Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Policy S/C/GER: Former Garage Block, East Road
Representation ID: 213923
Received: 24/09/2026
Respondent: Historic England
Whilst there are no designated heritage assets within the site, the site lies close to the Mill Road Conservation
Area and St Matthews Church (Grade II listed). We welcome the preparation of the HIA. We welcome the changes made to the policy wording.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/SH: 1-33 Stanton House, Christchurch Street
Representation ID: 213924
Received: 24/09/2026
Respondent: Historic England
Whilst there are no designated heritage assets within the site, the site lies adjacent to the Kite Conservation
Area and Christ Church (Grade II). We welcome the preparation of the HIA. We welcome the changes made to the policy wording.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/MRG: Milton Road Garages
Representation ID: 213925
Received: 24/09/2026
Respondent: Historic England
There are no designated heritage assets within the site or nearby. We welcome criterion 1a and reference to local context, contextually appropriate materials and skyline.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/SCL: Land South of Coldham's Lane, Cambridge
Representation ID: 213926
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
There are no designated heritage assets within the site or nearby. We welcome the preparation of the HIA. We welcome reference to St Andrews church. Part of the HIA refers to viewpoint 7 and part refers to viewpoint 10. The policy itself criterion 1b refers to Viewpoint F. Please check and clarify which viewpoint it is. The strategic views from Lime Kiln Road (E) and also from Worts Causeway (J) are also likely to be affected. Therefore, these should also be referenced in the policy.
The policy itself criterion 1b refers to Viewpoint F. Please check and clarify which viewpoint it is. The
Page 4 of 28 strategic views from Lime Kiln Road (E) and also from Worts Causeway (J) are also likely to be affected.
Therefore, these should also be referenced in the policy.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/BRN: Land at Barnwell Road and Newmarket Road
Representation ID: 213927
Received: 24/09/2026
Respondent: Historic England
There are no designated heritage assets within the site or nearby. We welcome the preparation of the HIA. We welcome the changes made to the policy wording.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/TRP: Travis Perkins, Devonshire Road
Representation ID: 213928
Received: 24/09/2026
Respondent: Historic England
Whilst there are no designated heritage assets within the site, the site lies adjacent to the Mill Road
Conservation Area. We welcome the preparation of the HIA.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/BFS: Brookfields
Representation ID: 213929
Received: 24/09/2026
Respondent: Historic England
Part of this site lies within the Mill Road Conservation Area. Any development of the site has the potential to impact upon the significance of the Conservation Area.
We welcome criterion 1a, 1b and 1c.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/SRW: Station Road West
Representation ID: 213930
Received: 24/09/2026
Respondent: Historic England
Whilst there are no designated heritage assets within the site, the site lies adjacent to the New Town and
Glisson Road Conservation Area. The site is also close to the Grade II listed Railway Station. We welcome the preparation of the HIA. We welcome the changes made to the policy wording.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Comment
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/BJH: Betjeman House
Representation ID: 213931
Received: 24/09/2026
Respondent: Historic England
This site is located in the Glisson Road and New Town Conservation Area, lies adjacent to the Grade II*
Botanic Gardens, a registered park and garden and close to the Grade II listed War Memorial and milestone.
We welcome the preparation of the HIA. We appreciate the site is under construction but welcome the reference to the scenario should the permission not be completed.
We welcome the reference to the retention of the Flying Pig House.
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/C/OPM: Old Press/Mill Lane
Representation ID: 213932
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
We note that the site boundary has been amended since the Regulation 18 version of the Plan. Therefore,
unfortunately the revised policy wording for criterion 1a is now incorrect. Paragraph 3.1.62 therefore needs to be amended to correctly recognise the designated heritage assets.
Please amend as follows:
‘Development must protect and enhance the setting, significance and character
of the Historic Core, Central Conservation Area and any designated assets within, or in close proximity to, the site and their settings. Grade II Listed Buildings within the site include the Cambridge University Press (Pitt Press) and
the Telephone Kiosks Outside Pitt Building. Listed buildings nearby include Queens College, Pembroke College and Chapel and St Botolphs Church (all GI), Little St Marys Church (GII*) and numerous GII listed buildings.
Queens College GII Registered Park and Garden lies close to the site. A Heritage Impact Assessment must be prepared to inform any masterplanning and proposals for the site and to inform any heritage mitigation and enhancement measures.’
Paragraph 3.1.62 therefore needs to be amended to correctly recognise the designated heritage assets.
‘There are two Grade II Listed Buildings within the site boundary the Cambridge University Press (Pitt Press) and the Telephone Kiosks. There are also a number of listed buildings in close proximity to the site including several Grade I and Grade II* buildings. There are Buildings of Local Interest (BLI) located within the site. As a result of development proposals, the setting of Listed Buildings in close proximity to the site, the Cambridge Historic Core and, and the Central Conservation Area and its setting, should be protected and enhanced (where the opportunity to do so arises through the improvement of the surrounding public realm). Buildings of Local Interest (BLI) within the site (the Anchor Pub and Laundress Lane Warehouse), together with other buildings identified as making a positive contribution to the Central Conservation Area.’
The final sentence doesn’t quite make sense and needs to be reworded. It would also benefit from being moved
to before the previous sentence.
Finally, in order to mirror the New Museums site policy, we recommend adding the following wording to the end
of criterion 1a
‘This must also be submitted with any application.’
Historic England recognises the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of its rich architectural and cultural heritage. We are keen to support sustainable growth in the right locations, but this growth must be carefully managed to ensure that the very things that contribute to the success of the City and surrounding area are not harmed in the process.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters. Our comments below should be read with reference to our previous comments. We do not have capacity to review every aspect of the Plan but instead have focussed our comments on key issues of soundness for the historic environment.
SUMMARY
As a general comment, Historic England welcomes the emerging plan and work undertaken to date. We can see the incorporation of many of the comments we have made in previous consultations which is appreciated. We particularly welcome the substantial effort that has been made in preparing a comprehensive evidence base including both strategic and site- specific heritage impact assessments (HIAs), topic papers, skyline and tall buildings strategy, townscape characterisation study, landscape sensitivity assessment including renewable energy assessment.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan, and where some small changes would, we believe, bring an enhancement and increase soundness.
Under paragraph 36 of the NPPF some aspects of this Plan are in our view, unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified below some of the key areas where we find the Plan unsound and what measures are needed to make the Plan sound.
In summary we highlight the following three issues namely
Beyond that, based on our review we have identified three key issues to be addressed in
1. Site Allocations 2. Policy GP/HA: Designated heritage assets 3. Approach to renewable energy schemes
These issues are explored in more detail below.
This letter should be read in conjunction with Appendix A which provides more detailed comments on these and other issues. Some of these are more minor and some are factual/textual changes.
Key Issues
1. Site Allocations
There are a number of site allocations where we have suggested some changes to policy wording, supporting text or the Strategic Framework diagrams. In particular, we highlight the following three sites (although there are other site-specific issues raised in Appendix A).
a) Cambridge East - We have highlighted the need to incorporate the HIA recommendations in relation to strategic landscaping, open space to northeast of site and heritage setting for airport buildings within the policy and strategic framework diagram. b) Eddington - We have expressed some concern regarding the inconsistency between the HIA recommendations in relation to height and the draft policy wording. c) Grange Farm We have raised some concerns about the references to the potential for a northern access road close to the Roman Road scheduled monument and impacts on the historic environment. We also highlight some concern regarding the approach to recreational access to the Roman Road.
We have set out a number of suggested changes in order to make the policies sound, both in terms of consistency with the NPPF and also justified by the evidence.
For policies to be effective and consistent with the NPPF, it is important that policies include sufficient information regarding criteria for development, justified by appropriate evidence (the heritage impact assessments). Paragraph 16d of the NPPF states that policies should provide 'a clear indication of how a decision maker should react to a development proposal'.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002-20190315Revision date: 15 03 2019 also makes it clear that, 'Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.'
Historic England's Advice Note on Site Allocations HEAN3 (referenced in Planning Practice Guidance Paragraph: 045 Reference ID: 61-045-20190315 Revision date: 15 03 2019) makes it clear that assessment should consider maximising enhancements and avoiding harm through (amongst other things) identifying design requirements including open space, landscaping, protection of key views, design, layout etc.
The advice note also includes a section on site allocation policies at paragraphs 3.1 - 3.2. It states, 'The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are implemented.'
2. Policy GP/HA: Designated heritage assets
Criterion 5 Whilst we appreciate that you have deleted the words Enabling Development, and essentially summarised the enabling development policy, we continue to advise that this whole criterion should be deleted. We recognise that you are seeking ways to support heritage and this is a laudable ambition. Nonetheless, reference to enabling development is not appropriate within the Local Plan context. 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. A local plan should adequately set out a positive strategy for the historic environment without the need to include reference to enabling development with a a policy.
3. Policy LP 17 Approach to renewable energy schemes
Historic England is supportive of renewable energy development and therefore the inclusion of a policy for renewable energy.
Whilst we welcome changes to paragraphs 4.45 and 4.50 in relation to the historic environment and need for heritage impact assessment, the Policy itself must also include reference to the need for detailed heritage impact assessment.
Further to recent discussions with the Council regarding the District Heat Network, we have recommended some the changes to Policy wording and supporting text.
Sustainability Appraisal
We make the following brief comments and observations based on a brief review:
a. The Summary Sustainability Appraisal Table on page 17 pf the Non-Technical Summary is welcome and useful is providing a brief overview of the SA. However, the title for Table 2 on page 17 is incorrect - Table 3 relates to cumulative effects, not table 2. b. We note that each site has now been assessed separately which is welcomed. C. We note that many of the policies are assessed as having significant positive or minor positive effects. However, there are quite a number of policies where effects are assessed as uncertain.
Other comments
In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Due to limited capacity, we have not been able to review every policy and potential site allocation in detail. Instead, we have focused on policies with the most direct relationship to the historic environment. Please note that absence of a comment on an allocation or document in this letter does not therefore mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. We trust that these comments are helpful to you in developing the Local Plan.
Attachments:
- Response Form (179.03 KB)
- HE Response (225.29 KB)
- Appendix A Table of HE comments (370.88 KB)
