Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Policy S/EOC/NWO: Land North of Worts’ Causeway
Representation ID: 213954
Received: 24/09/2026
Respondent: Historic England
There are no designated heritage assets within the site. The Grade II listed Milestone lies just to the east of the
site. 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/EOC/SWO: Land South of Worts’ Causeway
Representation ID: 213955
Received: 24/09/2026
Respondent: Historic England
There are no designated heritage assets within the site. The Grade II listed Milestone lies just to the east of the
site.
We welcome the changes made to the policy wording.
For accuracy, The Policy name is Policy S/EOC/NWO: Land north of Worts’ Causeway when presumably it
should be Policy S/EOC/SWO: Land south of Worts’ Causeway
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/EOC/FRE: Fulbourn Road East
Representation ID: 213957
Received: 24/09/2026
Respondent: Historic England
There are no designated heritage assets within the site. The Fulbourn Hospital Conservation Area lies to the
northeast of the site. 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/EOC/IDH: Ida Darwin Hospital
Representation ID: 213958
Received: 24/09/2026
Respondent: Historic England
There are no designated heritage assets within the site. The Fulbourn Hospital Conservation Area lies to the
southwest of the site whilst the Settlement Site by Caudle Corner Farm Scheduled Monument lies immediately
to the north of the site.
Any development of this site has the potential to affect these heritage assets and their settings. There does not appear to be an HIA for this site. However, we appreciate that planning permission has been granted for this site and construction is progressing. We welcome criterion 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)
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/AMC/FH: Fulbourn Hospital Area of Major Change
Representation ID: 213961
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
The site lies within the Fulbourn Hospital Conservation Area. The Settlement Site by Caudle Corner Farm
Scheduled Monument lies to the north east of the site. Any development of this site has the potential to affect
these heritage assets and their settings.
There does not appear to be an HIA for this site.
We broadly welcome criterion 1b and recommend the addition of the words '...and Caudle Corner Farm
Scheduled Monument' to the end of the sentence.
We broadly welcome criterion 1c but recommend the following modification '... Fulbourn Hospital Conservation
Area and Caudle Corner Farm Scheduled Monument.'
We broadly welcome criterion 1b and recommend the addition of the words '...and Caudle Corner Farm
Scheduled Monument' to the end of the sentence.
We broadly welcome criterion 1c but recommend the following modification '... Fulbourn Hospital Conservation
Area and Caudle Corner Farm Scheduled Monument.'
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/CBN: Cambourne North
Representation ID: 214019
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
Two listed buildings are located on the site, alongside other nearby heritage assets.
We welcome changes made to policy and supporting text and, the open space around the heritage assets on site (figure 78).
Changes to policy 14 ci and 14 d are suggested to allow for the conversion/restoration of the farmhouse and barns and finding a suitable use together with a conservation management plan and, that the policy should use the HIA recommended wording for areas of known archaeological sensitivity. Also, additional wording is needed in relation to archaeological assessment.
In 14 d Areas of known archaeological sensitivity should be referenced in the policy using the recommended wording from the HIA
Areas of potential high archaeological significance should be given the same consideration and protection as Scheduled Monuments. As such they should not be subject to development, and site layout should accommodate physical conservation of remains.
In addition, the following wording is needed in relation to archaeological assessment
A desk-based assessment should be undertaken to inform the masterplanning process. It is noted that field investigations are currently underway by East West Rail Co. in the south of the site as part of the DCO process for the new railway line connecting Cambourne and Cambridge. The results of this investigation may inform a future listing review
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/CB: Cambourne
Representation ID: 214020
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
Great Common Farmhouse listed at grade II lies within the site boundary. There are numerous listed buildings to the south, west and east of Cambourne, a number of scheduled monuments in the area and, two further registered parks and gardens. Any development of this site has the potential to affect these heritage assets and their settings. We welcome the changes made to the policy wording at criterion 3.
The policy should also reference the two nearby Registered Parks and Gardens, Bourn Hall (Grade II) and Longstowe Hall (Grade II*)
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/GF: Land adjacent to A11 and A1307 at Grange Farm
Representation ID: 214021
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
HIA for site is welcomed. As it notes that there will be a high risk of residual harm it is essential that every opportunity is taken to mitigate impacts and also maximise enhancements for heritage.
Welcome many of the changes to policy wording. Recommend criterion 12f separated into two criteria for clarity. Recommend wording for Criterion 21 is amended to carefully manage access onto the SSSI/ Scheduled Monument/PROW Roman Road and provide alternative walking/recreational opportunities within the SEA to minimise recreational pressure on sensitive ecological and heritage area. Concern at potential for infrastructure to be located in the SEA, contrary to focus as a buffer zone to the scheduled monument.
Northern access unacceptable due to likely harm to wider Roman Road setting, inconsistent with the HIA and NPPF. This is not justified by the evidence and potential impacts have not been explored. Proposal is contrary to the Regulation 18 Plan which demonstrated that the access to the site would be from the A1307.
Suggested amendments are provided for figure 68, and for supporting text at 3.3.53/ 3.3.55 and 3.3.57-58.
We recommend that the wording is amended to ‘Carefully manage access onto the SSSI/ Scheduled Monument/PROW Roman and provide alternative walking/recreational opportunities within the Strategic Enhancement Area to minimise recreational pressure on sensitive ecological and heritage areas’.
3.3.55: the reference to the Barrows in this paragraph should be updated to identify them as a scheduled monument, following their recent designation.
We recommend that the final clause of the last sentence of paragraph 3.3.57and all of paragraph 3.3.58 should be deleted. Figure 68 should also be amended.
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/BA: Bourn Airfield New Village
Representation ID: 214022
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
There are no designated heritage assets within the site but there are some Grade II barns to the north of the Grange. I the Strategic Enhancement Area to the south of the site allocation. Great Common Farmhouse (also Grade II listed) lies to the west of the site. Bourn Village and Hall Conservation Area lies to the south of the site. We welcome the changes made to the policy wording
Figure 72: This should also identify nearby heritage assets (much as the other Spatial Frameworks do)
Figure 72: This should also identify nearby heritage assets (much as the other Spatial Frameworks do)
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/RSC/WGC: Wellcome Genome Campus - Expansion Land, Hinxton
Representation ID: 214023
Received: 24/09/2026
Respondent: Historic England
Legally compliant? Yes
Sound? No
As policy now just relates to the expansion area, wording will need to be changed accordingly to reflect the appropriate heritage assets. We suggest amending criterion 7 wording to more accurately reflect what assets are within the site and nearby.
The expansion site (largely to the east of the A1301) includes part of the Hinxton Conservation Area. There are no listed buildings within the expansion area, but there are a number nearby which may be impacted.
Welcome some of the changes made to the policy wording and welcome paragraphs 3.4.17 and 3.4.18.
Criterion 7 should be amended to more accurately reflect what assets are within the site and nearby. We recommend the following wording:
‘a. Hinxton Conservation Area within and to the west of the site. Design mitigation…..’
b. Listed Buildings nearby including the grade II* Hinxton Hall and St Johns Church and various grade II listed buildings.
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)
