership in order to
secure the rationalisation and redevelopment of the former Chesterton Sidings site. Planning
permission has been granted for a 217 bed hotel (under planning application reference
S/2372/17/FL) and a 90,000 sq ft office (under planning application reference S/4478/17/FL),
referred to as the Phase 1a site. Construction is soon to begin on these two important
permissions which will serve to bring life to the Cambridge North station area and act as a
catalyst for the development of the wider North East Cambridge AAP.

1.4 Brookgate Land Limited are now seeking to bring forward the next phase of development ('Phase
1b') alongside the AAP process which will further build on the momentum created by the Station
development and the hotel and office permissions. A location plan indicating the Phase 1b site is
included at Appendix 1.

1.5 Phase 1b will comprise a residential-led mixed use development providing 1000 PRS homes, a
new specialist maths college and another office building. The intention is to submit a planning
application by the end of 2019. The land interest is wider than Phase 1b and that is included at
Appendix 2.

1.6 Brookgate Land Limited are supportive of the overall vision for the APP but wish to make the
following responses to the relevant questions in the Issues and Options consultation document.

2.0 The North East Cambridge Area Today

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

2.2 Brookgate Land Limited consider that paragraph 4.16 (Odour) requires further clarification and
comment.

2.3 To support the hotel and office applications, Brookgate Land Limited commissioned Arup to
prepare an Odour Assessment Report to assess the odour from the Cambridge Water Recycling
Centre. The Report has been shared with the Councils and is publicly available.

2.4 The Arup 2015 report confirms that the entire Phase 1b site is suitable for residential use. This
was based on Anglian Water's own monitoring data and included an allowance for higher
temperatures in the Summer months to ensure a robust approach.

2.5 The 1.5 ouE/m3 contour line from the Arup report (i.e. whereby residential uses are no longer
likely to be suitable) is shown by a dotted blue line below [attached].

2.6 Since the preparation of the above Arup 2015 Odour Assessment, the Councils have
commissioned their own independent Odour Impact Assessment, as referred to in paragraph
4.16 of the NEC AAP document. This Assessment involved an odour measurement survey which
was conducted at the Water Recycling Centre (WRC) in summer 2017 and the report is dated
October 2018. Despite several requests to be provided with copies of the Assessment by
Brookgate Land Limited as part of on-going discussions regarding the development potential of
the Phase 1b site, the report was only made publicly available on 13 March 2019 when it was
released as part of papers for the 20 March 2019 Joint Development Control Committee meeting.

2.7 The Odour Impact Assessment is due to also be reported to the City Planning Committee on 3
April 2019 and the South Cambridgeshire District Planning Committee on 10 April 2019. The
Odour Impact Assessment is therefore being reported through the committee cycle but is not
being subject to consultation, despite it being recognised as a key technical evidence base
document relevant to the NEC AAP area.

2.8 Brookgate Land Limited therefore object to the lack of opportunity for consultation on the findings
of the Councils Odour Impact Assessment.

3.0 Vision and Strategic Objectives

Vision

Question 5 - Do you agree with the proposed vision for the future of the north east
Cambridge area? If not, what might you change?

3.1 Brookgate Land Ltd supports the proposed vision. The AAP area is the largest brownfield site in
Cambridge and is extremely well served by existing public transport. It therefore has the potential
to transform into a high-quality gateway to the city and act as a catalyst for the regeneration of
the wider area.

3.2 The Cambridge and Peterborough Independent Economic Review (CPIER) was published in
September 2018. One of the key recommendations from the review, at 2.3, is to consider some
densification, particularly in Cambridge, away from the historic centre, and more on the edges, as
and where new development sites comes forward. The CPIER report specifically states that the
east side of Cambridge offers significant scope for housing and commercial development:
"Such development would have the advantage of being close to the principal centres of
employment and the existing rail infrastructure whilst also opening up opportunities for
new transport links to connect the main centres of employment more effectively. Most
significantly, it includes land which has previously been safeguarded for development
and is within the boundaries of the existing urban area so would proving opportunities in
line with the existing spatial strategy.

Objectives

3.3 Question 6 - Do you agree with the overarching objectives? If not, what might you
change?

3.4 Brookgate Land Limited broadly support the proposed overarching objectives.

3.5 Brookgate Land Ltd support proposals to improve pedestrian and cycle links to the surrounding
area, existing residential areas, employment areas, River Cam and Milton Country Park, and to
improve connectively across the Milton Road corridor.

3.6 However Objective 18 should be bolder given that the NEC AAP is the largest brownfield site in
the city and is served by excellent public transport infrastructure. Objective 18 should therefore
require proposals to make optimal and efficient use of the potential of the site given the highly
sustainable nature of the NEC AAP area.


4.0 Place Making

North East Cambridge Indicative Concept Plan

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

4.2 Brookgate Land Limited support the Indicative Concept Plan, particularly in terms of the
opportunity for residential-led mixed use development on land they control. The AAP should
however be clear that the Indicative Concept Plan only refers to a broad arrangement of uses
across the AAP site and is not prescriptive. The Local Authority therefore needs to take a flexible
approach to ensure the AAP can adapt to change.

Creating a Mixed-Use City District

4.3 Question 8 - Do you agree that outside of the existing business areas, the eastern part of
the Cambridge Northern Fringe (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?

4.4 Brookgate Land Limited support the proposal for a higher density mixed use residential led area
on land east of Milton Road. This would facilitate a large number of dwellings to be
accommodated near the station, increased Offices/RD provision with associated increase in job
creation. This represents efficient use of land in a highly sustainable location and creates the
opportunity for people to live close to where they work.

4.5 A higher density of people also helps to form a critical mass and sense of place to support the
range of ancillary retail uses, services and facilities that would come forward alongside the
residential and employment accommodation.

District Identity

4.6 Question 12 - What uses, or activities should be included within the NEC 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?

4.7 The AAP should allow for flexibility for a wide range of supporting uses to come forward. The
uses should include those typically understood as necessary for a fully functioning city or district
within a city.

Creating a healthy community

4.8 Question 13 - Should the AAP require developments in the NEC to apply Healthy Towns
principles?

4.9 Planning policies should aim to achieve healthy, inclusive and safe places. The need to
encourage healthy lifestyles and the use of sustainable transport modes will therefore be key in
any development proposals within the NEC.

4.10 Overarching principles relating to health and wellbeing are therefore welcomed but the AAP
needs to remain flexible in terms of any specific policy requirements in order to be able to
respond to change.

Building Heights and Skyline

4.11 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?

4.12 Brookgate Land Limited support the proposal for clusters of taller buildings around areas of high
accessibility. This permits a development of higher densities and the articulation of nodal points,
vistas and landmark buildings to aid legibility and orientation.

4.13 NEC is bounded by the railway line on the east, the A14 to the north, the Cambridge Science
Park to the west and the suburban Chesterton to the south. The City Centre is some 3.5km from
the site. This physical context presents an opportunity to investigate heights and densities which
might not be supported in other locations in Cambridge: taller buildings would have no impact on
any existing residential properties with regard to sunlight and daylight but could a) release
significant development pressure from the historic core of the City, b) create an opportunity to
define the NE corner of the City with striking buildings visible from the A14, and c) support the
additional uses and amenities that will make this a self-supporting district.

Local movement and connectivity

4.14 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 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 the 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 CNF 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 Increasing 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.

4.15 Brookgate Land Limited are supportive of the above. The emphasis of the movement principles
must be the promotion of non-car and active modes of travel and delivering a highly connected,
and accessible development by walking, cycling and public transport.

4.16 Some form of District Centre also needs to be provided within walking distance of Cambridge
North station to serve commuters.

Crossing the railway line

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

4.18 Yes, additional connectivity would be a positive improvement although there is already a
pedestrian and cycle route to the River Cam Tow Path from the south of the NEC via Moss Bank
and Fen Road, Furthermore, it should be noted that Network Rail would not likely support a
crossing point on land they control.

Milton Road connectivity

4.19 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 the NEC, creating a substantial green/ecological link(s) over the road.

We support the proposals to improve connectively across the Milton Road corridor
particularly for pedestrians and cyclists, and to better integrate the existing Science Park with
the wider NEC area and the Cambridge North railway station. However, we question the
practicalities of 'green bridges' and the associated cost and impact on the viability of the
overall development area. There are a lot of opportunities to enhance green infrastructure in
the NEC area which doesn't require significant infrastructure costs such as a 'green
bridge'. The Thames 'Garden Bridge' project is an example of the spiralling costs associated
with the overall 'green bridge' concept, a project which was cancelled after significant costs
had already been incurred. We support a scheme that improves connectively for
pedestrians and cyclists either by rationalisation of the current complex traffic signals, which
prioritise vehicle movements, or a grade separated footway / cycleway bridge. We consider
this to be a more practical and deliverable approach.

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.

As the response to Q18a) we see this option as prohibitively expensive, and creates a lot of
difficult engineering challenges to overcome. There are numerous accesses off the Milton
Road corridor to the NEC which would require slip roads etc which in themselves will create
a huge visual impact and a barrier to pedestrian and cycle movements. The existing Milton
Road where is joins the A14 grade separated junction is on a significant embankment, in
engineering terms it appears impractical, if not impossible to 'cut and cover' this road
effectively. Rather than a tunnel this option is likely to deliver a very expensive urban
underpass with associated negative visual impacts on the NEC area.

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.

Fully support this. The existing string of signalised junctions is unduly complex and designed to prioritise the predominance of vehicles over pedestrians and cyclists. There are opportunities to significantly alter and rationalise the existing signalised junctions on Milton Road and rebalance pedestrian and cyclist priority through targeted interventions. Further work is required to test these, but the street scene is currently motor vehicle dominated. The corridor is wide and presents opportunities for a rebalancing of priorities and to offer multiple crossing locations (rather than just focussing on a single location).

A reduction in vehicle movements associated with Cambridge Science Park would also
significantly help to improve connectivity across Milton Road between Cambridge North
Station and Cambridge Science Park

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.

A pedestrian / cycle bridge would require long ramps (to provide a max. of 1:20 slopes). This could be constructed on the axis of the Cowley Road cycleway / footway, incorporating the ramps east / west into the Science Park main entrance. This would provide a grade separated bridge which would allow pedestrians and cyclists a direct 'off road' east / west route from the Cambridge North railway station to the NEC and existing Science Park without having to cross any main roads.

A frequent 'shuttle bus', say every 15 minutes, could be provided from Cambridge North railway station to the whole CNF area, using the CGB, Cowley Road and internal NEC roads, encouraging employees of the existing Science Parks and the wider NEC to use the new Cambridge North rather than rely on the current mode of choice, the car.

E Other ways of improving connections (please specify)

Managing car parking and servicing

4.20 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?

Support low car parking proposals for the whole of the NEC site. This is essential for the successful delivery of a sustainable district. These low car parking principles should be applied across the whole of the NEC, including the existing science parks which have very high car parking provision and not surprisingly high car usage at present. A consistent car parking approach is required across all land-uses supported by a range of sustainable infrastructure improvements to enhance access by other modes.

4.21 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?

4.22 Yes. The fundamental reason why the existing area has a very low uptake in non-car modes is the historic high provision of car parking across the NEC. This is a legacy of earlier developments in other times. Although there are very good public transport links, including a main line railway station, and cycle and walking infrastructure to these existing employment areas, there is little incentive to use modes of transport other than the car due to the abundance of car parking and the proximity of the strategic highway network, also the immediate environment around the station is not welcoming This needs to be addressed to provide a balance and sustainable transport strategy for the NEC area as a whole.

4.23 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 essential.

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

The APP must embrace new technologies and new ways of managing places. Yes, support the
centralisation of refuse collection for example.

Car and other motor vehicle storage

4.25 Question 23 - Should development within the north east Cambridge area use car barns for
the storage of vehicles?

4.26 Yes, however there are no periphery development areas that are not accessed directly off Milton
Road so although the concept is supported (as it could remove 'trips' off the highway network)
the practical delivery of this option is questioned. An alternative is the suggested use of the
existing Milton Road Park and Ride site. This site is currently an underutilised piece of existing
infrastructure. We would suggest that this site could deliver a 'car barn' concept, taking vehicles
off the A10 prior to the A10/A14 junction thereby reducing the overall impact of the NEC on this
key part of the highway network. To encourage employees (both existing and future) to use this
facility, shuttle buses could be used to get people from the P&R site to NEC, cycle (and
pedestrian) links could be greatly improved to allow people to park and cycle from the P&R site to
NEC and Cambridge North railway station.

Green Space provision

4.27 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.

We could support this in principle, but it would have to be planned and designed collaboratively to ensure it functioned appropriately for all developments across the district. This may be difficult to do due to the phasing of the development of the district.

Furthermore, Brookgate Land Limited have learnt, through their experiences at CB1, that green spaces at a smaller scale, i.e. pocket parks, are more effective in residential-led schemes to serve the surrounding local community.

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.

We would support this, but it would have to be planned and designed collaboratively
across the district to ensure proper accessibility and connectivity for both utilization by
residents and workers, as well as functionally connected for infrastructure purposes.

C Enhance 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.

We would support this, but it would have to be planned and designed collaboratively
across the district to ensure proper accessibility and connectivity for both utilization by
residents and workers, as well as appropriate connections to the broader network.

D Green fingers to unite both sides of Milton Road and capitalise on the existing
green networks.

We could support this, but it will require a review of specific proposals.

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 the CNF. This would also enhance the setting to the City on this
important approach into the City.

We could support this, but it will require a review of specific proposals. One challenge
with structured landscape edges is that they can tend to act as buffers which separate
parts of a district. Care will need to be taken to ensure that any landscape edges provide
benefits to the visual characteristics of the district without reducing the level of perceived
or actual connectivity across the district.

F Creation of enhanced pedestrian and cycle connectivity to Milton Country Park
and the River Cam corridor
We would support this.


5.0 Transport

Non-Car Access

5.1 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 CNF. What other measures
should be explored to improve access to this area?

● A frequent 'shuttle bus', say a minimum of every 15 minutes, could be provided from
Cambridge North railway station to the whole NEC area, using the CGB, Cowley Road and
internal NEC roads, encouraging employees of the existing Science Parks and the wider
NEC to use the new Cambridge North rather than rely on the current mode of choice, the car.

● Better use of the existing Milton Road Park and Ride site. This site is currently an
underutilised piece of existing infrastructure. We would suggest that this site could deliver a
'car barn' concept, taking vehicles off the A10 prior to the A10/A14 junction thereby reducing
the overall impact of the NEC on this key part of the highway network. To encourage
employees (both existing and future) to use this facility, shuttle buses could be used to get
people from the P&R site to NEC, cycle (and pedestrian) links could be greatly improved to
allow people to park and cycle from the P&R site to NEC and Cambridge North railway
station. This could include improvements to the existing pedestrian only footbridge over the
A10 to allow it to be used by cyclists thereby improving the cycle links between the P&R site
and NEC (via Milton village and Jane Coston Bridge).

● Providing Park and Cycle facilities at Milton Road Park and Ride site.

Car usage in North East Cambridge

5.2 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?

5.3 Yes. The current area has significant historic car parking which does not encourage or assist
with more sustainable transport choices. The NEC area has good public transport connectively,
the CGB, frequent local buses (the Citi 2) and Park and Rides services, a mainline railway station
and good cycle and pedestrian connectively to Cambridge City Centre and the cycle network in
general. The NEC area as a whole can support a low car parking strategy due to the abundance
of other non-car mode options available. There are significant opportunities within the NEC to
further enhance non-car modes of transport and to increase the number of 'internal trips' from
existing / proposed employment areas to existing and proposed residential areas. There are
significant opportunities to build a community where people can live and work, commuting by foot
or bike or public transport within the NEC and surrounding urban area.

5.4 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?

5.5 A highway 'trip budget' approach is considered to be a reasonable as long as it is applied to the
NEC as a whole, both the existing science parks and the currently undeveloped (or
underdeveloped) areas. We would not support a 'trip budget' that restricts vehicle trips for new
development to a level that is not commercially viable (or practical in terms of a based need for vehicle movements) nor would we support a 'trip budget' which restricts the efficient use of this
important and strategic brownfield site, in terms of density of development or the mix of
development uses, residential and commercial.

5.6 We would not support a 'trip budget' approach that does not address the current dominance of
car trips, due to high car parking provision and poor uptake of sustainable modes of transport,
within the existing employment areas within the NEC. For a 'trip budget' approach to be
deliverable, and balanced, and successful in delivering a sustainable development across the
NEC it must address the current imbalance between car parking provision on the existing science
parks and that proposed for new development.

5.7 We support proposals which further improve cycle and walking infrastructure and public transport
services to and within the NEC, which will reduce the need for people to use their cars to access
the NEC.

Car Parking

5.8 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 other measures to improve access by means other than the car)?

5.9 Brookgate Land Ltd support the use of more restrictive car parking standards across the whole
area to reflect the highly sustainable location. Priority should be given to zero or low parking
schemes as maintaining existing parking levels is not acceptable. Priority should also be given to
electric cars and car clubs.

5.10 Transport modelling work will assist in determining the appropriate levels of car parking taking
into account the site accessibility and proposed land-uses.

5.11 Reducing the reliance on car parking in the AAP area employment areas is key to addressing the
current dominance of car use within the existing NEC. This would reduce the impact of the NEC
on the existing highway network and enable the whole area to be developed to its full potential,
and for any 'trip budget' for the NEC to be reasonable, both commercially and practically

Cycle Parking

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

5.13 Yes, high cycle parking is necessary to deliver a truly sustainable development, for both the
existing developed areas and new development proposals.

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

5.15 Yes, cycle parking requires a significant amount of space. High density cycle parking such as
'double stackers' should be the norm for commercial and residential developments in the NEC. It will enable efficient use of land and provide the quantum of cycle parking necessary to deliver a
sustainable development based on low car parking numbers.

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)?

5.16 Yes, convenient and secure cycle park and other facilities such as showers and lockers for cyclist
on commercial developments are supported. Charging points for electric bike should be
considered.

Innovative approaches to Movement

5.17 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?

5.18 The CGB provides a high quality, uncongested corridor through the CNF area, with one crossing
of Milton Road. This corridor has the potential for early delivery of a rapid transport, autonomous
vehicle shuttle between Cambridge North Station, the Science Park and Cambridge Regional
College.

Linking the Station to the Science Park

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

5.20 Yes. The Cambridge North Station is a fantastic facility which is currently underused. Links
between the station and the existing science parks could be significantly improved by a number
of measures:

● A frequent shuttle bus.
● Better pedestrian and cycle connectively across Milton Road.
● Better 'wayfinding' to encourage walking and cycling between the station and existing employment areas (a walk of less than 20 minutes).


6.0 Employment

Types of Employment Space

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

6.2 A combination of commercial and residential uses which are likely to include offices and R & D
uses, should be provided in the NEC area, with the mix being informed by both market conditions
and successful place-making.

6.3 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).

6.4 The policy framework should be flexible to allow for such developments. Bespoke solutions to
maximise economic and employment benefits should therefore be secured as part of individual
applications rather than through a generic and inflexible policy approach.


7.0 Housing

Housing Mix

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

7.2 Brookgate Land Limited would be supportive of a mix of dwelling sizes across the AAP, including
for purpose built private rented sector housing (PRS). This would support the Government's
objective of significantly boosting the supply of homes in ensuring that a sufficient amount and
variety of land can come forward where it is needed and that the needs of groups with specific
housing requirements are addressed.

Affordable Housing

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

7.4 Subject to viability testing, the 40% requirement should be applied to the NEC AAP as a whole.
The very heavy infrastructure costs and brownfield nature of the land with associated remediation
costs must be recognised and viability is of key importance.

7.5 Consideration should however be given to PRS developments where a different approach may
be required, such as discounted market rents, off-site contributions toward affordable housing
provision etc. As such, the NPPG (Paragraph: 004 Reference ID: 60-004-20180913) advises
that if agreement is reached between a developer and a local authority, the affordable housing
requirement could be met by other routes, such as a commuted payment and/or other forms of
affordable housing as defined in the NPPF. The details of this must be set out in the section 106.

Private Rented Sector (PRS) Housing

7.6 Question 44 - Should the AAP include PRS as a potential housing option as part of a wider
housing mix across the north east Cambridge area?

7.7 Yes. There is clear Government support for PRS with Build to Rent now explicitly recognised as a
distinct asset class within the private rented sector and has been defined in the NPPF glossary.

7.8 The cost of homeownership is rising and access to social renting has declined, meaning more
and more people in the UK now rely on PRS housing. In the 80s and 90s, PRS property
represented around 10% of all households in England. However, PRS has since become the
fastest-growing sector in the country, and that figure has doubled.

7.9 The ability of PRS schemes to create quality places to live cannot and should not be doubted, it
is no different to any development in the built environment. It needs a clear brief and good design
and delivery and collaborative working to make it successful architecturally and in urban design
terms.


7.10 PRS provides a means of widening housing choice for tenants, particularly those who may be
renting long term, and also to deliver much needed housing within a faster timescale.

7.11 Many authorities are developing PRS design guides (GLA, Newham) to assist developers. The
authorities may wish to follow a similar route and as part of the AAP produce guidance in
association with the developer but the ULI UK residential council has recently produced "Build to
Rent, a Best Practice Guide", which represents significant time and expertise and a question
must be posed over simply replicating existing guidance.

7.12 The Greater Cambridge Housing Strategy 2019-2023 recognises that PRS models can help
support the needs of those on middle incomes who come to work in the area but cannot afford to
live locally.

7.13 The Strategy states, at page 17 that
"We recognise that PRS can meet the needs of households on a range of incomes, from
those who are unlikely to be considered for social housing for rent to those who can
afford but do not want to own their own home. We also recognise PRS can help
accelerate overall housing build-out rates on large strategic sites. Subject to clear
evidence of need, we may consider proposals for new PRS as part of a wider housing
mix. Any such homes provided should remain available as PRS for an agreed period."

7.14 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?

7.15 Brookgate Land Limited are keen to work with the Council to develop a set of local requirements
to inform the development of a PRS scheme at NEC AAP. An example is Policy H13 of the Draft
New London Plan, an extract of which is below:

● the development, or block or phase within the development has at least 50 units
● the homes are held as Build to Rent under a covenant for at least 10 years
● there is unified ownership and unified management of the development
● there is on-site management, this does not necessarily mean full-time dedicated on-site staff,
but all schemes need to have systems for prompt resolution of issues and some daily on-site
presence
● providers have a complaints procedure in place and are a member of a recognised
ombudsman scheme

7.16 Question 46 - Should PRS provide an affordable housing contribution?

7.17 The NPPG advises that it is expected that developers will usually meet their affordable housing
requirement on build to rent schemes by providing affordable private rent homes. However, if
agreement is reached between a developer and a local authority, this requirement can be met by
other routes, such as a commuted payment and/or other forms of affordable housing as defined
in the National Planning Policy Framework glossary. The details of this must be set out in the
section 106.


7.18 Consideration should therefore be given to PRS developments where a different approach may
be required, such as discounted market rents or off-site contributions toward affordable housing
provision.

7.19 It is clear that the provision of good quality, institution-operated private rented accommodation
meets an identified housing need group, principally for those economically active individuals who
are vital to the Cambridge economy, and contribute massively to the success of its academic and
commercial research and development industries. Many of those working in these sectors do not
qualify for Affordable Housing, and the price of open market housing in the City is for them at an
unaffordable level, a point which has been well made by a number of employers in the area.
Failure to provide accommodation which is affordable to this group risks damaging the status of
Cambridge as one of the UK's fastest growing cities.

7.20 It is nevertheless challenging to build new accommodation specifically for the private rented
sector in the absence of a separate Planning Use Class, meaning that new applications for PRS
accommodation are assessed on the same basis as conventional C3 dwelling house
applications. Some local authorities have recognised that the economics of delivering PRS are very different to conventional housing and recognising the positive contribution to meeting housing need that PRS makes, have provided flexibility on other planning gain requirement, notably affordable housing. The delivery of PRS is linked closely to the City Deal objectives and will considerably add to the additionally argument that the combined authorities will need to demonstrate to access further tranches of monies.

7.21 The Greater Cambridge Housing Strategy 2019-2023 confirms, at paragraph 7.6.2 that recognising the different financial model involved in delivering PRS, consideration may be given to part of the affordable housing requirement on a strategic site being met through provision of Affordable Private Rent as part of a PRS scheme (rents set at least 20% below local market rents).

7.22 The Housing Strategy continues, at paragraph 7.6.2 and 7.6.3, in stating:

"For any new PRS scheme we will seek a range of rent levels to meet a variety of income levels. Rent levels in any scheme would need to be agreed with the relevant council, based on robust evidence around needs and income levels. As a guide, it is considered that 35% of net household income is reasonable to spend on housing costs, including rent and any service charges.

Prior to the review of the local housing needs assessment, as a benchmark for the levelof affordable private rent homes on PRS schemes, the local authorities will seek at least 20%."

7.23 Brookgate Land Limited are keen to work with the Councils to identify ways in which the challenges of delivering good quality private rented accommodation and affordable housing can be met to provide the best economic outcome for Cambridge.

7.24 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?

7.25 Clawbacks mechanism should be used on multi-phased developments only where market conditions may change over the life of the project. Projects with shorter build out programmes should not automatically be subject to claw back arrangements as they greatly affect funding streams.

7.26 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?

7.27 A suitable period would be a maximum of 10 years. No compensation.

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

7.29 The PRS model for Phase 1b is proposed to be owned by an institutional investor rented out through an agent or directly. Lease lengths are generally the same as other privately rented housing, but since the landlord is a professional investor, they are keen to keep tenants in place for the long term. This provides tenants with greater long-term stability.

7.30 The management is undertaken by a professional management company. This PRS property management model gives tenants access to professionally managed property and since the homes are purpose-built for renting, better all-round quality.

7.31 Management will be key to creating a "place" where people want to be. An example to refer to of
a successful PRS scheme is East Village, Stratford. This has a number of on-site leisure, retail and recreation facilities which are managed by a professional management company, together with areas of open space and landscaping. They have a management team on site to manage day to day matters.

Quality and Accessibility of Housing

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

7.33 There is no national requirement for authorities to apply national space standards in their area.
Space standards are optional. However, Brookgate Land Limited are committed to a PRS scheme that would be designed, constructed and managed to a high quality standard.

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

7.35 The AAP should ensure that all dwellings are designed, constructed and managed to a high quality standard. External space standards could apply where the viability of development is not compromised.


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

7.37 The AAP should ensure that all dwellings are designed, constructed and managed to a high quality standard.


8.0 Retail, Leisure and Community Services and
Facilities

8.1 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 on the North East Cambridge area? Are there other important factors we should be considering?

8.2 Yes, in order for the regeneration of the NEC area to be successful the required services and facilities must be provided. This will require collaborative strategies between key stakeholders and will be easier to achieve on sites such as Phase 1b, where large areas can be brought forward by relatively few stakeholders, simplifying the planning and engagement process. The delivery of such services and facilities is essential to ensure the creation of a vibrant, mixed use neighbourhood, as set out in the proposed vision.

Community Facilities

8.3 Question 57 - What community facilities are particularly needed in the NEC?

8.4 A range of community uses should come forward to create a vibrant, mixed use neighbourhood.

Open Space

8.5 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?

8.6 A collaborative effort to produce a network of connected green and open spaces which are accessible to all residents and workers in the district should be facilitated. This would include connections to the broader green network outside the district, as well as providing sport and recreational spaces within the district

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

8.8 Yes, if this is to truly be an urban place, the open space provision should be as efficient as possible and provide access to all residents and workers, and the spaces should be programmed at a district-wide level. Provisions of open space should be evaluated across the district and not on a parcel-by-parcel basis.

8.9 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?

8.10 The open space provision should provide a wide variety of recreational opportunities, but it should not over provide inside the district, nor should it replicate recreational provisions that are easily accessed outside the district for the sake of variety. It needs to be planned in consideration of existing offerings as well as a distributed system across the district.

8.11 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)?

8.12 Yes, as appropriate


9.0 Climate Change and Sustainability

Sustainable design and construction standards

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

9.2 Yes, but the AAP needs to remain flexible in terms of any specific policy requirements in order to be able to respond to change.

Reviewing Sustainability Standards in the future

9.3 Question 64 - Do you support the proposal for the AAP to be clear that review mechanisms should to be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy?

9.4 The development industry needs certainty, certainly at the point it embarks on attaining planning
permission for a new development. It is not reasonable to have a policy position that could shift following the start of that design and planning process. Any advancing sustainable agenda should be clearly set against clear and transparent policy milestones.

Site wide approaches to sustainable design and construction

9.5 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?

9.6 Such matters can often be difficult to provide in practice for many technical or feasibility reasons;
however, there should be an aspirational policy agenda around sustainability.

Smart Technology

9.7 Question 68 - Should the AAP require developments in the area to integrate smart
technologies from the outset?

9.8 As a place to be founded on the Science and Technology section there should be an ambition to
embrace Smart Technologies.

Waste Collection

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

9.10 This would be difficult to retrospectively fit to CSP but would be more viable for new large scale
development.


10.0 Implementation and Delivery

Phasing and Relocations

10.1 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?

10.2 Yes. Refer to our answer to question 78. Land that Brookgate Land Limited control can be developed early without prejudicing the outcome of the AAP process or the achievement of the comprehensive vision for the area as a whole.

Funding & Delivery of infrastructure

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

10.4 No, it is more appropriate for individual s106 which are site specific.

10.5 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

10.6 At the outset, it would appear appropriate for it to be related to the amount of new floorspace
provided against its use class and also based on number of and type of trips.

Joint Working

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

10.8 Yes. Brookgate Land Limited have been committed to joint working with the various landowners
and developers within the NEC since 2014 and continue to remain fully engaged to cooperate.
Specific matters are being discussed through the ongoing Landowner Liaison forums.

Pre-AAP Planning Applications

10.9 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.

10.10 Phase 1b is part of the designation of Policy SS/4 'Cambridge Northern Fringe East and
Cambridge North Railway Station' within the recently adopted South Cambridgeshire Local Plan
(2018). Phase 1b is on the border with Cambridge City Council and is also designated under
Policy 15 'Cambridge Northern Fringe East and new Railway Station Area of Major Change' of the Cambridge City Local Plan (2018).

10.11 Under both policies, the area is allocated for high quality mixed-use development, primarily for
employment uses such as B1, B2 and B8, as well as a range of supporting commercial, retail, leisure and residential uses (subject to acceptable environmental conditions).

10.12 Paragraph 3.31 in the supporting text of Policy SS/4 of the South Cambridgeshire Local Plan
Policy SS/4 states the following:
"Cambridge North railway station will provide a catalyst for regeneration of this area. Early development around Cambridge North station could help create a vibrant area around this key infrastructure to meet the needs of users of the station and bring forward further phased delivery elsewhere within the CNFE area. Planning applications submitted before the adoption of the AAP will be considered on their own merits and subject to ensuring that they would not prejudice the outcome of the AAP process and the achievement of the comprehensive vision for the area as a whole that will be established by the AAP."

10.13 The recently adopted Local Plan therefore makes it clear that planning applications are capable
of being submitted and granted planning permission in advance of the AAP being adopted.

10.14 Brookgate Land Limited are seeking to bring forward Phase 1b a residential-led, mixed use
development providing 1000 PRS accommodation, a new specialist maths college and another office building. The intention is to submit a planning application by the end of 2019.

10.15 The proposed uses would not generate significant peak hour traffic due to both the excellent
public transport accessibility of the site and the nature of the proposed uses. The proposals are to provide a relatively low level of car parking for the residential quarter. This would be supported by a range of measures to promote travel by means other than the car, taking account of the site's excellent accessibility by a range of means of transport along with measures to control parking in the surrounding area. This will significantly reduce potential traffic impacts on the existing highway network.

10.16 Better uptake of more sustainable modes of transport on the existing science park could also
reduce the traffic on the network and improves the position on the A14 junction, as would possible 'car barns' or similar measures.

10.17 The Station Amendments application and associated access roads largely determine the layout
for the Phase 1b site such that, with continued dialogue with Urban Design officers alongside the production of the NEC AAP, this would not prejudice or predetermine the design of the wider NEC AAP area. The Phase 1b proposals are also in accordance with the Indicative Concept Plan included in the NEC AAP and Brookgate Land Limited have undertaken extensive consultation (and will continue to do so) with neighbouring landowners and stakeholders to ensure that shared ambitions can be achieved,

10.18 In summary therefore, the Phase 1b proposals would clearly not prejudice the outcome of the
AAP process or the achievement of the comprehensive vision for the area as a whole.

10.19 The approach in the recently adopted local plan in respect of early submissions should not be
watered down through the AAP process, indeed, through the AAP process the opportunity to bring Brookgate land forward early should be explicitly acknowledged as beneficial to the regeneration of the area, creating a sense of place and arrival around the new Station and evidencing in commercial terms how the low parking ratios might work.

Meanwhile (Temporary) Use

10.20 Question 79: What types of 'meanwhile uses' should the AAP support for the CNF?

10.21 Brookgate Land Ltd is supportive of appropriate meanwhile uses where they add to the vibrancy of the area and are appropriate uses to support the AAP area.

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

10.23 No

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

10.25 Not necessary