Policy 9: Density, heights, scale and massing

Object

Representation ID: 52004

Received: 12/08/2020

Respondent: Miss Fiona Hynd

4-5 storey's could probably work, but you could end up with essentially a tower block estate on the edge of the city. Most of the surrounding area is two storey houses. Population density will be huge in comparison to the rest of the city

Object

Representation ID: 52494

Received: 10/09/2020

Respondent: Ms Yvonne Barr

Although the design provides a range of building heights with the tallest building in the middle of the site, 7-11 storeys is detrimental to the skyline of Cambridge. The range of 7-11 storeys in itself is vague in defining which buildings will be of these heights. This should be explicitly shown. The tallest building in Cambridge is the University Library Tower so placing buildings of potentially 3 storeys higher than this, in the North of Cambridge would set precedent for future developments to do the same. This will have huge impacts on the character of Cambridge. The density can be provided in other ways and should be re-thought.

Comment

Representation ID: 53301

Received: 02/10/2020

Respondent: Old Chesterton Residents' Association

Having lived the first ten years of my married life in a block of flats in Bloomsbury of similar density to what is being proposed for North East Cambridge I cannot support this policy. Such places might be suitable as pieds-a-terre for a transient population but are not suitable places in which to bring up a family. There are some good flat developmenrts in and around Cambridge but they are mostly not affordable to most people.I note the aspiration set out in 'a' to 'h'. My fear is that the opportunity will be exploited and the result could be poor quality design and the result an expensive slum. I hope I will be proved wrong.

Object

Representation ID: 53308

Received: 02/10/2020

Respondent: Mrs Jane Clarke

The density of development is too great for this site on the edge of the city. High rise development is unpopular in this country and is totally inappropriate for a city such as Cambridge which is very low-rise. You are trying to cram the maximum number of units you think you can get away with on to this site and are just creating a slum. I can foresee it will end up as a socially disadvantaged area distant from the rest of the city. I can't imagine anyone would want to live in close proximity to industrial units let alone on top of them. If this were to be similar to Orchard Park it might just about work. The open space is laughable for this density of development. Go back to the drawing board and start again. In the current time of Covid no-one wants to live in this sort of area. It looks like inner London with none of the advantages of being in the capital.

Comment

Representation ID: 53425

Received: 03/10/2020

Respondent: Fen Ditton Village Society

Totally inappropriate – will detract from beauty of Cambridge and surrounding flat fenland landscape
What guarantees are there that all developers will not opt for 13 storey, high density to maximise profit?
Variance from Local Plan – why this variance is important enough to be allowed is not explained.
Highest density and thereby highest buildings congregated at one site (Cowley Road) leading to lack of “community”

Object

Representation ID: 53477

Received: 03/10/2020

Respondent: Mrs Laurie Woolfenden

Totally inappropriate – will detract from beauty of Cambridge and surrounding flat fenland landscape
What guarantees are there that all developers will not opt for 13 storey, high density to maximise profit?
Variance from Local Plan – why this variance is important enough to be allowed is not explained.
Highest density and thereby highest buildings congregated at one site (Cowley Road) leading to lack of “community”

Comment

Representation ID: 54082

Received: 04/10/2020

Respondent: Mrs Anne Wildman

The assumption seems to be that the apartments will be in blocks, what about graduated shapes if you have to make the building so high? Sorry I know I have seen examples of this kind of urban building in both Copenhagen and Holland but can't recall where. If you look at the buildings in Hammarby Sjöstad, they are 'blocky' but have outdoor space in good sized balconies, breaking up the outline. And there is a lot of variety in the buildings.
The current height of buildings is not reflected in current Cambridge buildings. There is a great opportunity to do something other than what has been done in recent urban building around Cambridge (CB1, Eddington, Addenbrookes etc). They are very bland and quite honestly, not somewhere anyone I know would like to live. Where is the individuality and flair that you often see in new urban building in other countries? There is a wonderful opportunity that seems to be being squandered here and it could make a great place to live. But not high density blocks!

Object

Representation ID: 54087

Received: 04/10/2020

Respondent: Mrs Anne Wildman

I have already outlined my reasons for commenting but don't seem to be able to move on to the next section.

However I have just read your response to previous comments but can't see how you have accommodated the concerns for building heights by responding with comparisons to buildings a considerable distance from the proposed development. Your plans are still too overwhelming in terms of height.

Comment

Representation ID: 54095

Received: 04/10/2020

Respondent: Mr Seb Dangerfield

Cambridge city centre currently is quite low and whilst several buildings have tall spires and towers I think most are only 3 - 4 stories. Having upto 13 stories in an area outside of the centre will be very confusing as generally it's now considered a city should get denser and generally taller towards the centre then reduce in density and height as you go further out, however the heights proposed here would go against that and potentially create a "new centre" and "old/historic centre".

Comment

Representation ID: 54502

Received: 05/10/2020

Respondent: Cambridge Cycling Campaign

Camcycle supports plans to ensure that development proposals create a well-articulated and varied skyline which is pleasant and attractive to travel through at street level on foot or by cycle, and contributes to making a place that is easy to find your way around. We also support the mixed-use nature of the area and individual buildings which will help ensure that people have the opportunity to make everyday journeys without driving and that the district’s walking and cycling routes have good levels of natural surveillance at all times of the day and night.

We note that the high densities in the eastern part of the site seem to have been made necessary by the restrictions made on land-use in the western part of the site. This puts pressure on the public realm; for example cycleways are unlikely to be built wider than the 2.5m minimum, even where volumes of cycle traffic would require it, and green space is more limited than it should be. Choices should never be made between pavements, cycleways and green space: these should be the aspects the site is built around and the whole area should be as mixed-use as possible to make cycling and walking the natural choice for all short journeys. Density should be determined by factors such as liveability and local typology rather than external pressures which could lead to overdevelopment of the land.

Object

Representation ID: 55621

Received: 29/09/2020

Respondent: Historic England

Density, heights, scale and massing
We continue to express our significant concerns regarding the current proposed heights and densities for North East Cambridge. We reiterate the importance of thoroughly testing this approach with respect to impact on heritage assets, the historic environment and the wider setting of the city.
We understand that you are commissioning some further work to explore this aspect in more detail which we very much welcome. However, it will be important that this work truly shapes your proposals and that you respond to that, rather than merely justifying a particular approach. It is important that you explore other ways to increase densities rather than simply through height.
The comparative height examples are really helpful in illustrating what might be proposed (as indeed the comparison green space figures were also very useful). Of course, it is not just height, but also massing, that will be critical.
We welcome the requirement in the policy for proposals to include appropriate landscape and visual assessment as well as heritage impact assessment and massing studies, together with the wider skyline and heritage assets. We welcome the specific reference in the policy to Fen Ditton Conservation Area and other heritage assets.
Suggested Change:
We look forward to continuing to work with you regarding densities, heights, scale and massing on this site. We look forward to seeing the report that you are commissioning in this regard.

Object

Representation ID: 55673

Received: 02/10/2020

Respondent: St John's College

Agent: Savills

The expectation in the policy that the overall approach to building densities, heights, scale and massing for all development proposals at North East Cambridge will create a well-articulated and varied skyline throughout the area is roundly supported. It is also agreed that the impact of new development on the historic and wider skyline and their relationships with the surrounding context, the setting of Cambridge and Fen Edge approaches should be carefully assessed and considered through appropriate landscape and visual impact assessment, heritage impact assessment and massing studies.

An approach where storey heights are generally greatest towards the centre of the area is sensible also, but landmark buildings in other key locations should not be discouraged (provided site specific assessments demonstrate that they can be satisfactorily accommodated on the site in terms of landscape and townscape effects). The LCVIA which seemingly informed the AAP did not consider some taller buildings within areas and also only considered 3 scenarios – the majority of buildings being up to 6 storeys/18 metres, 9 storeys/27 metres and 12 storeys/36 metres i.e. incremental increases of 3 storeys/9 metres each. None of the scenarios considered buildings above 6 storeys/18 metres towards the northern extent of the area. A more nuanced assessment would support some taller buildings on parts of the site. The LVA submitted as part of applications 20/03523/FUL (South Cambs) and 20/03524/FUL (Cambridge City) for example demonstrates that some buildings taller than the maximum heights in metres shown on the plan on pages 18 and 103 can be satisfactorily accommodated on the site in terms of landscape and townscape effects. It may be the intention that some taller buildings are appropriate where justified by the inclusion of “Localised increases in height should be located to help define key centres of activity within the area and help with wayfinding” in Policy 9, but reference to the maximum heights in the Policy makes this unclear.

In addition to its content, the presentation of Policy 9 should also be reviewed. This is an example of where plans are currently too prescriptive, and a ‘heatwave’ approach would be more appropriate. The supporting text also states that Figure 21 is based on an assumed floor to floor height for residential use of 3m. Commercial buildings in particular will often though have a storey height of more than 3m. As currently presented this gives rise to the potential for ambiguity. Referring back to applications 20/03523/FUL (South Cambs) and 20/03524/FUL (Cambridge City), one of the proposed buildings is 5-storeys and 23.3 metres high. This highlights an ambiguity with Figure 21 as currently presented in that it is not higher than the 4-5 storeys typical height – there is no reference to 3m storeys in the policy – but is higher than the 18 metres maximum height.

Object

Representation ID: 55742

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 9 sets out expected building heights and densities across the area and how
the scale and massing (shape) of buildings should consider its impact on the
skyline.
To understand the potential impact of development, the Councils have undertaken
a Landscape Character and Visual Impact Appraisal to inform Policy 9 but are also
commissioning a Heritage Impact and Townscape Assessment to inform a wider
Townscape Strategy for North East Cambridge.
Policy 9 states that ‘development densities and building heights should not exceed
those identified on Figure 21 and Figure 23. Densities and intensification of
appropriate uses will increase around highly accessible parts of the Area Action
Plan area taking into account wider development sensitives, and activity clusters
such as the District Centre and Cambridge North Station.’
Brookgate object to Policy 9 in that the Policy is overly restrictive in stating that
building heights ‘should not exceed’ those identified on Figure 21. 4-5 or 5-6 typical
building height in an area around an existing station and public transport
interchange is particularly low. Figure 21 also fails to take account of the building
heights of the consented hotel and office adjacent to the station (both 7 storeys).
Both of these detailed applications demonstrated through detailed technical
evidence the acceptability of 7 storeys in this location.
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Furthermore, the maximum heights proposed in Figure 21 are assuming a
residential storey height as opposed to an office typical level and do not appear to
allow sufficient additional ground floor height for active frontage and alternative
uses. It should also be noted that office storey heights have recently increased to
be in line with developing national space standards and therefore they may be a
small increase when comparing to existing precedents.
Setting overly restrictive maximum height limits in certain locations and without the
proper consideration of the wider planning potential of development sites and wider
implications of not maximising those opportunities (by displacing development to
other locations that may not be best placed to accommodate it) is a risk to the
current approach set out in the NEC AAP. Such a displacement effect presents a
lost opportunity in key urban areas of high demand for new accommodation,
whether that is for living, working, leisure or other requirements in the built
environment.
With particular reference to Cambridge North, the Site is bounded by the railway
line to 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;
● Make optimal and efficient use of the capacity of the site and release
significant development pressure from the historic core of the City;
● Optimise the effectiveness of substantial investment in public transport
infrastructure and mobility corridors in terms of improved and more sustainable
mobility choices and enhanced opportunities and choices in access to housing,
jobs, community and social infrastructure;
● Create an opportunity to define the north east corner of the City with striking
buildings visible from the A14;
● Support the additional uses and amenities that will make this a selfsupporting
district; and
● Assist in reinforcing and contributing to a sense of place, such as indicating
the main centres of activity, important street junctions, public spaces and transport
interchanges. In this manner increased building height is a key factor in assisting
modern placemaking and improving the overall quality of our urban environments.
The NPPF confirms, at paragraph 118, that planning policies should “give
substantial weight to the value of using suitable brownfield land within settlements
for homes and other identified needs” and “promote and support the development
of under-utilised land and buildings”. The NPPF continues, at paragraph 112, in
advising that planning policies should support development that makes efficient use
of land, taking into account, inter alia, the identified need for different types of
housing and other forms of development, and the availability of land suitable for
accommodating it.
The NEC AAP is the largest brownfield site in Cambridge and is served by
excellent public transport infrastructure. It therefore presents a significant
opportunity to transform into a high-quality gateway to the city and act as a catalyst
for the regeneration of the wider area. Opportunities for densification of existing
urban areas in locations well served by public transport should therefore be
maximised wherever possible.
The tax payer, through the construction of the Station and the relocation of the
water treatment works, will contribute over £300M towards the regeneration of the
area. It is therefore imperative that a proper return is achieved on this massive
investment in the area and if the Mayor’s CAM comes to fruition, further tax payers
monies will be secured.
A high density development would represent efficient use of land in a sustainable
location and create the opportunity for people to live close to where they work. 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.
The need for densification in urban parts of Cambridge and adjoining transport
hubs is also supported by the Cambridge and Peterborough Independent
Economic Review (CPIER), 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.”

Comment

Representation ID: 55847

Received: 05/10/2020

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Figure 21 shows building heights for the proposed business space (B1) and housing at the Veolia
site off Cowley Road of between 5 to 6 storeys and a maximum of 8 storeys. The proposed uses on the
neighbouring areas also include tall buildings.

The proposed uses and the building heights for the Veolia site are supported, and these higher
value uses are necessary to enable the existing waste recycling transfer facility to be relocated
off site, otherwise relocation would not be viable.

In addition, the phasing of redevelopment will be important in order to ensure that tall buildings
are compatible with existing uses e.g. waste recycling transfer facility such like Veolia that
might remain in operation if an alternative site is not identified. It is unlikely that effective
temporary noise mitigation measures could be provided within the proposed residential buildings to
address
the noise generated by activities associated with the existing waste recycling transfer facility.

Support

Representation ID: 55903

Received: 02/10/2020

Respondent: GCR Camprop Nine Ltd

Agent: Carter Jonas

Figure 21 shows proposed building heights for Cambridge Science Park of 4 to 5 storeys with a maximum of 6 storeys. The existing building at 127-136 Cambridge Science Park is a single storey building. The current planning application for the redevelopment of the site would provide a building of 5 storeys in height, which would be consistent with the building heights specified in Policy 9 and Figure 21.

Comment

Representation ID: 55925

Received: 05/10/2020

Respondent: Ridgeons Timber & Builders Merchants and Turnstone Estates

Agent: Carter Jonas

Figure 21 shows building heights for the proposed residential development at Nuffield Road
Industrial Estate (including the Ridgeons site) of 4 to 5 storeys and a maximum of 6 storeys..
Policy 9 defines criteria for the density, height, scale and massing of proposed buildings in the
North East Cambridge area. However, there is no reference in the criteria to the relationship
between taller buildings and existing uses. This needs to be considered further, however it is
relevant to note that at present there are residential uses present in close proximity to the site.

If Ridgeons are able to viably relocate its existing builders merchant operations as part of
delivery of the AAP then the redevelopment of the site for residential development of between 4 and 6
storeys in height is supported.

Support

Representation ID: 55970

Received: 05/10/2020

Respondent: Hawkswren Ltd

Agent: Carter Jonas

Figure 21 shows proposed building heights and Figure 23 shows proposed densities for the
different development parcels within the AAP area. The development parcel that includes the
Barr Tech site indicates building heights of 4 to 5 storeys and a maximum of 6 storeys, and a
density of 225 dwellings per hectare. In contrast the adjacent development parcels show taller
building heights and higher densities, but there is no evidence provided to explain the differing
building heights or densities. For example, the development parcels to the west, north and south
show building heights of between 5 to 6 storeys and 6 to 8 storeys (maximums of 8 to 10 storeys)
and densities of between 260 and 300 dwellings per hectare. It is requested that the building
heights and densities for the development parcel that includes the Barr Tech site are increased to
be consistent with adjacent parcels; a building height of 6 to 8 storeys and a density of 300
dwellings per hectare would be appropriate. The development parcel that includes the Barr Tech
site is located within close proximity to a proposed mobility hub, it would be accessible by
walking, cycling and public transport including Cambridge Guided Busway and Cambridge North
Station, and it would be well related to the proposed District Centre. The location and future
accessibility of the Barr Tech site supports additional development at this parcel in the form of
taller buildings.

Object

Representation ID: 55995

Received: 05/10/2020

Respondent: Turnstone Estates Limited

Agent: Carter Jonas

Figure 21 shows proposed building heights and Figure 23 shows proposed densities for the
different development parcels within the AAP area. The development parcel that includes the
Tarmac site indicates building heights of 4 to 5 storeys and a maximum of 6 storeys, and a
density of 225 dwellings per hectare. In contrast the adjacent development parcels show taller
building heights and higher densities, but there is no evidence provided to explain the differing
building heights or densities. For example, the development parcels to the west, north and south
show building heights of between 5 to 6 storeys and 6 to 8 storeys (with maximum building
heights of 8 to 10 storeys) and densities of between 260 and 300 dwellings per hectare.
It is requested that the building heights and densities for the development parcel that includes the
Tarmac site are increased to be consistent with adjacent parcels; a building height of 6 to 8
storeys and a density of 300 dwellings per hectare would be appropriate. The development
parcel that includes the Tarmac site is located within close proximity to a proposed mobility hub, it
would be accessible by walking, cycling and public transport including Cambridge Guided
Busway and Cambridge North Station, and it would be well related to the proposed District
Centre. The location and future accessibility of the Tarmac site supports additional development
at this parcel in the form of taller buildings.

Object

Representation ID: 56019

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Barton Willmore

The Draft Policy states that “development densities and building heights should not exceed those identified on Figure 21 and Figure 23”. Figure 21 (Building Heights) shows development across the site ranging from building heights of between 4-5 and 13 storeys. Figure 23 (Residential Densities) provides the corresponding residential densities map, showing densities of between 75 and 385 dwellings per hectare (Figure 21/23 see submission attachment)
Draft Policy 9 clearly indicates that the heights and densities shown on the maps represent upper limits for development across NEC. Whilst we welcome the identification of these figures as maximums, we are of the view that the building heights and densities remain too great when considering the location of NEC Action Area within the historic city of Cambridge; the existing site constraints; and the proposed mix of uses.

This said, we recognise that the heights and densities proposed are necessitated by the high quantum of development that Draft Policy 1 seeks to allocate to the Action Area (see separate comments to Policy 1, above). Our representation to Draft Policy 9 therefore corresponds closely with our representation to Draft Policy 1.

Compared with strategic sites such as Cambourne, Northstowe and Waterbeach, the scale of residential development proposed in NEC involves building at residential densities that are unprecedented in the Cambridge area.

The NEC Typologies Study and Development Capacity Assessment (January 2020) provides a range of example developments at high density. However, we note that none of these include developments of circa 8,000 dwellings except for Hammarby Sjostad in Stockholm (9,000 units at 145 dph). Whilst there are examples in Cambridge and London of high-quality, high-density development, it typically comprises a smaller total quantum of development, e.g. CB1 Ceres in Cambridge (150 units at 300dph), S3 in Eddington, Cambridge (186 units at 261 dph) and Aylesbury Estate in London (260 units at 244dph). We are concerned that the high-density residential development proposed at NEC will not be in keeping with the site and surrounding area, including landscape and visual impacts on the local and wider cityscape.

Table 5 of the NEC Retail Evidence Statement (February 2020) sets out the proposed residential mix for the NEC Area (see below). This indicates a total 8,400 dwellings, of which 92% will be flats and 8% will be 3 and 4-bedroom houses. Of all dwellings, 70% comprises of 1 and 2-bed flats. This housing mix will generate an estimated total population of around 19,400 people (Retail Evidence Statement, paragraph 54).
(Table 5 See submission attachment)
We would question whether the proposed dwelling mix has been determined by a comprehensive analysis of population projections and housing need for the area – or whether the high proportion of small flats is necessary in order to achieve the high numbers and densities that are proposed.

With the anticipated permanent changes to our day to day living as a result of the Coronavirus Pandemic, we believe that there should be a reconsideration of the policy approach in relation to residential mix. In terms of preference, there has been a clear move towards people seeking more space within their homes, both internally to facilitate home-working and externally in terms of private garden space. We are concerned that the housing market in Cambridge may not support the level of apartment development that is currently proposed within the Draft AAP. Whilst this impacts the parameters set out in Draft Policy 9, this also has a knock-on effect on Draft Policy 1. We consider that a reassessment of this policy approach is required to ensure the long term viability of the project.

Again, the above raises the of question whether the quantum of 8,000+ units and other proposed employment, commercial and community uses and associated policy objectives is too much for the NEC Action Area.

Comment

Representation ID: 56093

Received: 02/10/2020

Respondent: South Cambridgeshire District Council

Agent: Carter Jonas

The statement in the policy ‘Development densities and building heights should not exceed those
identified on Figure 21 and Figure 23’ does not provide sufficient flexibility for a detailed
planning application process – there might be exceptional circumstances that support a taller
building beyond the heights specified, and policy should be written in a more positive manner i.e.
simply inserting ‘unless exceptional circumstances can be demonstrated’.

We would like to query why the plan takes a more cautious approach to heights than is recommended
in the LCVIA. For the area in which Building 140 is positioned, the LCVIA recommends ‘up to 6
storeys – 18m’ and we think the plan in question 6 might follow this approach and simply state ‘up
to 6 storeys’ rather than ‘typically 4 – 5 storeys, maximum 6 storeys’. This change in reference
would make it clear what the general upper height parameter should be (rather than the current
format which implies that only in special and limited circumstances will 6 storeys be deemed
acceptable), thereby creating a positively-worded policy
that will help optimise economic development across the CSP.

Comment

Representation ID: 56110

Received: 02/10/2020

Respondent: South Cambridgeshire District Council

Agent: Carter Jonas

The statement in the policy ‘Development densities and building heights should not exceed those
identified on Figure 21 and Figure 23’ does not provide sufficient flexibility for a detailed planning application process – there might be exceptional circumstances that support a taller building
beyond the heights specified, and policy should be written in a more positive manner i.e. simply
inserting ‘unless exceptional circumstances can be demonstrated’.

We would like to query why the plan takes a more cautious approach to heights than is recommended
in the ‘Landscape Character and Visual Impact Appraisal January 2020’ (‘LCVIA’). For the area in
which Buildings 270 and 296 are positioned, the LCVIA recommends ‘up to 6 storeys – 18m’ and we
think the plan in question 6 might follow this approach and simply state ‘up to 6 storeys’ rather
than ‘typically 4 – 5 storeys, maximum 6 storeys’. This would then step- down to 4 storeys on the
Site’s edge near the A14, as recommended. This change in reference would make it clear what the
general upper height parameter should be (rather than the current format which implies that only in
special and limited circumstances will 6 storeys be deemed acceptable), thereby creating a
positively-worded policy that will help optimise economic
development across the CSP.

Comment

Representation ID: 56126

Received: 02/10/2020

Respondent: South Cambridgeshire District Council

Agent: Carter Jonas

The statement in the policy ‘Development densities and building heights should not exceed those
identified on Figure 21 and Figure 23’ does not provide sufficient flexibility for a detailed
planning application process – there might be exceptional circumstances that support a taller
building beyond the heights specified, and policy should be written in a more positive manner i.e.
simply inserting ‘unless exceptional circumstances can be demonstrated’.

We would like to query why the plan takes a more cautious approach to heights than is recommended
in the LCVIA. For the area in which Vitrum is positioned, the LCVIA recommends ‘up to 6 storeys –
18m’ and we think the plan in question 6 might follow this approach and simply state ‘up to 6
storeys’ rather than ‘typically 4 – 5 storeys, maximum 6 storeys’. This change in reference would
make it clear what the general upper height parameter should be (rather than the current format
which implies that only in special and limited circumstances will 6 storeys be deemed acceptable),
thereby creating a positively-worded policy that will help optimise economic development across the SJIP.

Comment

Representation ID: 56143

Received: 05/10/2020

Respondent: U+I PLC.

Agent: We are Town

Continued concerns about provisions with regard to density, heights, scale and massing. The prescriptive format of the
diagrams is not underpinned by density studies and risks creating obstacles in the delivery of a compliant scheme.
Ongoing concerns over incompatibility of block structure shown with our emerging masterplan.
Page 105 - A quick analysis by Urbed of the residential densities set out in the draft suggests a maximum capacity using
the AAP figures of 12,167 units (see Appendix 4). The approach should be reconfigured as ‘heat maps’, less definitive and feature minimum densities to be achieved. This is one demonstration of our concerns over the diagrams and how they
might be read in a ‘binary’ rather than more nuanced way.
Height restriction of six storeys adjacent to A14 – may be overly restrictive and should be reviewed in line with emerging
acoustic strategy in due course.