Draft Greater Cambridge Local Plan for consultation

Object

Representation ID: 210171

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Historic England is supportive of renewable energy development and supports the inclusion of a policy for renewable energy.
Our advice note Commercial Renewable Energy Development Historic Environment Advice Note 15 provides further advice on Local Plans and renewable energy including site selection and development of policies and maps in plans.
We note that you have commissioned a Landscape Assessment – Part 2 Renewable Energy Development Assessment as part of the evidence base for the Local Plan. We note that this evidence has been used for the development of maps for solar and wind turbines which have then been used on the policies map.
The assessment is mainly landscape focussed and does not appear to give detailed consideration to the historic environment (though there are some mentions of heritage e.g. church spires but more in relation to the wider landscape).
Recognising the challenges in preparing a detailed and thorough assessment of heritage at a strategic scale, we consider that the mapping represents a helpful starting point, although there are some limitations. However, given the limitations of the mapping it is very important that the plan includes suitable strong caveats to help explain these limitations and also to set out what further heritage assessment will be needed at planning application stage.
This needs to be set out in robust policy criteria and in supporting text which is also reflected in the key to the policies map. We welcome references to heritage in the policy. However, we suggest a number of changes to wording to ensure that the policy and supporting text and policies map key is clearer and more robust.
1e we welcome the reference to the historic environment and the setting of heritage assets. The Policy should also include reference to the need for detailed heritage impact assessment.
Parts of the policy refer to a zooming study – whilst others refer to zoning – we assume the latter?
Paragraph 4.51 After (LVIA) add ‘…and Heritage Impact Assessment (HIA)’
Paragraph 4.56 We welcome the reference to heritage in this paragraph. The following wording must also be added: When identifying and considering impacts on heritage assets and / or their settings special regard will be had to the desirability of protecting and enhancing the significance of such assets. A detailed heritage impact assessment will be required during the planning application process for each site to consider all designated and non-designated heritage assets and their settings. Applications should include visualisations showing the relationship to heritage assets and settings. Viewpoints should be agreed in consultation with interested parties.
Reference to the need for further site-specific assessment of proposals should be included on the key for the proposals map.

Object

Representation ID: 210172

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We welcome the reference to a context led approach and also the reference to heritage assets.
Reference should also be made to gentle densification.

Object

Representation ID: 210173

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Historic England is keen to support growth in appropriate locations whilst protecting and enhancing what is important in relation to the skyline of the City and surrounding area. Cambridge is set within a low-lying landscape. Much of the city is hidden within a well treed skyline, punctuated by a few landmark buildings. Many (particularly in the historic core) are also highly graded heritage assets and well-known features on the skyline. Maintaining the settings of these heritage assets, including how they sit within the skyline, particularly from key views in and out of the City, will be important.
Within the wider area, we are seeking to ensure that the rural character of the area is maintained and that even within the new settlements, buildings do not over-dominate the wider landscape and have a negative impact on the historic environment. The relatively flat nature of the area means that impacts can be felt over considerable distances.
We welcome the inclusion of a policy for tall buildings and the skyline. We welcome the detailed evidence base that has been prepared in the form of the Skyline and Tall Buildings Baseline, Strategy and Guidance.
Policy and Supporting Text
We note that the policy wording itself is very similar to the previous Local Plan, albeit with greater emphasis on design quality and the addition of a further criterion relation to suicide prevention.
We welcome the reference to the historic environment in criterion b.
There are however some minor changes to wording that would be helpful.
Appendix H/I Sometimes this is referred to as Appendix H and sometimes I.
Appendix H
Para 2.1 add reference to historic environment ‘..important views, historic environment, the wider townscape…’
Section 5 seeks to define what is meant by tall buildings in the Cambridge context. This is a more nuanced definition than the former local plan, not least given that the policy now covers the rural area of South Cambridgeshire as well. We continue to have some concerns about the context heights identified and also the threshold heights.
In relation to context heights, it is important that the average context heights are sense checked and that they are nuanced enough to pick out for example areas which may be considerably lower than the surround context height.
Furthermore, just because an existing context height is a particular height, does not automatically mean that future development of a similar height or just a storey more may be acceptable, nor does it remove the need for assessment against the tall buildings policy.
These caveats should be set out clearly within the policy/supporting text/Appendix.
7.3 Figure 8 showing the key viewpoints should also be included in the Appendix.
8.1 It would be helpful if the views were given distinct numbering. At the moment there are several views identified as a.
We welcome the reference to dynamic views.
12.6 After heritage assets this should include heritage assets (listed building, scheduled monument, conservation area, registered historic park and garden and non-designated heritage assets, including but not limited to buildings of local interest)
This section should also refer to the Cambridge Historic Core Appraisal and Conservation Area Appraisals.
Process and Technical Requirements
Heritage Impact Assessment
Criterion 1 needs to be reworded to read:
Any application that results in potential harm to the significance of heritage assets, including the contribution made by its setting ((listed building, scheduled monument, conservation area, registered historic park and garden and non-designated heritage assets, including but not limited to buildings of local interest) needs to be accompanied by a separate heritage impact assessment.
Criterion 2 We welcome the reference our advice note 3. We recommend including the hyperlink The Setting of Heritage Assets | Historic England This criterion should also include reference to Tall Buildings: Historic England Advice Note 4
We welcome the reference to digital assessment techniques.
Skyline and Tall Buildings Strategy – See also our comments in our letter.
We welcome the detailed work that has been undertaken to prepare an evidence base in the form of the Skyline and Tall Buildings Baseline, Strategy and Guidance (although the detail is, at times, hard to follow – we recommend an executive summary is prepared to draw out the main points).
We remain concerned that the approach using context height and thresholds may lead to an ever-increasing roof height and flattening of the skyline to the upper limit, thus harming the overall gentle, treed skyline that currently exists within the city.
Similarly, we are concerned that a blanket threshold of 3 storeys for rural villages is inappropriate Whilst there may be scope for buildings of greater height at village centres, this may not be appropriate at the village edges or in areas with for example heritage sensitivities.
Finally, we note that the tall buildings strategy identifies areas of search for taller buildings and for clusters of tall buildings. We have some reservations about the strategy in this area and some of the assumptions made. We would be keen to discuss this matter further with you and also to ensure that the appropriate height parameters are in place for specific site allocations.
There also need to be strong clear caveats (in the Plan policy, supporting text, appendix and strategy) stating the need for proposals to be considered on a case-by-case basis. There must also be a clearer statement in both the Local Plan and also the Tall Buildings Strategy that the heights explored within the evidence base would need to be tested on a case-by-case for site-specific proposals and that the STBS is only one of a number of factors to be considered in determining the most suitable design and heights for a particular site.
We want to be able to support you in delivering much needed housing and growth in the city. In order to do so it would be helpful to discuss the evidence base. We would therefore welcome discussion with GCSP prior to regulation 19 to better understand the Strategy, how it was developed and its conclusions. This will help to clarify the extent of our concerns and to explore with you how they might be addressed.

Object

Representation ID: 210174

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Historic England welcomes this policy.
We welcome the positive strategy for the historic environment as set out here and elsewhere in the Plan.
We welcome the requirement for Heritage Impact Assessments. Although these are often known as Heritage Statements at Application stage.
We recommend adding more about the importance of heritage in place-making, quality of life and well-being as well as being a key economic driver as well as the importance of protecting and enhancing heritage because of this.
We recommend adding text that that recognises the growing pressures on heritage of a rapidly growing population. We recommend including in the strategy something about seeking to enhance existing provision and create greater access to other heritage assets to spread the impact on heritage destinations. This might include specific encouragement of other heritage/nature base areas to open up to visitors.

Object

Representation ID: 210175

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Criterion 1 sets an inappropriate tone. The clear overriding message should be that harm should be avoided in the first instance. We recommend that you amend criterion 1 to make it clear that harm should be avoided in the first instance.
Criterion 4 We welcome the reference to heritage at risk.
In relation to Heritage at Risk (HAR), does the Plan include any site allocations containing HAR or near to HAR? If so, the associated policies should reference their HAR status and encourage positive solutions/identify opportunities for their conservation and enhancement. We recommend that you check the HAR register and amend any site allocations accordingly.
Criterion 5 should be deleted. By definition, within the NPPF, enabling development is development that is not otherwise in accordance with adopted policy. We are therefore of the view that a policy on enabling development is not a necessary component of a local plan document and so should be deleted. A local plan should adequately set out a positive strategy for the historic environment without the need to include such a policy.
Paragraph 7.62could be much clearer in relation to the definition of designated heritage assets. Put simply, designated heritage assets are Listed Buildings, Conservation Areas, Registered Parks and Gardens and Scheduled Monument. We advise that you should amend the paragraph accordingly.
Paragraph 7.70 – 7.72 We recommend that these paragraphs should be removed for the reasons set out above.

Object

Representation ID: 210176

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We welcome the inclusion of a policy on non-designated heritage assets.
Paragraph 7.76 We recommend including a link to the criteria Criteria - Cambridgeshire's Local Heritage List in paragraph Paragraph 7.76 The final bullet point – it should be noted that not all entries on the HER are Non-designated heritage assets. A planning judgement (by a ‘plan-making body’) is needed to determine whether or not something is a non-designated heritage asset. Inclusion on the HER alone is not sufficient. Please refer to this in this paragraph.
Paragraph 7.78 We welcome the inclusion of links through to the Cambridgeshire Local Heritage List Portal.
Paragraph 7.79 This paragraph should make it clear that other ways that non-designated heritage assets may be identified are through:
•
Local Plans
•
Neighbourhood Plans
•
Conservation area appraisals and reviews
•
Decision-making on planning applications

Object

Representation ID: 210177

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We welcome reference to heritage assets in this policy.
We recommend that the policy should highlight the need to take a whole building approach.
We welcome the various hyperlinks to publications. We also recommend including the following link: Energy Efficiency and Retrofit in Historic Buildings | Historic England

Object

Representation ID: 210178

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The policy should reference the importance of archaeological assessment informing planning proposals including masterplans.
The policy should provide clearer guidance on the appropriate timing of archaeological assessment.

Object

Representation ID: 210179

Received: 29/01/2026

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We welcome the reference to historic shopfronts in this policy. The policy could go further and encourage the restoration and reinstatement of historic shopfronts. This is both in terms of the positive contribution historic shopfronts make to the character of an area, but also the economic benefit of providing traditional and bespoke shopping units to shop owners.
Our recent High Street Heritage Action Zones across the country are unlocking the potential of high streets, fuelling economic, social and cultural recovery and breathe new life into it for future generations. The Policy should make more reference the role of heritage in the re-vitalisation of retail areas. See our Heritage Led Regeneration Toolkit | Historic England for further suggestions

Support

Representation ID: 210180

Received: 29/01/2026

Respondent: Historic England

We welcome criterion 1g.